GDPR & Privacy Policy
Background
In this Policy the following terms shall have the following meanings:
CS Disabled Holidays understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://csdisabledholidays.co.... (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested at the time that you submit any data to the site.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account”
means an account required to access and/or use certain areas and features of Our Site;
“Cookie”
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14
“Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
Information About Us
Our Site is operated by CS Disabled Holidays Ltd. We are a company limited by guarantee registered in England and Wales under company number No. 09221328. Our registered address is Hunters, 9 New Square, Lincoln's Inn, London WC2A 3QN. We are a charity which provides access (through the provision of grants) to holidays for the severely physically disabled who have neurological or neuromuscular illness, and for the unpaid carers to those severely physically disabled through a property matching service.
We are not registered for VAT
The Data Protection Controller is CS Disabled Holidays Ltd.
The Data Protection Officer is Joanna Lees a Director and Trustee.
The Email address for all questions with regards to the Privacy Policy and our compliance with the General Data Protection Regulations is JoannaL@csdisabledholidays.co.uk.
We are Registered and Regulated by the Information Commissioner's Office
What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simple terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
- For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
- It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed if we have that data.
- Further information about your rights can also be obtained from the Information Commissioner's Office or your local Citizens Advice Bureau.
- If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
What Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal [and non-personal] data set out in the table below, using the methods also set out in the table. Please also see Part 14for more information about our use of Cookies and similar technologies and our Cookie Policy <<insert link>>.
Data Collected
How We Collect the Data
Identity Information including e.g. title, first name, Family Name, date of birth, gender
Application Form
Your consent to our GDPR and Privacy policy
Applications Forms and Donor Forms – anywhere where we will be storing data on an individual
Your acknowledgement/agreement to terms and conditions with regards to applications for grants or property matching services
Application forms
Contact information including postal address, email address and telephone number
Application form, donation form, contact for
Details about who is completing the form, Name, email and contact telephone number, plus relationship to the applicant
Application Form
Payment information, including method (bank transfer or cheque) to who it should be paid to, bank details.
Details about your illness
Application form
Levels of disability - do you use a wheelchair, hoist or ventilator or other items to assist you
Application form
We ask about what items you need help with - such as eating, washing, bathing, dressing, night checks or turning, toileting, PEG Feeding, Bladder Care, Bowel Care, Stoma Care, Tracheostomy Care, Pressure Area Care, and other care needs
Application Form
We ask why a holiday at this time would benefit you in particular
Application Form
How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will or may use your personal data, and our lawful bases for doing so:
What We Do
What Data We Use
Our Lawful Basis
Registering you on Our Site.
Through our Application Form
Through our Donor Form
Through our Contact Form
We need to have the data to process your application to identify if you meet the criteria for the relevant service.
We need the details to process the information to obtain your donation.
We need the information to respond to your enquiry
Communicating with you.
Contact information
To minimise costs CS Disabled Holidays Ltd will only communicate with you by electronic means – with every communication – you are provided with the option to opt out of communications – either in part or in entirety. We aim to communicate with you no more than once a quarter to update you with the charities activities.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary considering the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
Type of Data
How Long [We] OR [I] Keep It
Application for services provided from the charity including the details of who applied, their contact details and the reasons for the application
9 Years
Donations to the charity including contact information, who made the donation, and if the donation was made on behalf of someone who that was and why
For no less than 7 years
Contact Enquiry Forms - including contact information and what the enquiry was about
For no less than 7 years
How and Where Do You Store or Transfer My Personal Data?
We will only store your personal data in our database - which is purchased from Blackbaud - and is called Etapestry. It is stored in their Boston Datacentre. Blackbaud take data security very seriously and fulfil the duties set out in the GDPR - as shown in Security | Blackbaud. This means that it will be fully protected under the Data Protection Legislation.
We have clear procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner's Office where we legally required to do so.
- As soon as it is alleged any data has been leaked - all passwords to the database must be changed
- All Trustees must be notified
- The ICO must be notified
- All online communications must be shutdown until the potential leak has been identified and solved.
- A thorough investigation must be undertaken by an independent third party which must report to the Trustees and the ICO within 1 week or quicker if so required.
- The issue must be solved, any parties whose privacy has been breached must be contacted - along with what data has been or may have been breached.
- The ICO must confirm that they are content for operations to resume.
- Operations can resume.
- Do You Share My Personal Data
We will not share any of your personal data with any third parties for any purposes, subject to the following exception[s].
If we sell, transfer, or merge parts of our Charitable business or assets, your personal data may be transferred to a third party. Any new owner of our] charitable business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.]
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.]
How Can I Control My Personal Data?
- In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. We aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails). However, if you wish to apply for the services provided by the Charity, these are only provided through the provision of data through the website - and the storage of that data either for the times stated herein or until you request its removal.
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site, including applying for our charitable services, you will or may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see Cookie Policy or the attached link.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days and, in any case, not more than] one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
How Do We Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and always respected.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for <<insert description of use(s) of third-party cookies>>. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny your consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser's settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
Craft Cookies and GDPR
For GDPR purposes, please note that Craft's default cookies do not collect any personal or sensitive information. Craft's default cookies do not collect IP addresses. The information they store is not sent to Pixel & Tonic or any third parties.
Craft's default cookies are only used to communicate with your Craft installation for the purposes of user authentication, form validation/security, and basic web application operations.
Name of Cookie
Purpose
Strictly Necessary
CraftSessionId
Craft relies on PHP sessions to maintain sessions across web requests. That is done via the PHP session cookie. Craft names that cookie “CraftSessionId”. This cookie will expire as soon as the session expires.
yes
CRAFT_CSRF_TOKEN
If the enableCsrfProtection and enableCsrfCookie config settings are enabled, then a cookie named CRAFT_CSRF_TOKEN will be created to facilitate CSRF protection. It will expire as soon as the PHP session expires.
yes
Currently there are no third-party Cookies placed on your computer or device.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details .
Email address: JoannaL@csdisabledholidays.co.uk
Changes to this Privacy Policy
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 1 May 2023.
Attribution
This Privacy Policy has been created using a document template from www.simply-docs.co.uk