LIGHTHOUSE DATA PRIVACY NOTICE
updated 28th February 2023
1. Your personal data – what is it? Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).
2. Who are we? Throughout this policy, the term ‘Lighthouse’ shall be taken to mean, collectively the Data Controller, namely:
Lighthouse Central is the Data Processor, processing data on behalf of the Data Controller. This means it decides how your personal data is processed and for what purposes.
Data Processor: Lighthouse Central Registered Charity No. 1169839
Our registered office is Bridge House, Station Approach, Great Missenden, Buckinghamshire HP16 9AZ
There is one other Lighthouse that is not part of Lighthouse Central: Great Missenden registered Charity No 1071892 (Lighthouse88). They will have their own Data Privacy Notice.
3. How do we process your personal data? Lighthouse complies with its obligations under the “GDPR” by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. All personal data is kept on central IT systems and is not stored or transported on portable electronic devices.
We use your personal data for the following purposes:
4. What is the legal basis for processing your personal data?
5. What information do we collect about you?
We collect information about you when you volunteer with us that includes your date of birth, address and telephone number, email address along with answers to the following declaration questions:
Please note that DBS checks are carried out on behalf of Lighthouse by Peters Research Ltd.
b) Parents and children
We collect information about you when you register a child for a place at Lighthouse that includes your address details and the date of birth, health and special needs information of your children.
6. Sharing your personal data
Your personal data will be treated as strictly confidential. Lighthouse will not share your information for marketing purposes with anyone else unless obliged by law.
You have a right at any time to stop us from contacting you. If you no longer wish to be contacted by Lighthouse, please contact firstname.lastname@example.org
7. Who sees your information?
Lighthouse considers the following information to be confidential:
Confidential information shall be seen only by Lighthouse Trustees and other individuals nominated by them (including admin staff and key leaders such as Age Group Leaders and activity co-ordinators). In all other cases data is only shared on a strict need-to-know basis.
For example, an Age Group Leader or Teacher will generally only receive the names of the volunteers and children assigned to their age group. They may receive health and special needs information if a leader or child has a health condition or special needs that will impact upon them during their time on-site, whether this be behaviourally or through the requirement for medication.
Any printed reports are collected at the end of Lighthouse and securely destroyed.
8. How long do we keep your personal data?
Lighthouse retains all data collected about volunteers and children for a period of two years from the time it is first given. This time period is renewed when a volunteer or child registers again for Lighthouse.
The data for volunteers shall be used each spring to contact those who have volunteered in previous years. At this point, volunteers have the choice to register again for Lighthouse, ask for their data to be kept on file and for them to be contacted the following spring, or for their data to be deleted.
For the avoidance of doubt, if a volunteer registers and then in the subsequent two years requests for their data to be kept on file and for them to be contacted again, the second request will see the data kept for a third year after it was originally given. If no response is given the following spring (i.e. spring of year 4 where data was registered in year 1), the data will be deleted.
9. Exception to the two year period
In accordance with its duty of care responsibilities to all volunteers and children attending Lighthouse, Lighthouse will exceptionally keep a volunteer’s data on file for more than two years if that data indicates that the said volunteer could pose a threat to others, and the trustees or individuals nominated by them consider there to be a reasonable risk of that person attempting to register at Lighthouse again in the future.
It is required by our Insurers that records of who attended training and who attended Lighthouse is kept for 15 years. This will be on the basis of data sufficiency: name, role at Lighthouse and Lighthouse location only and will be archived on a secure database at Lighthouse Central
We retain gift aid declarations and associated paperwork for up to 6 years after the calendar year to which they relate.
10. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: -
11. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
12. Changes to our Data Privacy Notice
13. Contact Details
To exercise all relevant rights, queries or complaints please in the first instance email email@example.com or write to us at the following address:
Lighthouse Central, Bridge House, Station Approach, Great Missenden, Buckinghamshire HP16 9AZ
You can contact the Information Commissioners Office on 0303 123 1113
Their normal opening hours are Monday to Friday between 9am and 5pm (excluding bank holidays).
Live chat service https://ico.org.uk/global/contact-us/live-chat/ Available 9am-5pm Monday to Friday (excluding bank holidays).
Or write to the ICO at: The Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5A