Privacy, Data Protection and Your Personal Information

Privacy Notice

POhWER are a registered charity in England and Wales and Scotland. We provide information, advice, support and advocacy to people who experience disability, vulnerability, distress and social exclusion.

Our charity number for England and Wales is: 1061543 and for Scotland is: SC048858.

Our charity is registered with the Information Commissioner’s Office (ICO) as: a data controller.

Our ICO registration number is: Z8575018.

Our registered company number is: 3323040.

Our registered office address is: Suite 4, Middlesex House, Meadway Corporate Centre, Stevenage, England, SG1 2EF.

We want everyone who supports POhWER, or who comes to us for support, to feel confident and comfortable with how any personal information you share with us will be kept safe. This Privacy Notice explains how we collect, use and store your personal information and your Data Protection Rights. It applies to information we collect about:


Questions about our privacy notice

Any questions you have in relation to this notice, our privacy practices or how we use your personal information should be

  • emailed to our Data Protection Officer at: [email protected]
  • or sent in writing, addressed to:
    Data Protection Officer
    POhWER
    Suite 4, Middlesex House,
    Meadway Corporate Centre,
    Stevenage,
    Hertfordshire
    SG1 2EF


We collect information when you:

  • Make a donation to us, either by post, online (either directly or by using a third party digital platform such as JustGiving etc), over the phone or via SMS/text donation. We also collect information about you when you make a donation to us through setting up a standing order or Direct Debit, or donating via payroll giving (Give As You Earn);
  • Join our mailing list
  • Respond to one of our postal mailings or emails;
  • Complete a campaign action online (signing a petition, for example);
  • Make a purchase from our online shop; 􀁸 Sign up to a fundraising event;
  • Become a Member of POhWER;
  • Agree to or enquire about leaving a legacy;
  • Cookie information when you visit our website;
  • Interact with us over the phone, or on social media;
  • When you apply to work or volunteer for POhWER
  • Contact us through our HelpHub service by phone, email or letter
  • Interact with us in some other way, ie through third party partners working on our behalf.


What information we receive and how we use it

When you engage with us as a supporter, follower or Member we may ask for personal information when you make a donation to us, register for an event or a campaign, subscribe to a newsletter, engage with our social media or communication services or provide us with personal information in any other way. This information may include:

  • Your name, email address, postal address and telephone number;
  • Financial date such as bank account details provided by you, credit/debit card details (if you are making a purchase or donation), and whether donations are gift-aided.
  • A record of the financial donations that you have made and data about your tax status for Gift Aid purposes.
  • Details of opinions, preferences and the ways you support or have supported us, eg in relation to any campaigns, events or fundraising that you have participated in,
  • As well as information you provide in any communications between us. You will have given us this information whilst making a donation, placing an order on our website or any of the other ways you have interacted with us.


We will mainly use this information:

  • To process your donations or other payments, to claim Gift Aid on your donations and verify any financial transactions;
  • To provide the services or goods that you have requested;
  • To update you with important administrative messages about your donation, an event or services or goods you have requested; 
  • To comply with the Charities (Protection and Social Investment) Act 2016 and follow the recommendations of the official regulator of charities, the Charity Commission, which require us to identify and verify the identity of supporters who make major gifts so we can assess any risks associated with accepting their donations; 􀁸 To communicate with you as a Member, and in particular with information regarding our AGM.
  • To keep a record of your relationship with us.


We may also use your personal information:

  • To contact you about our services and how you can support POhWER's work;
  • To invite you to participate in surveys, research or campaigns.


Sensitive Personal Information

General Data Protection Regulation (GDPR) recognises that some categories of personal information are more sensitive, and can include information about a person's health, race, ethnic origin, political opinions, sex life, sexual orientation or religious beliefs. 

We ensure that processing of this sensitive information is lawful, fair and transparent and complies with all the other principles and requirements of the UK GDPR.


Cookies

Cookies are small pieces of code which are downloaded to your computer or mobile device when you visit a website, allowing us to recognise your device on subsequent visits. We use cookies to monitor the status of our website and ensure that it is running efficiently, and we also use cookies to remember your preferences. Cookies are anonymous and are not linked to any personal information. Our search engine does not collect any user-specific data. The search queries and results are logged anonymously to help us improve our website and search functionality.

People who receive support or who refer a friend or family member for support from POhWER


What information we collect and why

The main reason we ask for your information is to help you with your issue or problem. If you are referred to, or have support from POhWER, we will need to keep this information. We will only ask you for the information we need to support you.

Because this information is necessary to provide our service to you, we hold it under the lawful basis of 'legitimate interests'.

This means that a legitimate interest can exist where there is a 'relevant and appropriate relationship' between you and POhWER, i.e. if you are a client.

We will only use this information for the purposes of dealing with your enquiry, supporting you, training, and quality monitoring or evaluating the services we provide.

We might also use your information to:

  • Ask you for feedback about our service;
  • Investigate a complaint.

We will not pass on your details to anyone else without your explicit consent.


Sharing your Information

  1. There are times when we might have to share your information without your permission in exceptional circumstances. If we do, we will always make sure there is a legal basis for us to do so. For example, if we receive a court order, we have to produce information demanded in that order, or the situation might include anyone reporting serious self-harm or posing a threat to others or children contacting us and sharing serious issues such as physical abuse or exploitation.
  2. Only with your permission, we may contact other organisations to help you solve your problem, or because another organisation may be able to help or support you solve your problem.

  3. We might also use data about the support we give you in an anonymised way. Anonymised means that no one will be able to identify you. It means that we will not use your name or any other personal details that would make it possible for someone to identify whose data we are using.

For example, we may use anonymised data to:

  • Create anonymous case studies to raise awareness of our services and for campaigning purposes;
  • Prepare statistical reports, to help us improve our services;
  • To report to our commissioners about the work we do and what demographic groups we have supported.


Storing your information

Data that you submit verbally, either face-to-face or over the phone, by email, letter, paper form or online is stored on our secure case management system, including copies of any emails or correspondence and notes about the support we have given you. Our case management system uses encryption and password protection. Our staff are trained on keeping your information safe.

Calls to our Information, Advice and Advocacy Support Centre are recorded for quality and training purposes. Recordings of these calls are not loaded on to our case management system and are automatically deleted from the secure telephone system six months after the recording is made. If we need to save any of these recordings, for example, to respond to a complaint, we will save that recording under a separate process for handling complaints.

We will retain your information on our case management system for six years after the closure of your case with us (or as determined by individual contracts, if different). After that, your information will be permanently deleted.

People who provide feedback about our services


Why we collect and process your information

When you provide feedback to POhWER we ask you for your contact details so that we can contact you about the feedback you have given us. Feedback can be collected in a number of ways: face-to-face, over the phone, in writing or through our website. Our website uses a third party provider to facilitate collection of feedback and our agreement with that third party ensures they will not process any personal information they collect for us, other than to provide us with the completed feedback form.

Our legal basis in collecting, using and storing personal information from feedback is to review POhWER's performance of our services and this is called a 'legitimate interest'.


Using your information Non-complaint or Concern

When you provide feedback that is not to report on our services, but only in a way that does not identify you.
We may also share anonymous feedback with regulators, government departments and publicly in our reports, social media and website.


Using your information Complaint or Concern

Sometimes things don't go as well as we would like them to and we welcome complaints and concerns as a way will include the identity of the person making the complaint or concern, where they have provided this, as well as any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and check on the level of service we provide. We compile and publish statistics showing information such as the number of complaints/concerns we receive for the local authorities who commission our services, but not in a way that identifies anyone.

We usually disclose the identity of the person raising the complaint or concern to whoever the complaint or concern is about. This is so that we can investigate properly. If someone complains anonymously we may not be able to fully investigate.


Storing your information

Feedback that is not a complaint or concern is kept for five years on our secure system and then deleted.

For Complaints about POhWER's services, we retain this information for six years after the last action. We store this information outside of our client record database on our secure system. Only those people who need to access this information, for example, to investigate the complaint or concern, have access to the complaint/concern folder.

Children and young people

We sometimes receive limited data about children if they decide to help fundraise for us, and we will collect data about children for events we organise specifically for young people. Wherever possible, we will ask for consent from parents to collect information about children and young people under the age of 16.
However, where we are supporting a young person directly, any information will only be shared with their parent or guardian with the young person's consent.

How we will not use the information we collect from you

We will never sell, rent or trade personal information. We will make sure that any personal information we hold is secure, accessible only to those who need to access it, and held for only as long as is needed. We are not involved in data swapping schemes.

Your data protection rights

Under data protection law, you have rights and these are explained in more detail below. If you want more information or guidance about your rights, we will try to help you, or you can contact the Information Commissioner's Office, whose contact details are at the end of this Privacy Notice.

We will usually respond to you within one month. Occasionally it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.

Under most circumstances you will be provided with a copy of the information free of charge. In the rare circumstances where we may charge, we would let you know at the time of your request and any charges would only be based on the administration cost of providing the information to you.


Your right of access

You have the right to ask us for copies of your personal information. This right always applies and is called a Subject Access Request. There are some exemptions, which means you may not always receive all the information we process. You can read more about these exemptions on the your right of access page of the ICO website.


Your right to rectification

You have the right to ask us to rectify information we hold about you which you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.


Your right to erasure - also known as 'Right to be Forgotten'

You have the right to ask us to erase your personal information in certain circumstances. We have already explained how long we keep your personal information after which period our information is permanently deleted. More details on this right can be found on the right to erasure page of the ICO website.


Your right to restriction of processing

You have the right to ask us to restrict the processing of your information in certain circumstances. Details on this right can be found on the your right to limit how organisations use your data page of the ICO website.


Your right to object to processing

You have the the right to object to the processing of your personal data in certain circumstances. This means that in those circumstances, we would still store your information but not process, or use it. Situations where you can ask us to restrict processing can be found on the your right to limit how organisations use your data page of the ICO website.


Your right to data portability

You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances. If our contract with a local authority ends, you have the right to have your information transferred on active cases to a new provider. Either the local authority or we would ask for your permission to do this. Further information can be found on the your right to data portability page of the ICO website.

Data Breaches

A 'personal data breach' means that personal information is disclosed to, or accessed by someone who is not authorised to see it. We make sure that our systems are secure in line with recognised standards but if a personal data breach did happen that involved your personal information, we would tell you as soon as we became aware of it and let you know what we were planning to do about it. We would also tell the Information Commissioner's Office about it and make sure you know how to complain to the Information Commissioner's Office.

People applying for paid vacancies or volunteering positions


Why we collect and process your information

POhWER is the data controller for the information you provide during the process of applying for a job with POhWER or applying to volunteer with us. All of the information you provide during the application process will only be used so that we can progress your application, or to fulfil legal or regulatory requirements if necessary.

The information you provide will be held securely by us and/or our data processors (eg a recruitment agency), whether the information is in electronic or paper format.


Application stage for employment with POhWER

We only collect information that is necessary to the recruitment process, on the basis of consent. This includes contact details, skills and qualifications, past employment and experience, education and referees.

You will also be asked to provide equal opportunities information such as ethnicity and disability. This is not mandatory information and is not used to assess your application. Any information you do provide will be used only to produce and monitor equal opportunities statistics. If you don't provide this information, it will not affect your application.

If your application is shortlisted, you will be asked to attend an interview, which may involve some tests or presentations.
We keep interview notes and any correspondence after the recruitment process ends so that we can investigate if anyone raises a complaint about a recruitment process.

If you are unsuccessful in the application process, we will retain your application for period of six months and then the information will be permanently deleted.


Using your information

We will use the information you provide to progress your application, assess your suitability for the role and communicate about the success of your application.


Application stage to volunteer with POhWER

When you apply to volunteer with POhWER, you will complete an application form. If you are unsuccessful in the application process, we will retain your application for period of six months and then the information will be permanently deleted.


Successful staff and volunteer applicants

If you are successful in your application, we will ask you for information so that we can carry out pre-employment or volunteering checks. You must successfully complete these checks prior to commencing with POhWER. Due to the nature of our work and the client groups you may be supporting or otherwise interacting with, we must seek assurance as to staff and volunteer's trustworthiness, integrity and reliability, particularly through DBS checks and suitable references.


Sharing staff information

We may use recruitment agencies, payroll providers, and workplace pension providers to provide services associated with recruitment and employment. These are data processors. We have contracts in place with them and they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

There are times when we might have to share your information without your permission. If we do, we will always make sure there is a legal basis for us to do that. For example, if we receive a court order, we have to produce information demanded in that order. Or if we have to produce information if there are safeguarding concerns raised that involve you. This also applies to volunteers.

When a contract with a local authority is coming towards the end of its term, we are required to provide certain details to the local authority, who shares those details with other potential providers of the service. These details are required under TUPE legislation and will include length of service and role but no other identifying personal information. If a new provider is appointed and you are eligible for TUPE, HR would notify you that we will be sharing additional personal and/or sensitive information with the new provider. We will only share information as required under TUPE legislation.


Storing staff and volunteers' information

If you are successful, the information you provide during the application process will be retained by us as part of your personnel file. During the course of your employment, we may collect further personal or sensitive information with your permission, for example, the results of occupational health assessments. This information will be retained for the period of your employment plus 6 years following the end of your employment.

During the course of your volunteering you may want to tell us about any health issues that impact on your volunteering. This information will also be retained for the period of your volunteering plus 6 years following the end of your volunteering.

Contact Details

If you would like more information or further explanation of POhWER's Privacy Policy or the collection and use of personal information, please contact our Data Protection Officer using the contact details below.

  • By email to: [email protected] for the attention of the Data Protection Officer
  • or in writing to:
    Data Protection Officer
    POhWER 
    Suite 4, Middlesex House
    Meadway Corporate Centre
    Stevenage
    Hertfordshire
    SG1 2EF

If you are unhappy with the way that POhWER has handled your information, you can make a complaint to us, using the contact details above, or you can complain to the Information Commissioner's Office:

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