This privacy notice sets out how Dogwood Adventure Play uses and protects any information that you give us.
Dogwood Adventure Play is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, then you can be assured that it will only be used in accordance with this privacy notice. Dogwood Adventure Play may change this policy from time to time and will update clients directly should it do so and amend the website for all non-clients.
To ensure that we treat your personal details with care we promise to
- Always hold your details securely.
- Never share your information.
- Only ever get in touch in the ways that you wish, and we’ll make sure that everything we send to you is relevant to our work, products and services.
- We will adhere to your current communications preferences.
- Only analyse your data in order to communicate with you more effectively and better understand your preferences.
- Make sure you’re in control of your information, and that you can ask us to stop using it whenever you like.
What we collect:
• Contact information including email address
What we do with the information we gather:
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
• Internal record keeping. We may use the information to improve our products and services and will use it to keep your record up to date.
• We will not pass your information to any third party.
By submitting your personal information and indicating that you would like to receive further information from us, you consent to us using your personal information in the above ways.
How long do we keep information?
If you are a client will keep your information on our secure database and regularly check to ensure we hold the most current details for you.
The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
Dogwood Adventure Play (‘we’ or ‘us’ or ‘our’) are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Bill.
Dogwood Adventure Play are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and on-going compliance.
How We Prepared for the GDPR
· Information Audit – carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
· Policies & Procedures – implementing new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: –
o Data Protection – our main policy and procedure document for data protection meets the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
o Data Retention & Erasure – we meet the ‘data minimisation’ and ‘storage limitation’ principles and personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
o Data Breaches – The Information Commissioner’s Office (ICO) will be immediately informed of any hack or breach.
o International Data Transfers & Third-Party Disclosures – we do not transfer personal data or disclose it to third parties.
o Subject Access Request (SAR) – we accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
· Legal Basis for Processing – each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
· Privacy Notice/Policy – our Privacy Notice(s) complies with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
· Obtaining Consent – our consent mechanisms for obtaining personal data ensure that individuals understand what they are providing, why and how we use it and give clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
· Direct Marketing – we have clear wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
· Data Protection Impact Assessments (DPIA) – we do not process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data.
· Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.
· Special Categories Data – we do not process any special category information.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information in our office of an individual’s right to access any personal information that Dogwood Adventure Play hold about them and to request information about: –
· What personal data we hold about them
· The purposes of the processing
· The categories of personal data concerned
· The recipients to whom the personal data has/will be disclosed
· How long we intend to store your personal data for
· If we did not collect the data directly from them, information about the source
· The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
· The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
· The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Information Security & Technical and Organisational Measures
Dogwood Adventure Play takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures.
GDPR Roles and Employees
Dogwood Adventure Play has designated Katie Guastapaglia as our Data Protection Officer (DPO) to develop and implement compliance with the new data protection Regulation, promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
Dogwood Adventure Play understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR.