Billington Lodge privacy policy

We are the controller of your personal data. For more information on controllers and their

responsibilities please see our data protection and data security policy (POL-007)

This privacy policy tells you what to expect us to do with your personal information when you:

1. Work for us.

2. Contact details

3. What information we collect, use, and why

4. Lawful bases and data protection rights

5. Where we get personal information from

6. How long we keep information

7. Who we share information with

8. How to complain

Contact details

Telephone: 07561428571

Email: mfeerick@billingtonlodge.co.uk

What information we collect and use, and why

1. Staff recruitment, administration and management

We collect or use the following personal information as part of staff recruitment,

administration and management:

1. Contact details (eg name, address, telephone number or personal email address)

2. Date of birth

3. National Insurance number

4. Gender

5. Photographs (eg staff ID card)

6. Copies of passports or other photo ID

7. Next of kin or emergency contact details

8. Employment history (eg job application, employment references)

9. Details of any criminal convictions (eg DBS checks)

10. Performance records (eg reviews, disciplinary records, complaints or disciplinary action)

11. Training history and development needs

12. CCTV footage or other recordings

We also collect or use the following special category information for staff recruitment,

administration and management. This information is subject to additional protection due to its sensitive nature:

1. Racial or ethnic origin

2. Religious or philosophical beliefs

3. Health information

4. Sexual orientation information

2. Staff health and wellbeing:

We collect or use the following personal information for managing staff health and wellbeing:

1. General health and wellbeing information

2. Accident at work records

3. Access needs or reasonable adjustments

4. Protected Characteristics (as defined by the Equality Act and s.75 of the Northern Ireland Act for the purpose of equal opportunities monitoring)

We also collect or use the following special category information for managing staff health and

wellbeing. This information is subject to additional protection due to its sensitive nature:

1. Health information

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions

which may apply on the ICO’s website:

1. Your right of access - You have the right to ask us for copies of your personal

information. You can request other information such as details about where we get

personal information from and who we share personal information with. There are

some exemptions which means you may not receive all the information you ask for.

2. Your right to rectification - You have the right to ask us to correct or delete personal

information you think is inaccurate or incomplete.

3. Your right to erasure - You have the right to ask us to delete your personal

information.

4. Your right to restriction of processing - You have the right to ask us to limit how

we can use your personal information. 

5. Your right to object to processing - You have the right to object to the processing of

your personal data.

6. Your right to data portability - You have the right to ask that we transfer the

personal information you gave us to another organisation, or to you.

7. Your right to withdraw consent – When we use consent as our lawful basis you

have the right to withdraw your consent at any time.

If you make a request, we must respond to you without undue delay and in any event within

one month.

To make a data protection rights request, please contact us using the contact details at the

top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information as part of staff recruitment, administration and management are:

1. Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

2. Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

3. Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

4. Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information as part of managing staff health

and wellbeing are:

1. Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

2. Legitimate interests – we’re collecting or using your information because it benefits you,our organisation or someone else, without causing an undue risk of harm to anyone. All ofyour data protection rights may apply, except the right to portability. 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

3. Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Where we get personal information from

We collect your information from the following places:

1. Directly from you

2. Referees (external or internal)

3. Security clearance providers

4. CCTV footage or other recordings

How long we keep information

Billington Lodge has set the following guidelines for retaining all personal data as

defined in the Institute’s data privacy policy.

1. Website visitor data will be retained as long as necessary to provide the service

requested/initiated through the Billington Lodge website.

2. Contributor data will be retained for the year in which the individual has contributed and then for 6 months after the date of the last contribution. Financial information will not be retained longer than is necessary to process a single transaction.

3. Event participant data will be retained for the period of the event, including any follow up activities, such as the distribution of reports, plus a period of 6 months;

4. Program participant data (including sign in sheets) will be retained for the duration of the grant agreement that financed the program plus any additional time required under the terms of the grant agreement.

5. Personal data of subgrantees, subcontractors and vendors will be kept for the duration of the contract or agreement.

6. Employee and volunteer data will be held for the duration of employment and then 6 months after the last day of employment.

7. Recruitment data, including interview notes of unsuccessful applicants, will be held for 6 months after the closing of the position recruitment process.

8. Consultant (both paid and pro bono) data will be held for the duration of the

consulting contract plus 6 months after the end of the consultancy.

9. Board member data will be held for the duration of service on the Board plus for 6 months after the end of the member’s term..

10. Operational data related to program proposals, reporting and program management will be held for the period required by the Billington Lodge donor

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above. 

Who we share information with

In some circumstances, we may share information with the following organisations:

External authorities - police, LADO, social services

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us

using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113