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Revised Privacy Statement

Wednesday 23 May 2018

Privacy Notice

Last updated: 21st. May 2018 2018

How BAC uses your information

This privacy notice tells you what to expect when Belfast Activity Centre (hereinafter referred to as BAC) collects your personal information and how BAC plans to use that information.

From 25 May 2018 the EU General Data Protection Regulation (GDPR) replaces existing EU data protection regulations. It is designed to harmonise data privacy laws across Europe, to protect and empower all citizens’ data privacy and to reshape the way organisations across the region approach data privacy. For more information you can refer to the Information Commissioner’s Office: ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/

As someone who has engaged with BAC and about whom we hold any personal data, in the terms applies by GDPR you are a data subject.

BAC is a data controller, because we determine how and why personal data is processed.

BAC is also a data processor, in that we process personal data in order to administer a service. We will also, from time to time, use third party data processors primarily for the purposes of receiving electronic payments.

BAC is committed to upholding the principles of the GDPR when processing personal data. These are set out in article 5 of the GDPR stipulating that any personal data captured and held shall be:

1.     Processed lawfully, fairly and transparently

2.     Collected for specified purposes, and not processed for other purposes

3.     “Just the right amount” of data for the task at hand – not too much, but enough to do your job accurately

4.     Accurate and up to date

5.     Kept no longer than necessary

6.     Processed securely.

BAC has a security and confidentiality policy in place that all staff adhere to.

BAC is also registered as a Data Processor with the Information Commissioner’s Office (ICO).

Visitors to our website

BAC operates the website www.belfastactivitycentre.com as the main sources for information on our work, the services we provide and how to contact us.

Use of cookies by BAC

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive. No user-specific data is collected by us or any third party.

Information collection and Use

While using our website under the links “Make an activity booking” or “Contact us”, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, personal information such as your email address, contact telephone number and your name and/or the name of the group or organisation that you are representing through making an activity booking.

We may use third party services such as Google Analytics to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not allow identification. We do not make any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, for example through our “Make an activity booking” or ‘Contact us’ form, we will explain the purpose for collecting personal information and how this information will be used by BAC.

Search engine

Search queries and results are logged anonymously to help us improve our website and search functionality. No user-specific data is collected by BAC or any third party.

Security and performance

BAC uses a third party service to help maintain the security and performance of the BAC website www.belfastactivitycentre.com Addresses are not stored when we have visitors to our website. BAC uses a third party service, TIBUS (Level 7, City Quays 2, Clarendon Road, Belfast BT1 3FD. Tel. +44 (0) 28 9033 1122, email: belfast@tibus.com) to host and help maintain the security and performance of the BAC website www.belfastactivitycentre.com

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over, and assume no responsibility for, the content, privacy policies or practices of any third party sites or services.

Contact us form

We collect information from individuals, groups, organisations and others who contact us with a request for information, a query or a comment. Information provided is processed and stored in order to provide an information service to stakeholders. Your details may be forwarded within BAC to the appropriate member of BAC staff in order to deal with your query. This information will not otherwise be shared.

Using BAC services

BAC offers various services to stakeholders. We have to hold certain details of the people who have requested a service in order to provide it. However, we only use these details to provide the service that the person has requested and for other closely related purposes unless we have a clear consent to use the information for other specified purposes.

Provision of outdoor adventure learning activities, residential and camping activities, facilities booking (including on-site conference and training rooms):

Information will be required from individuals, groups, organisations and others as prospective or returning clients in order to provide an efficient activity booking and payment service. This may include names, contact details, personal data relating to prospective activity participants (name and date of birth/age at last birthday). Personal data requested will be kept to a minimum and only that information which is required as an essential component of providing the service (in line with the legislation) and to keep clients updated, will be requested. Clients may be asked if they consent to be contacted with broader information about the work of BAC or other future BAC organised events or activities. Consent once given can be subsequently withdrawn at any time.

For making an activity booking, BAC does not capture or process data within the ‘special categories’ relating to racial or ethnic origin, political opinions religious or similar beliefs, trade union membership, sexual life, sexual orientation, biometric or genetic data, and personal data relating to criminal offences and convictions. BAC will invite all prospective activity participants making an activity booking to complete a self-declaration medical form (special category relating to physical or mental health conditions) to support BAC risk assessing every prospective activity participant prior to takin g part in any adventure learning activity.

Provision of an HR service:

Information will be required from employers in order to provide HR services such as recruitment and from Access NI checks for child protection purposes for prospective employees. Personal data requested will be restricted to a minimum as that information which is required to support BAC recruitment policy and procedures.

Responding to enquiries, queries, complaints and feedback:

Communications may be received through postal services, electronic mailing or by telephone. These will be passed to the relevant BAC staff member for an answer or response. Personal data is removed or anonymised when it is no longer necessary in relation to the purpose of administering a response or to provide a follow on service such as an activity or facility booking. Personal data held is maintained and amended as necessary, when updates are provided by service users.

Service providers

BAC may employ third party companies and individuals to facilitate our own service provision such as providing an outdoor adventure learning activity service on our behalf. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Security

The security of your personal information is important to BAC, but BAC would stress that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. As such we make no warranties as to the level of security afforded to your data, except that we will always act in accordance with the relevant UK and EU legislation.

Children’s Privacy

Our “Make an activity booking” service does not address anyone under the age of 17 years of age (ie. children and young people) However, BAC may process data relating to children and young people (names, dates of birth/age at last birthday) as a necessary requirement of delivering an adventure learning activity. Personal data is limited to only that which is essential and a necessary requirement of delivering an outdoor adventure learning activity.

BAC will address individual enquirers under the age of 17 years of age in direct response to a “contact us” enquiry. Personal data is limited to only that which is essential and a necessary requirement of responding to an enquiry, query, complaint or feedback.

Communications

Outdoor Adventure Learning Activities updates and fundraising events and activities.

BAC may communicate through postal or electronic updates on the provision of events and activities organised and delivered by BAC within the context of our services as a registered Charity providing personal and social development opportunities through the medium of outdoor adventure learning activities. . We will send you these using the information provided by you at your first point of contact with BAC. We will do this on the basis that there is a legitimate interest to share communication with you for the purposes of providing services that you have registered as an interest. We may also contact you to ask for your feedback on the service that we provide so that we can ensure you continue to receive the best possible service. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any communication that we send.

We will never share or sell personal data with third parties outside of BAC unless use of a third party is required for the administration of a service, for example, on line booking registration and payment.

We will only send you this material with your consent. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in every communication that we send.

Completing customer satisfaction surveys and research

BAC uses a third party, Survey Monkey, as a tool to gather feedback from users about their experience of BAC or for other research purposes. For more information, see the Survey Monkey privacy notice . As a service user you may receive requests for feedback. No service user is under any obligation to provide feedback in order to continue to use the service.

We will only use the information gathered for the purposes that it is requested and will use the information only in ways that will not identify anyone.

Attending a BAC event

BAC uses a third party, Eventbrite, to manage event registration. For more information, see the Eventbrite privacy notice.

Individuals’ names and company names may be shared as part of a delegate list for networking purposes, no contact details will be shared.  Sharing contact details will only be done with the explicit consent of the individual concerned. Contact names lists will be used by BAC for communication before and during events for planning and reminder purposes, and may be used to contact event and activity participants about future events that may be of interest to them. Consent will be sought where appropriate.

Group photographs may be taken at events and during adventure learning activities and be used for post event communications and in marketing for future events and activities. Event attendees and activity participants (including parental or guardian approval and consent for children and young people under the age of 18 years of age) will be made aware of this and can advise BAC if they do not wish to be visible in any photograph. BAC will not attribute individual personal names to any photographs but may attribute an associated group or organisational name to individual photographs.

Changes to this privacy notice

BAC may update their privacy notice from time to time but will notify individual contact names held of any changes through postal or electronic means of communication.

You are advised to review BAC’s privacy notice periodically for any changes. Changes to this privacy notice are effective when they are posted on the BAC website www.belfastactivitycentre.com.

If BAC make any material changes to this privacy notice, BAC will notify you either through the email address you have provided us or by placing a prominent notice on our website.

This privacy notice is a living document that will develop over time. It was last updated on: 21st. May 2018.

Your rights

Under the General Data Protection Regulations, you have rights as an individual which you can exercise in relation to the information we hold about you.

You can read more about these rights at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/

BAC tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if BAC holds any personal information by making a ‘data access request’. If BAC is holding information about you that you are entitled to know about, BAC will engage with you and endeavour to:

1.     Give you a description of the personal information held

2.     Tell you why we are holding it

3.     Tell you who it could be disclosed to

4.     Let you have a copy of the relevant information in an intelligible form

5.     Remove your data if this would not prevent the administration of a service we are contracted to deliver

To make a request for any personal information we may hold you need to put the request in writing: by emailing officeadmin@belfastactivitycentre.com and address your correspondence DATA ACCESS REQUEST.

Complaints or queries

BAC strives to meet the highest standards when collecting and using personal information. For this reason, BAC takes any complaints received about personal information held very seriously. BAC encourages people to communicate with them if they think that BAC’s collection or use of information is unfair, misleading or inappropriate. BAC would also welcome any suggestions for improving its procedures.

This privacy notice is designed to provide clarity. It does not provide exhaustive details of all aspects of BAC’s collection and use of personal information. However, BAC are happy to provide any additional information or explanation needed. If you want to make a complaint about the way we have processed your personal information, or if you have a query, you can contact BAC atofficeadmin@belfastactivitycentre.com

You can also report a concern to the Information Commissioner’s Office. Further information is available at https://ico.org.uk/concerns

When you email BAC

Any email sent to BAC, including any attachments, may be monitored and used by BAC for reasons of security and for monitoring compliance with BAC policy and practice. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.

Emails may be shared within BAC to ensure that a question or query is addressed to, and resolved by, the correct member of BAC staff.

When you contact BAC via social media

BAC uses a variety of social media outlets to engage with stakeholders. We cannot guarantee that information shared through these media will be private, for example, if you share your contact details in an unsecure and public space then these may be viewed by parties other than BAC. Please do not share personal information in a public social media forum. For the relevant BAC social media privacy notices, please go to the BAC website www.belfastactivitycentre.com and follow the links to:

Facebook privacy notice
Twitter privacy notice
LinkedIn privacy notice

If you send BAC a private or direct message via social media the message will be stored but will not be shared with any other organisations.

When you visit our office: CCTV

BAC CCTV cameras installed which video record covering the front and rear entrances to the courtyard at Barnett’s Demesne, the back and front of the courtyard perimeter, and within the Belfast Adventure Learning Park located adjacent to the Courtyard. These CCTV cameras are for security and child protection purposes allowing for the premises to be monitored 24 hours a day 7 days each week.  Out of operating hours when no staff are present, CCTV recording acts as a deterrent to any potential criminal activity. Outside of the Courtyard and during out of operating hours, three staff from the BAC Senior Management Team are able to view the CCTV footage on secure devices, enabling them to visually check the premises should the security alarm be activated. The CCTV is stored in a secure room that is accessible only by passcode and requires sign in. Cameras have been positioned to avoid capturing the images of persons not visiting the premises. Recordings are retained for four weeks for incident reporting and to support incident investigations after which time they are automatically erased. Except for law enforcement bodies, images will not be provided to third parties.

Job applicants, current and former BAC employees (full and part time) and casual staff.

Information you provide to BAC

All of the information you provide during the recruitment process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary. BAC will not share any of the information you provide during the recruitment process with any third parties.  The information you provide will be held securely by BAC and/or our data processors whether the information is in electronic or physical format. BAC will use the contact details you provide to contact you to progress your application. BAC will use the other information you provide to assess your suitability for the role you have applied for.

Information requested and purpose

BAC do not collect more information than needed to fulfil its stated purposes and will not retain it for longer than is necessary. The information asked for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you do not provided requested information.

BAC will ask you for your personal details including name and contact details. BAC will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. BAC recruitment and selection interviewers will have access to all of this information.

You will also be asked to provide equal opportunities information. This is not mandatory information – if you don’t provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.

BAC might ask you to attend an interview. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by BAC.

If you are unsuccessful following assessment for the position you have applied for, BAC may ask if you would like your details to be held on a reserve list. If you say yes, BAC would proactively contact you should any further suitable vacancies arise.

If BAC makes a conditional offer of employment it will ask you for information so that the Charity can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.

You will therefore be required to provide:

• Proof of your identity.
• Proof of your qualifications.
• Access NI check.

BAC will contact your referees, using the details you provide in your application, directly to obtain references. If BAC makes a final offer, it will also ask you for the following:

• Bank details – to process salary payments
• Emergency contact details to contact in case you have an emergency at work
• Details required for the purposes of pension enrolment.

BAC may also seek information to assist in securing your membership of relevant health or other occupational benefit schemes.

Retained Information

If you are successful, the information you provide during the application process will be retained by BAC as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references. If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 12 months. Information generated throughout the assessment process, for example interview notes, is retained by BAC for 12 months. Equal opportunities information is retained for three years whether you are successful or not. These timeframes are in line with the Fair Employment and Treatment (NI) Order 1998.

Jurisdiction

This Policy shall be governed and construed in accordance with the laws of Northern Ireland, without regard to its conflict of law provisions.

How to contact us

If you want to request information about our privacy policy you can contact BAC at:

Belfast activity centre

Barnett’s Stable Yard

Barnett’s Demesne

Malone Road

Belfast

BT9 5PB

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