Data Protection

Data Protection

Positive Footprints Privacy Notice

Positive Footprints is part of the Regenda Group and provides personal
development programmes for young people.

This privacy notice tells you what to expect when Positive Footprints collects
personal information. It applies to information we collect about:

  • People who use and/or enquire about our services
  • Visitors to our websites
  • Job applicants

1. What is data protection?

The General Data Protection Regulation (GDPR) and Data Protection Act (2018)
sets out rules for processing personal information. This applies to personal
information we might hold about you on some paper files and on computers. The
Act states that those who record and use personal information must ensure that
it is handled properly. Therefore, we are required to ensure that personal
information is:

  • Processed in a lawful, fair and transparent way
  • Held only for the purposes we collected it for
  • Adequate, relevant and limited to what is necessary
  • Accurate
  • Held only for as long as we need it
  • Kept secure

The Information Commissioner’s Office (ICO) is responsible for regulating,
enforcing and promoting good practice and transparency in the access and use of
personal information.

Organisations have to notify the ICO of all the purposes for which they will be
processing information. We are happy to supply you with a copy of the
notification upon request or you can contact the ICO by calling 0303 1231113, or
writing to the Information Commissioner’s Office, Wycliffe House, Water Lane,
Wilmslow, Cheshire, SK9 5AF.

You can find out more information online at www.ico.org.uk.

2. What information does Positive Footprints collect about its customers?

We begin the process of collecting information about you, and if appropriate, your
family, when you apply to us either directly or through one of our partners.
Although the information we collect may vary, typically it may include:

  • Programme material
  • Images videos

3. How we collect information about you

Images, videos and programme material is collected from schools and partners
and at events.

4. Why do we collect this information?

Positive Footprints collects this information for marketing purposes.

5. Sharing your information

We will not share your personal information without your consent unless allowed
by law.

Examples of organisations we may share your information with, where
appropriate, are:

  • School partners
  • Schools
  • Business partners
  • Media

6. What is the legal basis for our use of your personal information?

Positive Footprints has signed consent forms and data sharing agreements in place
with all of its schools and school partners.

This includes but is not limited to the following set out within the GDPR:

  • Article 6.1(a) – the data subject has given consent
  • Article 6.1(b) – processing is necessary for the performance of a contract
  • Article 6.1(c) – processing is necessary for compliance with a legal
    obligation
  • Article 6.1(d) – processing is necessary to protect the vital interests of
    individuals
  • Article 6.1(e) – processing is necessary for the performance of a task carried
    out in the public interest or in the exercise of official authority vested in the
    controller

7. How long do we keep your personal information?

Positive Footprints has robust data retention guidelines. Records (electronic and
paper) will not be kept for longer than necessary and will be kept in accordance
with the terms and conditions set out with schools and school partners.
Positive Footprints are unable to remove any images or content in printed
materials or video footage if it has already been produced or remove images and
quotes that have already been published by the media.

8. How do we take care of your personal information?

Information is held in paper files and on our computer systems. Not all members
of staff are able to access this information, only those who need to. There may be
occasions when we have to share information with others (detailed in section 5)
to enable us to deliver our services and fulfil our legal and contractual obligations.

We are legally required to share information in the following circumstances:

  • Safeguarding
  • Prevention or detection of crime
  • Apprehension or prosecution of offenders
  • Assessment or collection of tax or duty owed to customs and excise
  • In connection with legal proceedings
  • Public health
  • To comply with the law

9. CCTV

9.1 What information do we hold?

If you are in the field of vision of any of our CCTV systems, we may collect from you video recordings and still pictures.  This personal information may include your activities, your face, car registration details and other visual information about you which is recorded on our CCTV system.

9.2 What do we do with your personal information?

We collect this information for the following purposes:

  • For the prevention and detection of crime
  • For evidence in any civil or criminal legal proceedings
  • To assist in investigations
  • For safety and security
  • Dealing with any queries, complaints, or enquiries
  • Retaining records

As well as being the purposes for which we use your personal information, all of the above are also legitimate reasons for us to use and store personal information relating to you which is captured on our CCTV system and legitimate interests are our legal basis for processing your personal information.

9.3 Who we share your personal information with

We share your personal information with the following parties:

  • Suppliers and service providers: to manage and operate the CCTV system.
  • The police and other law enforcement agencies: to carry out policing, assist investigations, trace missing people, and investigate alleged criminal activities.
  • The security services: where relevant for matters of national security.
  • People who have been injured, attacked, or had property damaged or stolen and their insurance providers: to assist them with any criminal or civil investigations or legal proceedings.
  • People who have been involved in road traffic accidents and their insurance providers: to assist with insurance claims, legal claims, and investigations.
  • Any relevant regulators: where we are required to do so by law or to assist with their investigations or initiatives and this includes but is not limited to the Information Commissioner’s Office.

We do not disclose personal information to anyone else except as set out above unless we have your consent, or we are legally obliged to do so.  We do not sell your data.

9.4 How long do we keep your information for?

We will keep your personal information for up to approximately one month after the recording was made. After this time, the recording stored on the hard drive of our CCTV system will usually be overwritten. However, if we receive an enquiry about a particular recording on our CCTV, we will generally then retain that part of the recording until it is no longer required. This period can vary as it will depend upon the circumstances of the particular case. As soon as it is no longer required, we will then delete the personal information.

10. Marketing and Communication

10.1 The Marketing and Communication Team may collect the following
types of personal data:

  • Images
  • Video footage including interviews

We may also collect:

  • Your name, age, address and contact details (email, telephone number
    and/or postal address)
  • Name of group/organisation or event
  • If it is for consent for a child aged 13 or under, or a vulnerable adult – the
    name of the consenter and their relationship to you

10.2 We may collect your personal data in a number of ways:

  • Through a consent form
  • By an authorised representative e.g. employed photographer at organised
    events

10.3 What is our lawful basis to obtain and use this personal data?

When we collect and use your personal information we rely on the following lawful
basis:

  • Consent: You or a representative have given consent
  • Legitimate interest – processing is necessary for the purposes of the
    legitimate interests pursued by the controller or by a third party

10.4 What does the communications and marketing team use your
information for?

We use images to promote services across the Regenda Group.

  • Images and footage may be published on any of the following channels:
  • Press and media (including newspapers, magazines, websites)
  • On our websites (including Petrus and Regenda)
  • On our social media feeds including LinkedIn, Twitter, Facebook and other
    corporate social media accounts in the future
  • In our printed publications such as newsletters, brochures, flyers and display
    materials
  • In our electronic newsletters
  • Media releases

The images/footage will often be accompanied by the details of your story,
however, we will not use personal details or full name of any individual in an
article.

If you no longer wish for your image or personal information to be used, please
contact us and ask us to remove them from the archive.

Please note that we will be unable to remove any images or content in printed materials or video footage if it has already been produced or remove images and
quotes that have already been published by the media.

11. Visitors to our websites

When someone visits www.positivefootprints.co.uk, http://thejobjunction.co.uk/
and www.regenda.org.uk we use a third-party service, Google Analytics and
Hotjar 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
identify anyone. We do not make and do not allow Google to 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, we will be upfront about
this. We will make it clear when we collect personal information and will explain
what we intend to do with it.

You may prevent your data from being analysed by Google Analytics by
downloading and installing the Google Analytics Opt-out Browser Add-on,
available at https://tools.google.com/dlpage/gaoptout/. Google’s ability to use
and share information collected by Google Analytics about your visits to this site
is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html and the Google Privacy Policy,
available at http://www.google.com/policies/privacy/.

To learn more about how Google collects and processes data in connection with Google Analytics, visit http://www.google.com/policies/privacy/partners/.

You can opt-out of tracking by Hotjar here: https://www.hotjar.com/opt-out and
can learn about Hotjar’s ability to use and share information through the Hotjar
Terms & Conditions of Use, available at https://www.hotjar.com/terms, and the
Hotjar Privacy Policy, available at https://www.hotjar.com/privacy/.

When you use our website, no user-specific data is collected by either Positive
Footprints or any third party. We use Google Analytics for trend reporting and
visitor behaviour to help us improve our website and search functionality.

11.1 Security and Performance of the Positive Footprints website
Positive Footprints uses a third-party service to help maintain the security and
performance of the Positive Footprints website. To deliver this service it processes
the IP addresses of visitors to the Positive Footprints website. This information is
not used for identifying purposes, except for investigation if an intrusion occurs.

11.2 Use of cookies by Positive Footprints

Positive Footprints websites use cookies. Cookies are small text files placed
on your computer by the websites you visit. They are used to help make websites
work efficiently. You can control cookies through the settings of your web browser.
To find out more, visit www.aboutcookies.org or www.allaboutcookies.org.
These are the cookies we use:

Google Analytics – to monitor website use and the type of browser that is accessing
the website
Hotjar – to monitor website and page usage

12. People who contact us via social media

We use a third-party provider, Hootsuite to manage our social media interactions.
If you send us a private or direct message it will not be shared with any other
organisation.

Social media messages are retained for three months.

13. People who email us

Positive Footprints email is encrypted at rest and in transit, using several strong
encryption protocols, and technologies that include Transport Layer
Security/Secure Sockets Layer (TLS/SSL), Internet Protocol Security (IPSec), and
Advanced Encryption Standard (AES). If your email service does not support the
same encryption, you should be aware that any emails we send or receive may
not be protected in transit.

We will also monitor any emails sent to us, including file attachments, for viruses
or malicious software. Positive Footprints use web beacons on our websites and in our emails. When we send emails, we may track behaviour such as who opened the emails and who clicked the links. This allows us to measure the performance of our email campaigns and to improve our features for specific customers. To do this, we
include single-pixel gifs, also called web beacons, in emails we send. Web beacons
allow us to collect information about when you open the email, your IP address,
your browser or email client type, and other similar details.
Emails are retained for fifteen months.

14. What are your rights

14.1 Right of access to your data

If we hold personal information about you, you have the right to ask us:

  • What we use the information for
  • To provide you with a copy of the information you are entitled to
  • To supply you with details of the purposes for which we use the
    information and who it is shared with
  • For incorrect information to be corrected.

This can be requested either verbally or by completing a Subject Access Request
form. We have one month from the date we receive your request to provide you with
the information.

14.2 Right to rectification

If you think that Positive Footprints is holding incorrect personal information about
you, you have the right to have this personal information amended.
Once you have advised Positive Footprints of the details of the incorrect data and
the required amendments, your data will be updated within 30 days. If your
personal data cannot be amended, Positive Footprints will advise you in writing
why this is the case.

14.3 Right to be forgotten and restriction of processing

You have the right to be forgotten and ask us to erase your personal information.
You also have the right to restrict the processing of your personal data. This
means that Positive Footprints cannot further process your data, for example, we
cannot share your data with a third party.

15. Job applicants

Regenda Homes is the data controller for the information you provide during the
employment recruitment process. If you have any queries about the process or
how we handle your information, please contact us.
The following explains how Regenda uses the information you provide in your
application, along with your rights, our reasons for requesting it and who will have
access to it.

15.1 What information do we collect?

We collect information on the following information as part of the application process:

  • Name, address, email, telephone number
  • CV (if applicable)
  • Equal opportunities monitoring information (defined as special categories
    data) – this information is purely for statistical analysis and monitoring
    purposes
  • Answers to application questions
  • Any other information you wish to provide in support of your application

15.2 Why do we collect this information and who do we share it with?

We use your details and information so that we can assess your suitability for
employment with us and carry out statistical analysis. Information you provide
as part of your job application will be:

  • Held on our computer systems and may be downloaded by us
  • Used to deal with your application
  • Made available to us and our processors
  • Used for communication with you regarding the vacancy
  • Used to satisfy legal requirements
  • Used for statistical analysis
  • Held and may be used to contact you about other vacancies

If you are successfully recruited, we will upload your details to our HR system,
Cascade.

15.3 How can you access the information we hold about you?

If you choose to register on our recruitment website, hosted by Networx
recruitment you may access your profile, correct and update your details, or
withdraw your details at any time. To do this, you can access your personal profile
by using the secure login.

You have the following rights in relation to the way in which we deal with your
personal data:

  • The right of erasure or to be forgotten
  • The right to rectification if the information is inaccurate or out of date
  • The right of data portability (to obtain and reuse your personal data)
  • The right to object to Regenda Homes processing your personal data
  • The right to withdraw your consent with regards to the handling of your
    personal data
  • You have the right to ask for a copy of the information we hold about you
    (Subject Access Request)
  • You have the right to lodge a complaint with a supervisory authority – the
    ICO

Where you exercise your right to object or withdraw your consent, we may process
your personal data without your knowledge or consent where we are permitted or
required by law or regulatory requirements to do so. In such a case, we will not
process more personal data than is required under the circumstances.

15.4 Conditional offer

If we make a conditional offer of employment, we will ask you for information so
that we 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 eligibility to work in the UK – you will be asked to attend our
    office with original documents, and we will take copies.
  • Proof of your qualifications, if required.
  • You may be asked to complete a DBS application to declare any unspent
    convictions, depending on the nature of the role you apply for.
  • We will contact your referees, using the details you provide in your
    application, directly to obtain references.
  • We will also ask you to complete a questionnaire about your health. This is
    to establish your fitness to work and any adjustments we need to consider
    before you start. This is done through our current occupational health
    provider.
  • Our Code of Conduct requires all staff to declare if they have any potential
    conflicts of interest. If you complete a declaration, the information will be
    held by our Business Assurance team.

If we make a final offer, we will also ask you for the following:

  • Bank details – to process salary payments.
  • Emergency contact details – so we know who to contact in case you have an
    emergency at work.

15.5 Health management

Corazon provides our Occupational Health service. If we make you a conditional
offer, we will ask that you complete a questionnaire which will help to determine
if you are fit to undertake the work that you have been offered or advise us if any
adjustments are needed to the work environment or systems so that you may
work effectively.

We will send you a form to complete and return directly to Corazon. The
information you provide will be held by Corazon who will provide us with a fit to
work certificate or a report with recommendations. You are able to request to see
the report before it is sent to us. If you decline for us to see it, then this could
affect your job offer. If an occupational health assessment is required, this is likely
to be carried out by Corazon.

15.6 Fleet and mileage claims

The organisation is required to undertake statutory checks to ensure vehicles that
our staff drive on behalf of the company is roadworthy. To achieve this, we
require staff to provide the following documents:

  • Driving license details
  • MOT (if applicable)
  • V5 registration document (if applicable)
  • Insurance details

This information is collected to ensure that any mileage payments paid to
employees are done so in accordance with health and safety legislation, which
requires us to ensure all travel undertaken for the business is compliant.
In addition, we carry out checks on all staff’s licenses through the DVLA to ensure
they are legally able to drive both their own and company vehicles.

This information includes:

  • Driving convictions i.e. drink driving, speeding etc.
  • Number of penalty points

This information is used to ensure all drivers are legally entitled to drive. In
addition, we use this data to monitor staff who have a more than 6 penalty points
on their driving license.

15.7 How long is the information retained for?

If you are unsuccessful at any stage of the process, the information you have
provided until that point will be retained for 6 months from the closure of the
campaign.
Equal opportunities information is retained for 6 months following the closure of
the campaign for unsuccessful candidates. Successful candidates’ data will be
stored via the Cascade system.

16. Complaints or queries

Positive Footprints tries to meet the highest standards when collecting and using
personal information. For this reason, we take any complaints we receive about
this very seriously. We encourage people to bring it to our attention if they think
that our collection or use of information is unfair, misleading or inappropriate. We
would also welcome any suggestions for improving our procedures.
This privacy notice was drafted with brevity and clarity in mind. It does not provide
exhaustive detail of all aspects of Positive Footprint’s collection and use of personal
information. However, we are happy to provide any additional information or
explanation needed. Any requests for this should be sent to the address below.
If you want to make a complaint about the way we have processed your personal
information, you can contact us at dataprotection@regenda.org.uk

17. Changes to this privacy notice

We keep our privacy notice under regular review. This privacy notice was last
updated on 7 October 2020.

18. How to contact us

If you want to request information about our privacy policy you can email us
or write to:

dataprotection@regenda.org.uk
Data Protection
The Regenda Group
The Foundry
42 Henry Street
Liverpool
L1 5AY
Telephone: 0151 703 3000