Money Carer Privacy Policy

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998 (the Act) and, the data controller is Sean Tyrer, The Money Carer Foundation, Dalton House, Cross Street, Sale, Manchester, M33 7AR.

Data protection law has changed in the UK with the Data Protection Act 1998 (‘DPA’) being replaced with the European General Data Protection Regulation (‘GDPR’) form 25 May 2018. 

This Privacy Statement explains how we process your information and your rights under both DPA and GDPR.

Information we may collect from you

We may collect and process the following data about you:

Information you give us. This could be your name, date of birth and telephone and/or email contact details along with a description of why you have contacted us via our website.

Information we receive from other sources. Other sources could be social workers or other representatives of a local authority, medical professionals, advocates or care organisations for example. They may provide your name, date of birth and contact details along with a description of why they have chosen to contact us via our website on your behalf.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy below.

Uses made of the information

We use information held about you in the following ways:

Information you give to us. We will use this information to make contact with you if possible, in order to ascertain how we may be of assistance to you.

Information we receive from other sources. We may combine this information with information you give to us and the information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information

We may share your personal information with:

• Employees of The Company in order to undertake the services we have been retained to provide on your behalf.

We may share your information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with [them or] you, including without limitation any data processor we engage. Examples of such third parties are: The Department of Work and Pensions (DWP), approved law firms, approved independent social workers, approved genealogy organisations, analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of The Money Carer Foundation, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

The data that we collect from you may be transferred to and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.  You can also exercise the right at any time by contacting us at GDPR@moneycarer.org.uk.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

Your rights under Data Protection Law

We operate under the Data Protection Act 1998 (‘DPA’) as replaced by the European General Data Protection Regulation (‘GDPR’) from 25 May 2018.

The DPA and GDPR apply to ‘personal data’ we process and the data protection principles set out the main responsibilities we are responsible for.

We must ensure that personal data shall be:

1. processed lawfully, fairly and in a transparent manner;
2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
3. adequate, relevant and limited to what is necessary for relation to the purposes for which they are processed;
4. accurate and where necessary kept up to date;
5. kept for no longer than is necessary for the purposes for which the personal data are processed.  We operate a data retention policy that ensures we meet this obligation.  We only retain personal data for the purposes for which it was collected and for a reasonable period thereafter where there is a legitimate business need or legal obligation to do so.  For detail of our current retention policy contact our privacy officer at GDPR@moneycarer.org.uk
6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

We ensure lawful processing of personal data by obtaining consent; or where there is a contractual obligation to do so in providing appropriate products and services; or where processing the data is necessary for the purposes of our legitimate interests in providing appropriate products and services. 

In the majority of cases, we process personal data based on your contract with us.  In other cases, we process personal data only where there are legitimate grounds for so doing.

To meet our Data Protection obligations, we have established comprehensive and proportionate governance measures.

We ensure data protection compliance across the organisation through:

1. implementing appropriate technical and organisational measures including internal data protection policies, staff training, internal audits of processing activities, and reviews of internal HR policies.
2. maintaining relevant documentation on processing activities.
3. implementing measures that meet the principles of data protection by design and data protection by default including data minimisation, pseudonymisation, transparency, deploying the most up-to-date data security protocols and using data protection impact assessments across our organisation and in any third party arrangements.

How you can obtain a copy of the data we hold about you

You have a right to receive a copy of the personal data that we hold about you. Under the DPA We have the discretion to make a charge of £10.00 towards the cost of administration

To obtain a copy of the personal information we hold on you, please write to us at the address below and provide us with your details or ask for a Subject Access Request form.

Under the DPA you also have a number of additional rights in respect of your personal data.  The Information Commissioner’s website provides guidance on these at www.ico.org.uk

Questions regarding this Privacy Statement should be directed to:

The Data Controller, The Money Carer Foundation, Dalton House, Cross Street, Sale, Manchester, M33 7AR.

From 25 May 2018 under the GDPR You have the following specific rights in respect of the personal data we process:

1. The right to be informed about how we use personal data. 
   
   This Privacy Statement explains who we are; the purposes for which we process personal data and our legitimate interests in so doing; the categories of data we process; third party disclosures; and details of any transfers of personal data outside the UK.
2. The right of access to the personal data we hold.  In most cases, this will be free of charge and must be provided within one month of receipt.
3. The right to rectification where data are inaccurate or incomplete.  In such cases, we shall make any amendments or additions within one month of your request.
4. The right to the erasure of personal data, but only in very specific circumstances, typically where the personal data are no longer necessary in relation to the purpose for which it was originally collected or processed; or, in certain cases where we have relied on consent to process the data when that consent is withdrawn and there is no other legitimate reason for continuing to process that data; or when the individual objects to the processing and there is no overriding legitimate interest for continuing the processing. 
5. The right to restrict processing, for example, while we are reviewing the accuracy or completeness of data, or deciding on whether any request for erasure is valid.  In such cases, we shall continue to store the data, but not further process it until such time as we have resolved the issue.
6. The right to data portability which, subject to a number of qualifying conditions, allows individuals to obtain and reuse their personal data for their own purposes across different services. 
7. The right to object in cases where processing is based on legitimate interests, where our requirement to process the data is overridden by the rights of the individual concerned; or for the purposes of direct marketing (including profiling); or for processing for purposes of scientific/historical research and statistics, unless this is for necessary for the performance of a public interest task. 
8. Rights in relation to automated decision making and profiling.

Please contact our privacy officer at GDPR@moneycarer.org.uk for more information about the GDPR and your rights under Data Protection law.

If you have a complaint about data protection at The Money Carer Foundation contact our privacy officer at GDPR@moneycarer.org.uk

Alternatively, contact our supervisory authority for data protection compliance (www.ico.org.uk):

Information Commissioner’s Office
Wycliffe House
Water Lane, Wilmslow
Cheshire, SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

About cookies

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The use of cookies is an industry-standard, and most websites use them to provide useful features for their customers. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer. Most browsers are initially set to accept cookies.

If you would prefer, you can set yours to refuse cookies. However, you may not be able to take full advantage of a website if you do so.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to GDPR@moneycarer.org.uk

Last updated: May 7th, 2018