We understand the importance of maintaining your privacy, keeping your personal information secure and complying with data protection laws.
This privacy notice sets out the standards that you can expect from NYAS when we request or hold personal information (‘personal data’) about you; how you can get access to a copy of your personal data; and what you can do if you think the standards are not being met.
NYAS is registered with the Information Commissioner’s Office (ICO) with registration number no. Z5916509. Our Data Protection Policy and procedures are governed by the Data Protection Act 1998 and the EU General Data Protection Regulation 2018. The law in this area is changing rapidly and we anticipate this statement may be revised in the future, in line with further guidance from the Information Commissioner’s office.
Why we hold your personal data and how we use it
We only collect, use and store your information where we have lawful grounds and legitimate reasons for doing so. Personal information is used in order:
- to provide our services to you
- to deal with your enquiries and requests for information
- to process and record donations and fundraising activities
- to provide you with information about our activities
- to maintain information as a reference tool or general resource
The legal grounds upon which we might rely for justifying why we are using your personal information are:
Performance with a contract with you: processing is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into a contract.
Compliance with a legal obligation: processing is necessary for compliance with a legal obligation to which we are subject.
For our legitimate interests where these do not cause you undue harm: processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information. Our main legitimate interests for using your personal information are:
- To enable us to provide legal, advocacy and other appropriate services to children, young people and vulnerable adults.
- To promote our services
- To enable individuals or organisations to support NYAS
When we use your sensitive personal information (e.g. religious belief, health, biometrics, sexual orientation, criminal convictions or political opinions) we must be able to rely on an additional legal ground. The additional legal grounds that we may rely on are:
Substantial public interest: Processing is necessary for safeguarding purposes
Your explicit consent: you have given your explicit consent to the processing of your personal information for one or more specified purposes. You may withdraw your consent at any time by contacting us at Help@nyas.net, speaking to your advocate or caseworker or by phoning 0151 649 8700. If you do so, you may not be able to receive the benefit of some of our services.
For legal claims: processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
For archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State Law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.
You have made this information public: you have made your sensitive personal information public.
We also collect ‘special categories of personal data’ for the purposes of monitoring equality, which is a legal requirement from public authorities under the Equality Act 2010. Special categories of personal data obtained for equality monitoring will be treated with the strictest confidence and any information published will not identify you or anyone else associated with this data.
Personal data held by NYAS
Personal information is any information that may identify a living individual. We collect personal information such as:
- Your name
- Telephone number
- Postal address
- email address
- IP addresses
- Unique personal identifiers and biographical information (e.g. date of birth)
- Credit/debit card details (if you are making a donation or purchase)
- Records of information about the service provided to you
How we collect your personal information
When you interact with us directly: this could be if you ask us about our services, make a referral for a young person, register with us for a training event, make a donation to us, apply for a job or volunteering opportunity or otherwise provide us with your personal information. This includes when you phone us, visit our website, by email or in person.
When you interact with us through partners working on our behalf: This could be through an advocate, caseworker, contact facilitators or other professional who are always working on our behalf and always under our instruction.
When you interact with us through third parties: This could be if you provide a donation through a third party such as Just Giving
When you visit our website: there are more details below – please see ‘cookies’
From publically available sources: including but not limited to internet search engines, public records and registers and social media.
We may collect information from you about other people or organisations. If you give us information about another person, it is your responsibility to ensure and confirm that:
- You have told the individual who we are and how we use personal information, as set out in in this privacy notice and
- You have permission from the individual to provide that personal information to us and for us to use it, as set out in this privacy notice.
Sharing your information
We will never share your personal information with organisations so that they can contact you for marketing activities. Nor do we sell any information about your web browsing activity.
NYAS may however share your information with our trusted partners and suppliers who work with us on or on our behalf to deliver our services, but processing of this information is always carried out under our instruction. We make sure that they store data securely, delete it when they no longer need it and do not use it for any other purposes. We enter into contracts with these service providers that require them to comply with Data Protection Laws and ensure that they have appropriate controls in place.
Information may be shared with the organisation that pays for your service in order to be able to provide you with a service. We may be required to share your data with other agencies for legal reasons, an example being for a court order or with other organisations if we believe that you are at risk or at harm or may harm someone else.
We will only contact you about our work and how you can support NYAS by phone, email or text message if you have agreed for us to contact you in this manner.
However, if you have provided us with your postal address we may send you information about our work and how you can support NYAS by mail unless you have told us that you would prefer not to hear from us in that way.
You can update your choices or stop us sending you these communications at any time by contacting email@example.com or clicking the unsubscribe link at the bottom of the relevant communication.
How we protect your personal information
NYAS takes looking after your information very seriously. We’ve implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off line from improper access, use, alteration, destruction and loss.
Whilst we strive to protect your personal information, due to the nature of the internet we cannot totally guarantee the security of any of the information you transmit to us. With this in mind transmission is at your own risk and we urge you to take every precaution to protect your personal information whilst you are online.
How long we hold your information for
Your personal information will not be retained for any longer than is necessary for the lawful purposes for which it has been collected and processed. This is to ensure that your personal information does not become inaccurate, out of date or irrelevant. NYAS have set retention periods for the personal information that we collect and you can contact our data protection officer for a copy of our retention policy.
You have various rights in respect of the personal information we hold about you as set out in the table below. If you wish to exercise any of these rights or make a complaint you can do so by contacting our Data Protection Officer at NYAS, Tower House, Tower Road, Birkenhead, CH41 1FF, by email at firstname.lastname@example.org and by phone on 0151 649 8700. You can also make a complaint to the data protection supervisory authority, the Information Commissioner’s Office https://ico.org.uk
|To be informed||This Privacy Notice provides the information you are entitled to receive|
You have the right to request access to a copy of the personal information that we hold about you, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for automated decision making.
You can make a request free of charge. Please make all requests for access in writing and provide us with evidence of your identity.
|Rectification||You can ask us to change or complete any inaccurate or incomplete personal information held about you.|
|Erasure or right to be forgotten||You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent or where we have no lawful basis for keeping it.|
|Restrict processing||You can ask us to restrict the personal information held about you where you have asked for it to be erased or where you have objected to our use of it.|
|Data portability||You can ask to provide you or a third party with some personal information that we hold about you in a structured, commonly used, electronic form so it can be easily transferred.|
|To object||If we can, we will stop processing your data if you object to processing based on legitimate interests or the performance of a task in the public interest / exercise of official authority. We will stop processing your data for direct marketing if you tell us to. We will stop processing your data if you object to processing for purposes of research and statistics.|
|Not to be subject to automated decision-making including profiling||We do not use any automated decision-making.|
Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.
NYAS use the following cookies:
- Session cookies (temporary cookies stored in the browser’s memory until the browser is closed).
- Persistent cookies (longer-term cookies that are tagged by the issuer with an expiration date. These cookies are stored by the browser even after the browser is closed).
- Analytical cookies (allow NYAS to recognise and count the number of visitors. This also helps us understand how visitors navigate through the website, for example, to ensure that visitors are finding what they are looking for efficiently.
The table below lists all of the individual cookies that NYAS use and their purpose:
|NYAS||PHPSESSID||Also called a transient cookie, a cookie that is erased when the user closes the web browser. The session cookie is stored in temporary memory and is not retained after the browser is closed.||Session Cookie|
|Cookie Notice||viewed_cookie_policy||When a user clicks accept on the cookie popup notification, a cookie is generated which will reset after one year. When deleted, the cookie will be reset which will then prompt the user to accept or reject the cookie notification popup.|
|NYAS Recruitment||_RequestVerificationToken||Also called a transient cookie, a cookie that is erased when the user closes the web browser. The session cookie is stored in temporary memory and is not retained after the browser is closed.|
|Google Translate||Googtrans||Also called a transient cookie, a cookie that is erased when the user closes the web browser. The session cookie is stored in temporary memory and is not retained after the browser is closed.||Google Translate|
|Test Cookie||wordpress_test_cookie||Session cookie – tests that the browser accepts cookies.||WordPress Cookies|
To find out more about this policy and how we look after your personal information, contact our Data Protection Officer at email@example.com or on 0151 649 8700