Creative Alternatives is a programme commissioned by St.Helens Council and delivered by Alef Trust. As the Data Controller for Creative Alternatives, Alef Trust takes full responsibility for privacy and the protection of your data. We will only use your personal information to maintain communications, to complete the process of programme referral and to maintain your involvement as a client on Creative Alternatives.
Alef Trust deals with all personal information provided in a responsible manner that respects personal privacy and is in full compliance with the Data Protection Act 2018 (DPA) and the new General Data Protection Regulation (GDPR). Although the DPA/GDPR are UK and EU regulations, Alef Trust applies the same high standards for the protection of your privacy and personal information, regardless of where you are located. Additional information on the Alef Trust Privacy, Data Protection and other policies can be found by visiting our Privacy & Data Protection page. If you have any questions about how Alef Trust collects or uses your personal information, the Alef Trust Data Protection Officer (DPO) can be contacted in writing via the mailing address located on our Contact Page, or directly by emailing email@example.com.
This privacy statement explains how Alef Trust (“we”, “our”, “us”) collects, uses and shares your personal data, and your rights in relation to the personal data we hold. This privacy statement concerns our processing of personal data of past, present and prospective clients of Alef Trust (“you”, “your”). Alef Trust is the Data Controller of your personal data and is subject to the Data Protection Act 2018 (DPA) and the new General Data Protection Regulation (GDPR). This Privacy Statement covers the following topics related to the protection of your information and privacy:
- Your rights
- Who to contact if you have any questions
- How we collect your information
- The types of information we collect
- How we use the information we collect
- The basis for processing the information we collect
- Sharing information with others
- How long your information is kept
1. Your Rights
Under the DPA & GDPR you have the following rights:
- Right to Information (Art. 13) – to be informed of which data we collect, where, how it will be used, our legal basis for collecting this data, how you can rectify, access or delete your information, and how to contact our Data Protection Officer or to raise a complaint.
- Right to Access (Art. 15) – to obtain access to, and copies of, the personal data that we hold about you;
- Right to Rectification (Art. 16) – to require us to correct the personal data we hold about you if it is incorrect;
- Right to Erasure (Art. 17) – to require us to erase your personal data;
- Right to Restrict Processing (Art. 18) – to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
- Right to Portability (Art. 20) – to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
- Right to Object to or Cease Collection (Art. 21) – to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights;
- Right to File a Complaint – if you are not satisfied with how we are processing your personal data, you can make a complaint to our Data Protection Officer through the contact form below, or file a complaint with the Information Commissioner.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
If you have given your consent and you wish to withdraw it, please contact our Data Protection Officer using the contact form at the bottom of this page. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.
2. Who To Contact if You Have Any Questions
If you have any questions about how Alef Trust deals with your data or privacy, or if you would like to request to have your data updated, provided to you or deleted, the Alef Trust Data Protection Officer (DPO) can be contacted in writing via the mailing address located on our Contact Page, or directly by emailing firstname.lastname@example.org.
3. How We Collect Your Information
We may collect your personal data in a number of ways, for example:
- from the information you provide when you contact us before becoming a client, for example when you express your interest in joining Creative Alternatives;
- when you apply to join Creative Alternatives and complete the referral forms;
- when you communicate with us by telephone, email or via our website, for example in order to make an enquiry;
- when you are formally inducted on to the Creative Alternatives programme and become an active client;
- in various other ways as you interact with us during your time as a client of Creative Alternatives, for the various purposes set out below;
- from third parties, for example from your GP or another health care professional who may refer you onto the programme with your consent.
4. The Types of Information We Collect
We may collect the following types of personal data about you:
- your name, and contact information such as address, email address and telephone number.
- information relating to your family or personal circumstances, for example your employment status.
- sensitive personal data and information including:
- information concerning your health and medical conditions (e.g. mental health condition or disability);
- information about your racial and ethnic origin; religion or similar beliefs.
5. How We Use The Information We Collect
The purposes for which we may use personal data (including sensitive personal data) we collect during a client’s association with us include:
- recruitment and induction;
- ongoing support;
- provision of workshops;
- other administrative purposes, including:
- project evaluation and statistical analysis;
- promoting our services (e.g. providing information about ongoing creative opportunities and Arts in Libraries events);
- dealing with complaints and enquiries.
6. The Basis for Processing The Information We Collect
We may process your personal data because it is necessary for the performance of a client agreement with you or in order to take steps at your request prior to entering into an agreement. In this respect, we use your personal data for the following:
- to interact with you before you are inducted as a client, as part of the referral process (e.g. to send you a leaflet or answer enquiries about our programme);
- once you have been inducted, to provide you with the services as set out in our welcome information pack;
- to deal with any concerns or feedback you may have;
- for any other purpose for which you provide us with your personal data.
We may also process your personal data because it is necessary for the performance of our tasks carried out in the public interest or because it is necessary for our or a third party’s legitimate interests. In this respect, we may use your personal data for the following:
- to monitor and evaluate the performance and effectiveness of Alef Trust & Creative Alternatives, including by training our staff or monitoring their performance;
- to maintain and improve human resource management of Alef Trust & Creative Alternatives;
- to promote equality and diversity throughout Alef Trust & Creative Alternatives.
We may also process your personal data for our compliance with our legal obligations. In this respect, we may use your personal data for the following:
- to meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws and safeguarding requirements;
- for the prevention and detection of crime;
- in order to assist with investigations (including criminal investigations) carried out by the police and other competent authorities.
We may also process your personal data where:
- it is necessary to protect your or another person’s vital interests; or
- we have your specific or, where necessary, explicit consent to do so.
7. Sharing Information With Others
For the purposes referred to in this privacy notice and relying on the bases for processing as set out above, we may share your personal data with certain third parties. You are given the opportunity to opt out of some of these data sharing arrangements, for example when you register with us. However, information sharing with our partners may be essential and unavoidable for programme registration and completion.
Unless an opt-out is in place, we may disclose limited personal data to the following stakeholders listed below. Note that only the referral form will include your full name and personal information. Our other forms and documents will only refer to you by your first name and the first letter of your surname:
- St.Helens Council for the purpose of delivering Creative Alternatives;
- our employees, agents and contractors where there is a legitimate reason for their receiving the information, including:
- Creative Alternatives programme coordinators and artists for day-to-day management of the programme;
- third parties who are contracted to provide IT services for us;
- internal and external auditors.
- those with an interest in tracking client progress and attendance, including:
• health providers, social care services, and others providing services to you.
- crime prevention or detection agencies (e.g. the police, the Department for Work and Pensions and Trading Standards);
- parents, guardians, and next-of-kin (where there is a legitimate reason for disclosure);
8. How your information is stored and how long it is kept
- We keep all information secure, storing it on password protected laptops, in locked cabinets, and on a secure online drive facility which is fully compliant with data protection laws.
- Hardcopies of all our referral and programme enrolment forms are digitised on a regular basis and all hardcopies are then safely disposed of, using St.Helens Council facilities.
- Subject to any other notices that we may provide to you, we may retain client data in a digital archive, as follows:
- Information pertaining to clients who self-refer or are referred into our programme but who then do not join the programme is retained for a period of up to 6 months.
- Information pertaining to clients who partake in our programme is retained for a period of 18 months after their association with us has come to an end.