Perthshire Women’s Aid (PWA) – Website Terms, Privacy Notice and Cookies Policy

 

This document is complicated but we’ve tried to keep it as clear as possible and to have all the things you need to know about in one place.  This document tells you about:

1.     Our terms and conditions for when you use our website

2.     Our privacy notice which tells you about how we use your personal information after you give it to us

3.     And about the online cookies (not chocolate ones)  we use to learn from the way you interact with us.

 

1.     Website Terms

 

You must agree to these  terms to use this PWA website – www.perthwomensaid.org.uk

 

Using the PWA website 

You agree to use the PWA website only for lawful purposes. You must also use it in a way that does not infringe the rights of, or restrict or inhibit the use and enjoyment of, this site by anyone else. 

We update the PWA website when we need to. We can change or remove content at any time without notice. 

We amend these Terms and Conditions when we need to. Every time you wish to use our website, please check these Terms and Conditions to ensure you understand the terms and conditions that apply at that time. 

By continuing to use our website after these Terms and Conditions have been updated you are agreeing to be bound by them. 

 

External links from the PWA website 

The PWA website links to websites that are managed by government departments and agencies, service providers or other organisations. We do not have any control over the content on these websites. 

We’re not responsible for: 

• the protection of any information you give to these websites 
• any loss or damage that may come from your use of these websites, or any other websites they link to  

You agree to release us from any claims or disputes that may come from using these websites. You should read all terms and conditions, privacy policies and end user licences that relate to these websites before you use them.  

 

Content licence 

We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved. 

If you are an individual, you may print off one copy, and may download extracts, of any page(s) from our site for your personal use. 

If you are an organisation, you may print off copies, and may download extracts, of any page(s) from our site for non-commercial organisational purposes and you may draw the attention of others within your organisation to content posted on our site. 

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text. 

Our status (and that of any identified contributors) as the authors of content on our site must always be acknowledged (except where the content is user-generated). 

You must not use any part of the content on our site for commercial purposes without obtaining a licence to do so from us

 

Disclaimer 

While we make every effort to keep the PWA website up to date, we do not provide any guarantees, conditions or warranties that the information will be: current , secure , accurate , complete  or free from bugs or viruses 

We publish impartial information about our women’s aid service. This does not substitute independent legal advice. You should get professional or specialist advice before doing anything on the basis of the content. 

We’re not liable for any loss or damage that may come from using the PWA website.

Opinions expressed within the information contained in this website are those of the authors and do not necessarily represent the opinion of PWA. 

 

Governing law and legal enforcement 

We are situated in Scotland and the law of Scotland shall govern any interpretation of these Terms and Conditions. The Scottish Courts shall decide any disputes between us. 

We fully co-operate with the police in identifying those who use our service for illegal activities. We reserve the right to report to the police any activities that we reasonably believe to be unlawful. 

 

 

 

Information about you and your visits to the PWA website 

We collect information about you in accordance with our privacy notice and our cookie policy. By using the PWA website, you agree to us collecting this information and confirm that any data you provide is accurate. 

 

About termination of your registration 

If you breach any of these terms we reserve the right to delete any information provided by you to the Site and immediately terminate your ability to access the Site and/or any other service provided by us to you.

 

2.     Our Privacy Notice

PWA wants to make sure that  you understand how we process your personal data and information.

We are also required by data protection law to explain certain matters to you. This notice sets out that information.

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

• People who use our services; including
• People who contact us via social media
• People who call our helpline
• People who email us
• People who make a complaint to us; and
• People who support our service.

 

Our lawful basis for processing data:

Data protection law sets out that we must have a lawful basis for processing your personal data.  The lawful basis upon which we collect and process personal data is the one called legitimate interests.

Our legitimate interests are:

·       Being able to provide you with the service that you have asked us to

·       Being able to provide evidence of the work we have done to our funders to seek to continue receiving funding and allow us to continue to provide  funded services in the future

·       Collecting data to provide this evidence effectively

We collect and use sensitive information to:

·       To identify trends and shape our services to best meet the needs of people who use our service

·       Reduce the risk of harm to Women, Children and Young People

 

People who use our services will reasonably expect that we need their name and contact details in order to contact them and to continue the service, that we would hold support and safety plans to monitor the progress of their service and make sure that risk of harm is reduced. We will keep any information which is reasonably necessary for us to provide our services e.g. personal data and information which is provided in order to assist us in making a benefit application on behalf of an individual. Data processing is necessary to achieve this.

We also recognise individuals’ rights and freedoms.  We acknowledge the added responsibility which processing data for legitimate interests gives us.

If a service user requests at any time that their personal data is deleted from our system we will comply with their request wherever possible. However, our ability to provide services will be negatively impacted if we don’t have a service user’s personal data (e.g. their contact details).

 

People who use our services.

We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes.

These purposes may include contacting people who have used our service to complete a survey or evaluation about their experience of our service, or to invite them to events or to meet with our funders or regulators such as Care Inspectorate, Scottish Social Services Council, OSCR or any other regulator connected to PWA.

Limited personal information may be required by funders to evidence that public funds are being used appropriately in line with our funding commitments.

For all people who use our services we will collect and hold:

• Personal information (such as name and address, telephone number, email address, national insurance number)
• Characteristics (such as ethnicity, language, nationality)
• Support information (such as support plan, safety plan, risk assessment, notes from meetings, group sessions attended)

Why we collect and use this information:

We use the data:

• to provide appropriate support and care
• to monitor and report on progress
• to check the quality of our services
• to report to funders on the work we carry out
• to comply with the law regarding data sharing

 

We will hold personal data about people using our services for 7 years from their last point of contact.  This is required by the organisations who provide funding for PWA.

Some of the data that people using our services provide us with might include sensitive personal data. This includes information about medical conditions or criminal activity.

 

People who call our helpline

When you call PWA’s helpline we will collect personal information about you and will make notes of the content of your call and will record these on our secure case management system. This is to help us to provide our service and allow call handlers to work with you on future calls.

 

People who email us

Email communication from service users and any replies that we make are copied into the service users own file within our secure case management system and deleted from the email system within three months. We only communicate by email with service users who have given permission for this and who have informed us that their email address is safe.

Any legitimate information sharing by email which contains any personal information about service users between PWA and any third party is done through our secure, encrypted email system.

Any email sent to PWA, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. 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.

 

People who make a complaint to PWA

When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint. We will only use the personal information we collect to process the complaint and to check on the level of service we provide.

We compile and share statistics showing information such as the number of complaints we receive, but not in a form which identifies anyone.

We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for five years from closure to enable us to assess any patterns of complaint over a period of time. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

Some of our services are regulated by the Care Inspectorate and we must share information with them on complaints that we receive and this will include the complainant’s identity and any individual the complaint is about. Information is shared with the Care Inspectorate via their secure online portal and processed and retained by them in line with their retention policies.

PWA’s funders may require us to provide information about complaints we have received. In such cases we will provide information in an anonymised format unless we have sought express permission from the complainant to share their personal information.

Similarly, where enquiries are submitted to PWA, we will only use the information supplied to us to deal with the enquiry and any subsequent issues, and to check on the level of service we provide.

 

People who support PWA

Any personal information that is provided by individuals to support PWA will be retained for the following periods:

• Individuals making one off donations – personal information will be retained for two years so that the donation can be acknowledged.
• Individuals making regular donations – personal information will be retained for two years following the last donation so that the donation can be acknowledged.
• Individuals offering support in the form of political or lobbying support – personal information will be retained for two years following the last active contact.
• Individuals offering support in the form of volunteering – personal information will be processed as per our privacy statement for applicants, employees and volunteers.

 

Individuals Connected to People who use our services

We process the personal data of individuals connected to people using our service in order to provide our service and to identify risks to those we work with. We also process the personal data of individuals connected to people using our service as part of our role on multi agency risk reduction partnerships. We only process this information in order to protect the lives of people using our service.

 

Your rights

You have certain rights in relation to the personal data which we process about you:

• You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights; this is why we are providing you with this privacy notice.
• You can request to access your personal data.
• You have the right to restrict some processing of your personal information, which means that you can ask us to limit what we do with it;
• Subject to certain limitations you can request that your personal data is erased. We will comply with this wherever possible.
• Where we hold data that is inaccurate, you can ask us to complete or rectify this,
• You also have the right to complain – please see below.

 

Complaints or queries

PWA 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 to try to make this information accessible and understandable.  If you need further information please get in touch with us to discuss.  If you are unhappy with our response, you can complain to the Information Commissioner in their capacity as the statutory body which oversees data protection law – www.ICO.org.uk/concerns.

 

Access to personal information

PWA tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under data protection law. If we do hold information about you we will:

• give you a description of it;
• tell you why we are holding it;
• tell you who it could be disclosed to; and
• let you have a copy of the information in an intelligible form. Sometimes it is helpful for us to share the information you give us or to obtain information about you from other services. However, we will not pass on any or collect information without your consent, other than in the following circumstances:

 

Disclosure of personal information

• Where we have a statutory duty to do so in order to protect you, prevent harm to someone else, for example a child, or prevent or detect a crime. If we have to share information in these situations, we will only share information that will improve your and/or your children’s safety. We will always try and tell you when information is being shared unless it is not safe for you or someone else or we can’t contact you. Further information is available in our Child and Adult Protection Policies about the factors we consider when deciding whether information should be disclosed.
• Service users’ names and dates of birth may also be shared with our funders’ monitoring officers as evidence of legitimate use of public funds.
• Anonymised data may be shared with Scottish Women’s Aid to support them in their role as umbrella organisation for certain Women’s Aid organisations in Scotland.
• PWA is regulated by the Care Inspectorate and monitoring officers from this agency may require access to case files during monitoring visits to review PWA’s practice. No personal information will be processed or removed during monitoring visits by the Care Inspectorate, unless there is a statutory requirement for this. The Care Inspectorate may also require PWA to provide details of reportable incidents. Any personal data shared with them will be limited to that which is necessary for the Care Inspectorate to investigate the incident and will be shared only through the Care Inspectorate’s secure portal.
• If we do hold information about you, you can ask us to correct any mistakes either verbally or by sending an email or letter to the Data Controller at the addresses set out below.
• If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
• To make a request to PWA for any personal information we may hold about you please put the request in writing marked for the attention of the Data Controller and sent to the email or postal address provided below. Personal information can be requested verbally, but we may need to verify your identity before releasing your information. If you request your information verbally we may ask you to confirm your identity and a member of staff will record the process of confirmation.

 

Right to be forgotten

You have the right to have the personal data that we retain about you erased under the following circumstances:

• The personal data is no longer necessary for the purpose which we originally collected or processed it for;
• If you object to the processing of your data, and we don’t have an overriding legitimate interest to continue this processing. An example of an overriding legitimate interest would be if you were staying in refuge and we required your personal data to process housing benefit or to administer the rent and bills that we receive from you.
• If we have processed your personal data unlawfully.
• If we are legally obliged by you to do so.

 

Links to other websites

This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

 

 

3.     PWA Online Cookie Policy

Cookie Policy

What’s a cookie?

A “cookie” is a piece of information that is stored on your computer’s hard drive if you agree to this and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.

Cookies are used by nearly all websites and do not harm your system.

We are required to obtain your consent for all non-essential cookies used on our website. You can block cookies (including essential cookies) at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block essential cookies you may not be able to access all or parts of our site.

How do we use cookies?

We use cookies to track your use of our website.

This enables us to understand how you use the site and track any patterns with regards how you are using our website. This helps us to develop and improve our website as well as products and / or services in response to what you might need or want.

Cookies are either:

Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or
Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics.

Cookies can also be categorised as follows:

Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests.
First and third party cookies: First party cookies are cookies set by our website.
We use only first party cookies on this website.

You can alter your cookie preferences at any. Please refresh your page to ensure that the new settings have taken effect. You can also control your cookie settings through your web browser.

You can opt out of being tracked by Google Analytics across all websites, by going to http://tools.google.com/dlpage/gaoptout.

If you have any questions about the cookies that we use, feel free to get in touch to talk about it.