Earlsdon Carnegie Community Library: Data Protection and Privacy Policy

This document constitutes the privacy policy of Earlsdon Carnegie Community Library, (referred to subsequently as ECCL), for Coventry City Council Library Service users, ECCL volunteers, supporters of ECCL and other users of ECCL’s services or facilities. Your privacy is important to us so we will always keep your details secure in compliance with the United Kingdom GDPR and the Data protection act 2018.

Except where otherwise stated, ’we’ and ‘us’ in this document refers to ECCL.

1. Statement of Policy

Earlsdon Carnegie Community Library is a registered charity (no. 1180063) that is operating a community library in Earlsdon delivering Coventry City Council’s Library Service and operating its own activities and services for the community.

Coventry City Council Library Service users should read this Privacy Notice together with the Coventry City Council Library Service Privacy Notice (http://www.coventry.gov.uk/info/126/libraries/3213/join_find_use/6) which explains how information about you is used when you become a member of any of Coventry City Council’s libraries including community libraries.

ECCL is committed to protecting any personal data that we are entrusted with. We want volunteers, supporters and those who use our services to be clear about how we use and look after any personal information that they share with us. This policy sets out how we collect, use and store personal information and the rights of anyone whose personal data we hold. The holding and processing of data is governed by the General Data Protection Regulation (GDPR) and the Data Protection Act (DPA) 2018.

2. Who are we under the GDPR and DPA?

ECCL is termed the Data Controller for personal data provided to or obtained by us from volunteers, supporters and users of ECCL services and facilities. This means ECCL decides how your personal data is processed and for what purposes.

ECCL has a more limited function when delivering Coventry City Council’s Library Service

3. Your personal data – what is it?

Personal data means any information relating to a living individual who can be identified directly or indirectly from that data. Identification can be by that information alone or in conjunction with any other information in the possession of ECCL.

We may collect your personal data when you register for or participate in events or an event, when you make a donation to us, apply to become a volunteer or otherwise provide us with your personal information. This includes when you meet our volunteers at an event, phone us, visit our website, email or write to us.

Sensitive Personal Information

Data Protection law recognises that some categories of personal information are particularly sensitive. Sensitive Personal Information can include information about a person’s health, race, ethnic origin, political opinions, sex life, sexual orientation or religious beliefs. We may request sensitive personal information for the purposes of implementing our Equality and Diversity policy, in particular to monitor our volunteer recruitment processes and to ensure that our support services are meeting the diverse needs of our local community. We will always ask your consent to collect this data and it will only be used for these monitoring purposes.

We will only use this information for the purposes of monitoring or evaluating the services we provide. We will not pass on your details to anyone else without your express permission except in exceptional circumstances and where we are required to do so by law (outlined in our safeguarding policy).

If you provide us with any Sensitive Personal Information by telephone, email or by other means, we will treat that information with extra care and confidentiality and always in accordance with this Privacy Policy.

4. Why we need your information

Volunteers

When you apply to join the Library as a volunteer, we ask you to complete a form to give us your name, home address, date of birth, contact details and information about ethnicity and disability. You may also have provided us with recruitment information about ways in which you are able to assist the Library in a volunteer capacity. You are not required to give us this information, but if you do so, we will use it for the purposes of managing your application and involvement with ECCL and for equal opportunities monitoring only.

Supporters of ECCL and users of ECCL’s services or facilities

The circumstances when we might collect personal information include:

• When you donate directly to ECCL through a system established and administered by ECCL
• When you personally apply to use the Library facilities or to make use of any service provided by ECCL
• When you interact with us through third parties: for example, if you donate to us through a third party such as BT My Donate and provide your consent for your personal information to be shared with us.
• When you visit our website: for example, if you fill in a form available on our website.

The personal information we collect may include your name, date of birth, email address, postal address, telephone number and, if you are making a donation, your bank card details and other information you provide in any communications between us or with third party fundraising websites.

We will mainly use this information:

• To provide events and room hire services and to share information about our work with you.
• To process your donations or other payments, to claim Gift Aid on your donations and verify any financial transactions.
• To update you with important administrative messages about your donation, training/events or services you have requested.
• To comply with the Charities (Protection and Social Investment) Act 2016 and follow the recommendations of the official regulator of charities, the Charity Commission, which require us to identify and verify the identity of supporters who make major gifts so we can assess any risks associated with accepting their donations.
• To keep a record of your relevant transactions with us.
• Where you volunteer with us, to administer the volunteering arrangement.

If you do not provide this information, we will not be able to process your donation or provide services you have requested.

We may also use your personal information to contact you about our work and how you can support ECCL.

5. What is the legal basis for processing personal data?

Data protection laws set out a number of bases on which organisations can collect and process personal data. We may rely on the following legal bases:

• Consent: in most instances we obtain explicit consent from each individual (“data subject”) for the purposes of administering our volunteer system or so that we can keep you informed about news, events, activities, services and, where applicable, process your donations and recover Gift Aid from HMRC.
• Contractual obligations: sometimes, we need your personal data to comply with our contractual obligations, for example, for us to provide room hire services.
• Compliance with legal obligations: we may need to collect and process your personal data if required by law, for example we must keep records of our Trustees.
• Legitimate Interest: whenever we process your Personal Information under the ‘legitimate interest’ lawful basis we make sure that we take into account your rights and interests and will not process your personal information if we consider there is an imbalance between the respective rights and interests of each party. Some examples of where we have a legitimate interest to process your Personal information are where we contact you about our work via post, improving our services, for our legal purposes (for example, dealing with complaints), or for complying with guidance from the Charity Commission and HMRC.

6. Who we share your information with.

Your personal information will be treated as strictly confidential and we will take reasonable steps to ensure that it is kept secure. The personal information we collect about you will mainly be used by our volunteers so that we can provide services to you or manage your volunteering.

We will never sell or share your personal information with organisations so that they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity.

Except as stated here we will not disclose your personal information to other individuals or organisations outside ECCL.

• We will share data with Coventry City Council’s Libraries Service, for volunteer training purposes, and with Three Rings for purposes connected with the administration of ECCL, in particular that of providing a volunteer rota system for the library. Please refer to the Three Rings Privacy Policy for further information: https://www.3r.org.uk/privacy.
  
• ECCL 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 the data securely, delete it when they no longer need it and never use it for any other purposes. Examples of where we may share your information are with our outsourced accountants and Three Rings (see above). 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 to secure your information. Legal disclosure: We may need to disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority).

7. How long do we keep your information for?

We only keep your personal data as long as is reasonable and necessary for the relevant activity, for which the data was provided. This will depend on the specific activity or event but retention would not normally exceed a period of 2 years after their termination

We may also retain personal data to comply with statutory obligations (for example, we need to keep data related to Gift Aid for a statutory determined period, currently 6 years).

8. Keeping your data safe

The processing of all the personal data we hold is done by our volunteers in the UK. However for the purposes of IT hosting and maintenance this information may be located on servers elsewhere. Where we transfer your information outside the EEA (European Economic Area), we will only use processors certified as compliant with the EU Privacy Shield and committed to complying with the provisions of GDPR. An example is the processor whose services we use for emails and to securely share files between our core trustee team. Our policies, procedures and training cover data protection, confidentiality and security of data. We conduct regular reviews to ensure that that we continue to hold data securely.

9. Your rights and your personal data

You have the right to:

• Ask for a copy of information we hold about you
• Correct any information about you that is found to be inaccurate or out of date
• Withdraw your consent at any time to the processing of data
• Ask us to delete or destroy any personal data we hold about you where it is no longer necessary for ECCL to retain such data, as, for example, if you cease to be actively engaged as a library volunteer
• You have the right to complain if you are unhappy with the way your request is handled, or disagree with a decision made by the trustees about your data
• If you want to make a complaint you can contact the ECCL Data Protection Officer and request a review of the decision
• Complain to the Information Commissioner’s Office

10. Contact Details

To exercise all relevant rights, queries or complaints please in the first instance contact: The Data Protection Officer, Earlsdon Carnegie Community Library, Earlsdon Avenue North, Coventry CV5 6 FZ or at admin@earlsdonlibrary.org.uk

If you are not satisfied you can contact the Information Commissioners Office at:

The Information Commissioners Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113 (local call rate)

Earlsdon Carnegie Community Library is a charity registered in England and Wales. Registration number 1180063.