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Privacy Policy Notice – Service Users & Employees
Gloucester Street Community Centre (GSCC) are committed to complying with the General Data Protection Regulation and the Data Protection Act 2018. Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer you a better and more personalised service. Click on The 6 Principles of Data Protection in GDPR Statement for more information.
We have published this notice to help you understand
• how and why we collect information from you;
• who we share your information with, why and on what basis; and
• what your rights are.
If we make changes to this notice we will notify you by updating it on our website. GSCC will be what is known as the ‘Data Controller’ of the personal data you provide to us, and we will sometimes refer to ourselves in this notice as “we” or “us”. By Data Controller, this means GSCC determines the purposes and way in which any personal data are, or will be, processed.
Should you need to contact us please write to:
Data Protection Officer 1-8 Gloucester Street, Wolverhampton, West Midlands. WV6 0PT
or via admin@gscommunitycentre.org.
What information we collect when you register and why?
When you apply for the childcare service from us, you are entering into a contract with us. You will need to complete forms such as registration and consent forms, so we can set up your child(rens) personal file, so we will ask you to provide some personal information about yourself and your child such as;
• full name
• address (and previous addresses)
• date of birth
• contact numbers
• email address
• Child’s name
• School
• GP
As an existing service user we will continue to invoice you via email or by post in order for you to settle your account within the given timescale.
For employees and other community centre service users, your information retained as above will only be used to support the services we provide for you either as an employee or participant on the project.
When you visit our Community Centre we use CCTV for security monitoring purposes.
How do we use your information?
Data Protection says that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons and these are:
• Contract – your personal information is processed in order to fulfil a contractual arrangement e.g. in order to send you an invoice, contact you in cases of emergency, for you to make payment.
• Consent – where you agree to us using your child’s picture, information or your personal information in this way e.g. for storing your contact details for payment requests, pictures during activities, marketing and promoting the service.
• Legitimate Interests – this means the interests of GSCC in managing our business to allow us to provide you with the best service in the most secure and appropriate way e.g. to share your data to certain Third Party’s such as, Ofsted, Early Years or Social Services.
• Legal Obligation – where there is statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes.
Here is a list of the ways that we may use your personal information, and which of the reasons described above we rely on to do so. Where we list legitimate interests as a reason, we also describe below what we believe these legitimate interests are.
What we use your personal information for Our reasons (legal basis) Our explanation of GSCC legitimate interests
Set up your child(ren) personal file

• Legitimate interest Process efficiency in dealing with such activity.
Emergency contact • Consent N/A
Health & Safety • Fulfilling a contract
• Legal obligation/ Legitimate interests (depending on nature of services) Process efficiency in dealing with such activities or incidents that may occur. We also aim to improve our services and assess risks.
Maintain and update your child’s personal file. • Legitimate interests Keeping our records up to date, handling service user contact efficiently.
Sharing relevant information with Third Parties who require personal data for enforcement purposes, when necessary. • Legal obligation/ Legitimate interests (depending on nature of services) Maintaining our legal obligation to share data with relevant Third Parties
Marketing and promotion communications to inform you of GSCC events and new services. • Legitimate interests Developing products and services, that attract and retain service users. Improving service user interaction with the Community Centre.
Contact you to undertake service user satisfaction surveys – feedback. • Legitimate interests Developing services and activities that attract and retain service users. Improving service user interaction with our centre.
Who we share your information with and why
GSCC work with a number of trusted and registered agencies and businesses in order to provide you with best practice, good quality child care services that you should expect from us. We also adhere to our legal obligations by contacting and sharing information with Third Parties when required. Some examples of the categories of third parties with whom we share your data are:

Ofsted
In order to run a childcare service we are required to adhere to Ofsted regulations and from time to time they may request specific information about our service users.

Local Authority
Safeguarding Vulnerable Groups Act 2006 and the Protection of Freedoms Bill. This Safeguarding Vulnerable Groups Act (SVGA) 2006 was passed to help avoid harm, or risk of harm, by preventing people who are deemed unsuitable to work with children and vulnerable adults from gaining access to them through their work. Therefore, we ensure Child Protection processed and procedures are in place in order to adhere to this legislation.

Partnerships
We work in partnership with local businesses and organisations who help us promote our childcare services on a regular basis and conduct reviews when required.

Payment processing
GSCC works with trusted third party payment processing providers in order to securely take and manage payments.

Keeping in touch with you
We want to keep you up to date with information about our services, special events and activities that your child(ren) might want to engage in. When we set up your child(ren’s) personal file, we will ask you if you want to receive this type of marketing / promotional information.

GSCC will not share your information with companies outside of our establishment for their marketing purposes.

If you do decide you want to receive this marketing/promotional information you can make that request on the application form of by writing to the Data Protection Officer to the address GSCC, 1-8 Gloucester Street, Wolverhampton. West Midlands WV6 0PT, emailing admin@gscommunitycentre.org, or by calling the Main admin office on 01902 425461.

You may continue to receive mailings for a short period while your request is dealt with.
How long we keep your information
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.
We may need your personal information to establish, bring or defend legal reasons such as Safeguarding. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under, ‘How we use your information’ above. The only exceptions to this are where:
• the law requires us to hold your personal information for a longer period, or delete it sooner;
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
• we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
• in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
What are your rights
You are entitled to request the following from GSCC, these are called your Data Subject Rights and there is more information available on the Information Commissioners website www.ico.org.uk
• Right of access –to request access to your personal information and information about how we process it
• Right to rectification –to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
• Right to erasure (also known as the Right to be Forgotten) – to have your personal information erased. Contact us on 01902 425461
• Right to restriction of processing – to restrict processing of your personal information
• Right to data portability – to electronically move, copy or transfer your personal information in a standard form
• Right to object – to object to processing of your personal information
• Rights with regards to automated individual decision making, including profiling –rights relating to automated decision making, including profiling

If you have any general questions about your rights or want to exercise your rights please contact, admin@gscommunitycentre.org

You have the right to lodge a complaint with a data protection regulator in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office (ICO), the data protection regulator in the UK, are available on the ICO website www.ico.org.uk where your personal information has or is being used in a way that you believe does not comply with data, however, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.
Opting In
Service users who want their data used by GSCC for marketing and promotion can opt in. To opt in, please email admin@gscommunitycentre.org and state ‘I wish to opt in to receiving marketing and promotion notifications. Alternatively, you can do so when you complete an application form we provide.
Contact us
Should you need to contact us please write to: Gloucester Street Community Centre, 1-8 Gloucester Street, Whitmore Reans, Wolverhampton. West Midlands. WV6 0PT or via email admin@gscommunitycentre.org