Introduction

This privacy policy explains how Enfield LGBT Network (ELGBT) uses personal data.

ELGBT are data controllers of this information for the purposes of this policy.

Personal data is defined in Data Protection law and is essentially personal data by which an individual can be identified.

Keeping your personal data safe and secure is one of ELGBT’s top priorities and to ensure we give it the respect and security it deserves. This statement makes it easier for you to find out how we use and protect your information.

We are extremely concerned to protect your privacy and confidentiality. We understand that all users of our services are quite rightly concerned to know that their data will not be used for any purpose unintended by them and that it will not fall into the hands of a third party.

If you think our policy falls short of your expectations or that we are failing to abide by our policy, do please tell us.
Any changes we make to this privacy policy in the future will be managed through an updated version of this document and, where appropriate, notified to you by e-mail.

Please contact us to see any updates or changes to this privacy policy.

When does this policy apply?

This policy applies to the personal data that ELGBT collects and holds about you when you become a service user, member or when using other services e.g. Asylum Support.

What types of personal data do we hold?

Information we hold about you may include any one or more of the following types of data:

• Service User information:
  When you become a service user of ELGBT, will usually ask you to provide your name, email address, telephone number. We may also ask you for additional information e.g. nationality, date of birth depending on the service you are requesting from us.
• Information from you:
  If you contact us (by email, telephone or letter), we may keep a record of that correspondence. Your e-mail address is recorded when you send e-mail to us. We shall use it only to correspond with you or otherwise strictly in accordance with your instructions. We shall not under any circumstances divulge your e-mail address to any person who is not a member of the Board of Directors or a member of staff, unless you give us permission to do so.
• Online usage information:
  If you use our web site we may, in the future, collect your browser type, the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), pages you viewed or searched for, page response times, length of visits to certain pages, page interaction information, (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page. In addition, online usage information may be linked to a unique identifier but we do not link online usage information to named individuals. In order to collect online usage information we may use cookies and other similar technologies. However we do not currently do this.
  Although we do not disclose your personal information to any third party (except as set out in this notice i.e. when you tell us to e.g. in letters to solicitors or the Courts for Asylum Claims), we may receive data which is indirectly made up from your personal information, from software services such as Google Analytics and others. No such information is identifiable to you.
  Your browser software provides help on how to manage and disable cookies. We recommend that you allow the use of cookies in order to take advantage of the features of our website that rely on their use. If you prevent their use, you may not be able to use all the functionality of our website.

Where we hold your information

The data that we collect from you is stored at a destination inside the EU. It is processed by staff operating inside the UK who are members of the Board of Directors or Staff. They may be engaged in, among other things, details and the provision of support services. By submitting your personal data, you agree to this storing or processing. We will take all steps to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on secure servers and computers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

The purposes for which we use your information

• Legal obligations: ELGBT may use (and disclose) the information it holds about you in order to comply with any investigative demand, court order, or a request for cooperation from a law enforcement or other government agency.
• Other legitimate purposes: ELGBT analyses information it holds about you to identify trends in demographics e.g. age, gender, the areas members live in, in order to plan the services we provide and for statistical analysis and to report to commissioners. This is in order to improve the way we meet the needs of congregants and attenders.

Disclosure of your information

• LBE: Information held by ELGBT may be used by ELGBT for the purposes set out in this policy. ELGBT does not sell, rent or share your personal identifiable data with any other company or third parties but we may share aggregate/anonymised information which is based on your data with commissioners for data analysis.
• Disclosures for legal reasons: ELGBT may also disclose the information it holds about you to those persons that have a reasonable need to know such information, if it believes in good faith
  that this is necessary to: (i) establish, exercise or enforce its legal rights, including contractual rights; (ii) to defend itself against a legal claim; (iii) report a crime or prevent a crime; (iv) prevent harm to any individual or any property (including intellectual property, for example if you misuse images or videos or any other content ELGBT makes available to you); or (v) to prevent fraud.

How long do we keep your information?

Enfield LGBT Network will keep your information for as long as necessary for us to fulfil that we describe in this policy. As a general rule: • its financial transactions with you for six years in order to comply with its obligations to maintain adequate accounting records;

• its contracts with you for six years so that it has appropriate evidence in place if there is a claim for breach of contract made within the statutory limitation periods;
• job applications for up to six months in case other suitable opportunities arise;
• your name, address, email address, and date of birth until you cease to be a service user;
• any other information you post online for 3 years if it is on the main Facebook page and online usage information for 3 years.

If any information falls into more than one category, then the longer storage period will apply.

Your rights

You have the right under applicable data protection laws to access information held about you and you can do so by contacting us using the details provided below in this policy. Your right of access can be exercised in accordance with applicable data protection laws.

To better safeguard your information, we will also take reasonable steps to verify your identity before granting access or making corrections to your information.

You have several rights under applicable data protection laws, which we’ve summarised below. These rights can be exercised by contacting ELGBT using the details given below in this policy.

You have the right to:

• ask us not to process your personal data for direct marketing purposes;
• request access to personal information held about you and a copy of it;
• obtain, without undue delay, the rectification of inaccurate or incomplete personal data;
• obtain, without undue delay, erasure of your personal data in certain circumstances, for example if ELGBT processing of your personal data is no longer necessary for the purpose for which we collected it;
• restrict the processing of your personal data in certain circumstances rather than having it erased;
• object to the processing of, personal data in certain circumstances, for example, where ELGBT’s processes personal data for legitimate purposes but you do not feel that your interests or fundamental rights and freedoms have been protected;
• receive personal data, which you have provided to ELGBT, in a structured, commonly-used and machine-readable format and transmit that personal data to another data controller, or have ELGBT do so on your behalf where technically feasible;
• be informed about any use of your personal data to make automated decisions about you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and
• lodge a complaint about the way in which your personal data is being used to a supervisory authority.

Children

We appreciate that many children have access to the Internet. We would therefore ask that parents and guardians supervise their children when they are online and that children under 16 do not submit personal information or content to ELGBT, without the consent of their parent or guardian.

We encourage children under 16 to consult with their parent or legal guardians before submitting or requesting any content or information to/from us. Any users of our online services who indicate they are under 16 will be asked for contact details of their parent / legal guardian so we can verify legal consent.

Some comments/content accessible through our online facilities are not intended to be accessible by minors. Parent or legal guardians should supervise children when online are we recommend parental controls be put in place. Any child using our online facilities is confirming that they have received the consent of their parent or a guardian to do so.

How you can contact us

This policy has been compiled to comply with current GDPR legislation as far as we are aware and from directives currently available from the Information Commissioner’s Office (https://ico.org.uk), as at the date stated at the end of this policy.

Should you wish to contact ELGBT about this policy or any of the legal rights outlined in it, you can email ELGBT’s Data Protection Policy Officer at info@lgbtenfield.org or write to; Enfield LGBT Network, Lancaster Centre, 53 Lancaster Road, Enfield, EN2 0BU.

This policy was late updated 16th January 2021