Introduction

This policy describes how City Year UK collects, uses and protects personal data we receive from volunteer mentors and individuals external to our charity, including through our website.

As a continuously improving independent charity City Year UK systematically collects data about our contacts, participants and organisations such as schools, in order to improve our services and measure our impact on our beneficiaries. City Year UK respects the confidentiality of all the individuals with whom we engage and this policy describes the way in which we process, analyse, archive and dispose of such data to ensure confidentiality and compliance with the General Data Protection Regulations (GDPR).

City Year UK is registered with the ICO and conducts its work according to the five underlying principles of GDPR, attached in Appendix 1.

Detail

  1. What personal information is collected and on what lawful basis?
  2. Why is it collected and how do we use it?
  3. How is the data protected?
  4. How long do we store data for?
  5. How can individuals stop City Year UK contacting them?
  6. What is the process for deleting data?
  7. What happens when we receive a Subject Access request?
  8. Complaints procedure
  9. Data breach procedure
  10. GDPR guidance online
  11. Privacy policy

1. What personal information is collected and on what lawful basis?

a. Recruitment

The recruitment department collects information about individuals interested in joining City Year UK, including contact details (name, address, email address, telephone number), educational institution attended, and personal demographic/background information (such as age, sex, ethnicity). An expression of interest will only be advanced and personal data collected if consent is granted on the initial form. It is then recorded on the contact’s record.

b. Programme

Programme obtains the above information about individuals if they become volunteer mentors. On joining the programme, a Volunteer Agreement and Confidentiality Agreement are signed and recorded on the contact’s record. The volunteer mentor also marks that they have read this Data Protection policy. The Agreement provides City Year with the legitimate interest to hold and process their personal data for the duration of their year of service. More detail about the information we collect and how we use it is in section 2 below.

When volunteer mentors complete their year of service with City Year UK and become alumni, Programme will then ask for consent, via a privacy notice, to hold their information for impact reporting purposes and this is recorded on the contact’s record.

Programme processes school data about pupils in the schools in which we serve. The department collects the following details: first names and surnames, information about whether the pupil is eligible for free school meals, has special educational needs, speaks English as an additional language, and the year in which they would have completed year 11/GCSEs. They also collect school pupils’ progress data throughout the year in order to measure the impact of the programme.

Only programme staff are able to identify the pupils by name and all data is anonymised for use in impact evaluation and reporting across the organisation.

There is a GDPR agreement between the partner school and City Year UK that covers this data collection under legitimate purpose for the period of the partnership.

c. Development

The Development department collects details about corporate and trust funders, individual donors, corporate volunteers and prospective supporters. Development also records contact details of key contacts at our current funders and prospective funders’ organisations under legitimate purpose (name, email address, organisation and job title) to support with the stewardship of our partners and new business funding requests.

When making an individual donation, contacts’ details (name, address, email address, telephone number), and information about the amount donated is collected.

When making an online credit card donation individual givers’ payment details are processed through a third-party secure server payment gateway.

When required, consent is requested via an online privacy notice and is recorded on the contact’s record.

d. Communications

The communications department collects contact details from individuals external to City Year UK through various marketing systems. On the website, individuals can opt-in to receiving our newsletter at which point, City Year UK obtains their contact details, including name and email address. When people visit our website, City Year UK ask for their consent for the use of ‘cookies’ which are a type of file stored on internet devices (PC, phone or tablet) and used by most websites in various ways, including enabling visitors to login and generally personalise and improve the online experience.

2. Why is it collected and how do we use it?

a. Recruitment (staff and VMs)

Recruitment collects information for the purposes of contacting and keeping track of applicants, and for equal opportunities monitoring within City Year UK. If an applicant is successful, the information will be used for personnel records and payroll and other payment purposes which will be processed both manually and automatically. We may also use aggregate information for reporting purposes but this will not include personal data; for example, we create statistics and related graphs to show the level of ethnic diversity across volunteer mentors through figures and do not include names.

City Year UK will use your data to apply for necessary DBS checks only if you are successful in getting a place on our programme. At this stage we will also be required to see original identification documentation. This will mean sharing your personal details with Atlantic Data Ltd and, subsequently, DBS. Your personal data supplied for the purpose of this application will be kept for as long as necessary. Once the checks are submitted or you are unsuccessful in gaining a place on the programme, we will delete scans/shred paper copies of documentation that you provided for the purpose of your DBS application.

b. Programme

Pupils

A major component of volunteer mentor activity is engaging with pupils who are at risk of falling behind with their attendance, behaviour or curriculum, known as their ‘focus list’. City Year UK needs this information about each pupil to compile such lists and to assess our impact in anonymised reports.

Volunteer Mentors

For the duration that a volunteer mentor is on the programme we will retain personal and sensitive information about their health and well-being and their progress throughout their year of service, through their personal development plan, surveys and in limited cases, occupational health assessments. We will also retain interview notes and observation records. We will require them to complete a CV which will be used to support their career development by sharing their C.V.s (with permission) with third parties for Interview Skills practice and share information about them with their Corporate Mentor while we are matching them. We will also gather stories, quotes and photos from their experience of their service year and will use these to communicate the positive experiences of completing a year of service.

Safeguarding

We ensure that no identifying details are recorded by programme staff and that the only information we hold about a safeguarding incident is a log of the nature of the incident. The only exception to this is when an issue is raised about a child outside of the school setting, in which case an email with the details of concern will be emailed to the school. This email will remain confidential and held in a closed Google team drive accessible only to Designated Safeguarding Leads in the organisation.

Alumni

It is important to City Year UK that we keep in touch with previous volunteer mentors. We often need to provide references and verification of full time volunteering. We want to understand what alumni go on to do, find ways of supporting them in their future career paths and keep them engaged in the City Year UK mission.

c. Development

Development collects personal information to process donations and to collect Gift Aid on donations. Development needs to keep a record of who donates and when for our financial records and to pursue future donations. Development also contacts corporate volunteers and funders, who are supporting our work, about upcoming events and news to keep them updated.

d. Communications

The communications department aims to inform stakeholders, members of the public, political, potential funders and recruits about City Year UK’s mission and how they can support with growth and impact of the programme. It is essential then that we collect contact details and personal information about those who interact with us, or may wish to, to increase City Year UK’s communication reach.

3. How is the data protected?

We will keep all personal data secure. Most of the data collected across departments is stored and safely protected (via password access) in Salesforce. Data may also be stored in City Year UK’s shared drive which is only accessible to City Year UK staff by role (via personal login and two step verification), and some folders/documents with particularly sensitive data will be password protected with restricted access to only the necessary members of relevant staff.

By locking computers when staff are away from their desks, especially if individuals are not on City Year UK premises, City Year UK reduces the risk of personal data being accessed by unauthorised individuals.

Our data servers are continuously monitored and underlying infrastructure is used to protect them from threats, including spam, malware, viruses and other forms of malicious code. We use encryption to keep data safe and private while it is in transit.

In the rare case where a physical document is required, the documents are stored in locked filing cabinets, and the data is shredded and destroyed as soon as it is no longer needed.

4. How long do we store data for? (retention)

Our approach is that we do not keep any information about individuals for longer than needed.

For volunteer mentors, this is for the period of their volunteering year of service.

Other contacts have retention periods defined by the specific use of their data in line with reasonable operational need.

Data auditing is also something that occurs periodically across the organisation. We will contact individuals to ask for updated details at regular intervals.

5. How can individuals stop City Year UK from contacting them?

Volunteer mentor applicants, newsletter recipients, corporate volunteers and donors can either opt-out when contacted by us (mostly by email), or can contact us to correct or erase data. If individuals sign-up to our newsletter they will have the option to unsubscribe at any point and will then be removed from our contact database.

6. What is the process for deleting data?

Each department has a destruction schedule based on the retention period for each category of data.

If the data is stored in hard copy (e.g. paperwork) all departments use a shredder or secure destruction bin to safely dispose of documents. If the data is stored digitally (e.g. in emails or on the shared drive) the data needs to not just be deleted from the folder, but in some cases ‘double’ deleted – so deleted from the ‘recycle bin’ on email or desktop.

On G Suite, we use the spanning backup and all ex-staff files are exported and archived under a secure account that is only accessible to the IT department.  Closed Spanning accounts data is purged after 30 days. Windows server – S Drive backups are done daily to Zen backup off site servers. This data backup service retains data backups for 30 days. For all off site backups data is moved and stored using 256-bit AES encryption.

On Salesforce, we have an automated process that flags when retention periods end so that a consent renewal request can then be sent. Any personal data without consent or legitimate purpose is then deleted. This also happens when individuals opt-out of our direct mailing at anytime.

7. What happens when we receive a subject access request?

Any member of the public who is a subject of personal data held by City Year UK is entitled to:

  • Ask for what information the charity holds about them and why.
  • Ask how to gain access to the information held about them.
  • Be informed on how to keep the data up to date.
  • Be informed on how the charity is meeting its data protection obligations.

Should any employee receive a request for personal information or a complaint (either formally under the general data protection regulations or informally as an ad hoc request), then please forward it to the Data Systems Manager at gdprsupport@cityyear.org.uk.

We will comply as soon as reasonably possible and within no more than one month.

If we refuse to comply we will inform the individual within a month why that is, and that they have the right to complain as below.

8. Complaints Procedure

If anyone wishes to complain to City Year UK about how their personal information has been processed, how their (GDPR) complaint has been handled, or appeal against any decision made following a complaint they can do so by emailing gdprsupport@cityyear.org.uk.

The complaints procedure for handling and escalation of these complaints is as follows:

  1. Complaints regarding how personal information has been processed should be submitted to the Data Systems Manager, at the email address above, who will acknowledge receipt within 3 working days.
  2. The Data Systems Manager will review and respond in writing to the complainant as soon as possible and within no more that 28 working days of receipt of the complaint. If an extension is required, this will be with the agreement of both parties and up to a maximum of a further 10 working days.
  3. If the complainant remains dissatisfied they may forward your complaint to: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

9. Data Breach Procedure

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, City Year UK shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Information Commissioner’s Office  (more information on the ICO website).

10. Links to GDPR guidance online

ICO checklist for Subject Access Request

ICO Subject Access Code of Practice

If you have any questions after reading this policy please seek advice from Sophie Segal who is our Data Manager or Michael Joseph who is our Director of Finance.

11. Link to our Privacy Policy


Appendix 1:  Data protection principles

City Year UK is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

Appendix 2:  GDPR Principles that apply to this policy

Definitions

GDPR Means the General Data Protection Regulation
Responsible Person Means Data Systems Manager
Register of Systems Means a register of all systems or contexts in which personal data is processed by the Charity.

General provisions

  1. This policy applies to all personal data processed by the Charity.
  2. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.
  3. This policy shall be reviewed at least annually.
  4. The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data.

Lawful, fair and transparent processing

  1. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
  2. The Register of Systems shall be reviewed at least annually.
  3. Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.

Lawful purposes

  1. All data processed by the charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
  2. The Charity shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in  consent shall be kept with the personal data.
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Charity’s systems.  

Data minimisation

  1. The Charity shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Accuracy

  1. The Charity shall take reasonable steps to ensure personal data is accurate.
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

Archiving / removal

  1. To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  2. The archiving policy shall consider what data should/must be retained, for how long, and why.

Security

  1. The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date.  
  2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
  3. When personal data is deleted this should be done safely such that the data is irrecoverable.
  4. Appropriate backup and disaster recovery solutions shall be in place.