LEWISHAM ISLAMIC CENTRE PRIVACY NOTICE
1.1 Lewisham Islamic Centre (LIC) is immensely grateful for your kind donation, support and service.
1.2 Here at LIC, we are committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner.
1.3 In respect of the personal data that you have provided to us, LIC will be what is known as the ‘Data Controller’ and we will sometimes refer to ourselves in this notice as “we” or “us”or “our”.
1.4 By being a ‘Data Controller’, LIC determines the purposes and ways in which any personal data are, or will be, processed. In other words, LIC is responsible for the proper use and safe custody of your personal information.
1.5 We are a ‘data controller’ for the purposes of the Data Protection Act 1998 and the EU General Data Protection Regulation(GDPR). We take our responsibilities as a data controller seriously and are committed to using the personal data we hold in accordance with the GDPR.
1.6 LIC is committed to complying with the GDPR once enacted on the 25th of May 2018; as maintaining the security of your personal data is our priority.
1.7 We have published our Privacy Notice to help you understand: -
• how and why LIC collects information from you;
• how we use your personal data;
• what personal data we collect;
• how we ensure your privacy is maintained; and
• your legal rights relating to your personal data.
1.8 This privacy notice also assures you that the personal information that you have provided to LIC is to enable us to, process your kind donation or alert you on our events or process the performance of a contract or service, is dealt with properly and securely.
1.9 Not only looking after the personal information you share with us is important, equally important is your utmost satisfaction and peace of mind. We pledge to constantly handle your personal data fairly, transparently and legally. If in any case you are dissatisfied, this privacy notice provides information on how to resolve any issues you have surrounding your personal data.
1.10 If we make changes to this privacy notice, we will notify you by updating it on our website.
1.11 This privacy notice provides detailed information about how we process personal data.
Please read it carefully and, if you have questions regarding your personal data or its use, please contact;
The Data Protection Officer by, email on ;
telephone on 0208 690 5090, post to Data Protection Officer, Lewisham Islamic
Centre, Lewisham High Street, SE13 6NZ.
2. INFORMATION COLLECTED AND PURPOSES FOR WHICH WE COLLECT DATA
2.1 We collect most of the personal data we process directly from the individual concerned or third parties such as referees, previous employment or the Disclosure and Barring Service.
2.2 The personal data we process may be factual information, testimonials, images, video recordings or other recorded information which identifies or relates to a living individual.
2.3 The information relates to prospective, current and past: staff, volunteers, contractors donors, service users, friends and supporters of LIC; and other individuals connected to or visiting LIC (including school visits).
2.4 We do not and will not knowingly collect information from any unsupervised person under the age of 16.
2.5 Examples of information collected include:
• Names, addresses, telephone numbers, e-mail addresses, postal address and other contact
details from referees.
• Employment data of staff, volunteers and contractors.
• CCTV surveillance, images, audio and video recordings of our events.
• Financial information (Standing Orders, Pledge forms or Direct Debits).
• Counselling sessions, meetings or events attended.
• Marriage, Divorce, Khula and New Muslim certificates with their respective application forms.
2.6 We will mainly use this information:
• To keep a record of your relationship with us e.g. legal basis for the performance of a contract
or receiving a service.
• To administer volunteering arrangement/recruitment.
• To process special category personal data (e.g. biometric data) and criminal records
information about staff and volunteers. We do so in accordance with respect to safeguarding
or employment or by explicit consent.
• To process your donations or other payments, to claim Gift Aid on your donations and verify
any financial transactions.
• To enable us to achieve our strategic objective of remaining independent through fundraising
appeals. (We fundraise from individuals, Islamic centres and foundations who want to
support our charitable purposes and do so in accordance with the Fundraising Promise and
Fundraising Code of Practice).
• We will use your contact details to keep you updated about our activities, fundraising
appeals, events and important announcements about Eid and Ramadan. We ask you to let
us know your data preferences so that we can ensure our communications are relevant
to you. You can update your data preferences at any time using the link on our emails. Your
data preferences will not affect our contact with you.
• To provide the services that you have requested e.g. school visits.
• To update you with important administrative messages about your donation, an event or
services you have requested.
• To invite you to participate in our events or workshops.
• When you interact with us through third parties we work with such as PayPal and
JustGiving and have provided your consent for your personal information to be shared with
us whilst donating. (These Merchant Service Providers listed here will contact you with
a similar notice to this one, explaining clearly what they will do with your personal
information in order to process your kind donation).
• For engagement of contractors (including compliance with DBS procedures); administration
of payroll, pensions, sick leave and maternity leave; review and appraisal of staff
performance; handling grievances or disciplinary procedures; and the maintenance of
appropriate human resources records for current and former staff; and providing references;
• The promotion of LIC through its own website and our social media networks;
• For the operational management of LIC including; the administration of invoices and
accounts; the management of LIC’s assets; the management of security and safety
arrangements (including the use of CCTV in accordance with our CCTV Policies and
Acceptable Use Policy);
• For the administration and implementation of LIC’s rules and policies
• To comply with the Charities (Protection and Social Investment) Act 2016 and follow the
recommendations of the Charity Commission, which require us to identify, assess and verify
the identity of donors and speakers who make major donations and give lectures
respectively; for risk implications.
2.7 The processing set out above is carried out to fulfil our legal obligations (including those under our volunteer and staff employment contracts). We also expect these purposes to form our legitimate interests and promise not to pass on your details to anyone else without your express permission; except in exceptional circumstances.
3. COLLECTION, HANDLING, SHARING, RECORDING AND RETENTION OF PERSONAL
3.1 We are fully committed in looking after your personal information and only collect personal data as is required for the purposes for which the data was provided. This shall differ depending upon whether you are an employee, a volunteer, a donor, a contractor, a service user or service recipient.
3.2 In some cases, we will only use your personal information where we have your consent or because we need to use it to fulfil a contract with you.
3.3 We would also process personal information due to legitimate interests of complying with guidance from the Charity Commission.
3.4 We have implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both automated and in paper files from; improper access, use, alteration, destruction and loss.
3.5 LIC will continue to monitor and maintain our systems, processes and procedures to ensure and assure that the personal data of data subjects, be they employees, volunteers, donors, contractors, service-users or service recipients, are kept securely and safely at all times.
3.6 In the course of LIC’s running, we may share personal data (including special category personal data where appropriate) with third parties such as Disclosure and Barring Services, Immigration, HM Revenue and Department for Work and Pensions).
3.7 We may share your data with third parties where:
(a) if we are under a legal or regulatory duty to do so,
(b) if it is necessary to do so to enforce our contractual rights,
(c) to lawfully assist the police or security services with the prevention and detection of crime or terrorist activity,
(d) where such disclosure is necessary to protect the safety or security of any persons
(e) otherwise as permitted under applicable law.
3.8 We do not transfer personal data outside of the European Economic Area or any Third countries, international organisations or other parties.
3.9 We will never sell or share your personal information with organisations, so they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity.
3.10 We take the responsibility recording personal data and the envisaged time limits for retention of the different categories of data very seriously. We only keep data as long as is reasonable and necessary to fulfill statutory obligations (for example, the collection of Gift Aid).
3.11 We also only retain personal data for as long as is reasonably required by law or best practice following the last contact with the data subject. The retention period shall differ depending upon whether the data subject is an employee, a volunteer, a contractor, a donor, a service-user or a service recipient (school visits).
3.12 We have adopted Records Retention Guidelines which set out the time period for which different categories of data are kept in conjunction with a timely data cleansing operation.
3.13 If you have any specific queries about our record retention periods, please contact the Data Protection Officer by email on ; by telephone on 0208 690 5090, by post to the Data Protection Officer, Lewisham Islamic Centre, Lewisham High Street, SE13 6NZ.
4. YOUR RIGHTS UNDER THE GDPR
4.1 LIC is aware that is incumbent upon it as a Data Controller to facilitate the exercise of your rights in respect to your personal information; in a timely manner. You have the following rights in respect to your personal data
I. The right to request from LIC a copy of your personal information as it is held by us. There is normally no charge for us doing this.
II. The right to request LIC to correct any errors in the personal information that we hold about you. We may request supplementary information to confirm that an error has been made.
III. The right to ask LIC to erase any personal data that LIC holds on you (although that right does not apply where LIC has a legal obligation to retain it).
IV. The right to ask LIC to restrict (suspend) processing of your personal data.
V. The right to object to LIC processing of your personal data under certain circumstances.
VI. The right to ask LIC to provide a copy of the personal data that were obtained from you in a portable machine-readable format and to ask us to send that copy to another data controller.
VII. Where you have given your consent, you have the right to withdraw that consent at any time. If you do this, the withdrawal of consent does not affect LIC’s legal obligation to retain certain information such as for the purpose of keeping taxation records and it does not act retrospectively.
VIII. The right to complain to a supervisory authority (regulator) regarding your personal data.
4.2 In all inclusivity, you have right to be aware of and verify the lawfulness of the processing of your personal information.To ensure your personal data is processed fairly; LIC shall provide you with a concise, transparent, intelligible and easily accessible form, with clear and plain language.
4.3 You can file a subject access requests (SARs) and obtain from LIC a copy of your personal data, together with an explanation of the categories of data being processed and the purposes of such processing.
4.4 We will aim to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits, which is one month in the case of requests for access to information.
4.5 We will be better able to respond quickly to smaller, targeted requests for personal information. If the request is manifestly excessive or similar to previous requests, we may ask you to reconsider or charge a proportionate fee, but only where GDPR allows it.
4.6 You should be aware that certain data is exempt from the right of access. This may include information which identifies other individuals, or information which is subject to legal privilege. We are also not required to disclose any confidential reference of any individual passed to us for the purpose of volunteering or employment.
4.7 In some cases, you may require LIC to correct / rectify errors or erase your personal data or request your incomplete personal data completed by means of providing a supplementary statement. Not only are we duty-bound to rectify inaccurate personal data when it becomes apparent we shall do our best to attend to your request without undue delay.
4.8 We may delete your data when it is no longer needed for its original purpose, or where the processing is based on your consent of which you withdrew, as long as there is no other lawful basis for processing. The broad principle underpinning this right is to, enable an individual to request the deletion or removal of personal data; where there is no compelling reason for its continued processing.
4.9 Nonetheless, exemptions and limitations may apply and LIC may, restrict the provision of information where it is necessary and proportionate. In certain circumstances personal data cannot be deleted because the data is required for the purposes of exercising or defending legal claims.
4.10 LIC may continue to store the data but not further process them; whilst limiting their access using passwords and other access controls. Examples of personal data in this category include Marriage, Divorce and Khula certificates.
4.11 You may withdraw consent, where given, or otherwise object to receiving generic or fundraising communications. Please be aware that we may have another lawful reason to process the personal data in question even without your consent e.g. an employment or volunteer or contractual services.
4.12 You may also wish for your personal data to be transferred to another controller if so desired without hindrance from LIC; where technically feasible.
4.13 If you would like to access or amend your personal data, or would like it to be transferred to another person or organisation, or have some other objection to how your personal data is used, please make your request in writing to the Data Protection Officer by email on ; by telephone on 0208 690 5090, by post at Data Protection Officer, Lewisham Islamic Centre, Lewisham High Street, SE13 6NZ.
5. KEEPING PERSONAL DATA ACCURATE AND UP TO DATE
5.1 LIC currently conducts regular data purge to ensure that all personal data held in relation to an individual is as up to date and accurate as possible. From time to time we sort, delete/shred any data that is no longer needed, or relevant. In the long run this will enable us to remove obsolete and out of date information thereby, reducing mistakes and saving time when, looking for a specific piece of information.
5.2 But we are unable to reach the peak of our efficiency without your intervention. Please notify the Data Protection Officer by email at ; by telephone on 0208 690 5090, by post at Data Protection Officer, Lewisham Islamic Centre, Lewisham High Street, SE13 6NZ. of any significant changes to important information, such as contact details, held by us about you.
6.1 You have the right to lodge a complaint if your legal rights have been infringed or your personal information has or is being used in a way that you believe does not comply with the GDPR. Nevertheless, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have promptly.
6.2 Kindly contact the Data Protection Officer by email at ; by telephone on 0208 690 5090, by post at Data Protection Officer, Lewisham Islamic Centre, Lewisham High Street, SE13 6NZ.
6.3 You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO), although the ICO recommends that steps are taken to resolve the matter with us before involving them. 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
7.1 LIC does not intend to process your personal information for any purposes other than those described in this privacy notice and for which you have given your consent or where LIC has a legal obligation to do so.
7.2 LIC anticipates that this notice explains how we will use the personal information that you have supplied to us and assures you that we are treating you fairly and lawfully. If you have any concerns or complaints, please do not hesitate to contact the Data Protection Officer whose details are in this Privacy Notice.
7.3 LIC will do its utmost best to get this right by not only meeting your legal requirements and adopting a whole organisation approach, but also giving you a great experience of supporting LIC.
7.4 Nothing in this document seeks to or should be taken to override any statutory rights that apply to you.
This privacy notice was last updated on 20thMay 2018.