YWAM HARPENDEN PRIVACY NOTICE
Please read this Privacy Notice carefully to understand our practices regarding your personal data and how we will collect, use and store your personal data. We may update this Privacy Notice from time to time so please check it regularly. If there are significant updates, we will notify you.
Last modified: 21 January 2019
At Youth with a Mission Harpenden Limited dba YWAM Harpenden and/or University of the Nations (“YWAM” or “we” or “us” or “our” or the “Organisation”), we sincerely care about privacy, security, and transparency; these fundamental elements of privacy and security play an important part in our organisation’s mission. Toward that, this Privacy Notice explains how we safeguard your personal information when you surf our website; it also clarifies your privacy privileges and how the law protects you. This privacy notice also applies to personal data you entrust to us when applying to our training centre, and when enrolling in training development.
How YWAM Collects Information
One of the purposes of this Privacy Notice is to explain how the Organisation collects and processes personal data when using our website at ywamharpenden.org, including any data provided through the website. The information may be provided through the Contact Us form or when you submit questions or feedback. This may also apply when you sign-up for newsletters, apply to attend seminars or training, and other related uses of the website.
Please be informed that this website is not intended for children, defined as age 13 and under; we absolutely do not knowingly collect data concerning children.
We encourage you to read this Privacy Notice; it has been written to ensure you understand how we collect information, how it is safeguarded, what is collected, how it is processed, with whom we may share it, and your rights under the law.
Understanding Who Controls Your Data
This Privacy Notice applies when we are acting as the Data Controller with respect to the personal data we process about you. In other words, where we determine the purpose and the means of the processing, we are identified as the Data Controller and we are responsible for controlling and safeguarding your personal data.
Toward that, we have assigned a data privacy manager to superintend all aspects of this Privacy Noticing, ensuring your questions are answered and your rights are respected. Whenever you have questions, you should contact the Data Privacy Manager by email or postal mail as follows:
Youth With a Mission Harpenden Limited, Data Privacy Manager, email@example.com
6 Highfield Oval
Harpenden AL5 4BX
How We Collect Your Data
We may collect your data through direct interaction, automation, or third parties. Here’s more information about these methodologies:
• Direct interactions. We may receive your information directly when you:
• e-mail us;
• subscribe to our service or publications;
• request marketing information to be sent to you;
• enquire about enrollment;
• submit an application;
• interview with us; or
• provide us feedback.
• Automated technologies or interactions. When you use our website or log in to our service, we may learn technical data about your computing system and browsing activity. This data is gathered by employing cookies and related tools.
• Third parties. Your personal data may be received via a third party as follows:
Via analytics through providers such as Google Analytics, which is located outside of the EU; and
From service providers, we use, including companies such as MailChimp when you request to be part of our newsletter.
Information We May Collect About You
We may collect the following information about you that makes you identifiable. We may also process, store, transfer or modify data that has been grouped together such as:
• Identity Data including first name, surname, username, and any other personal details you may send to us.
• Contact Data includes email address, geographic address, and social media data.
• Technical Data includes your internet protocol (IP) address, operation system, browser type and plug-ins, mobile platform, and other technical data regarding your computing platform.
• Usage Data includes data regarding how you use our platform, which pages you visit, and other relevant metrics about our website.
• Communication Data includes marketing data, including choice in whether or not to receive newsletters and communication from us or our third parties.
Sometimes we aggregate data such as statistical metrics or demographic information stemming from your personal data. It should be noted that statistical and demographic data is not personal data when it does not directly or indirectly reveal your identity. Only when statistical data is combined with personal data will this Privacy Notice apply.
In some instances, such as apply to one of our training offerings and complete an application, we may receive sensitive data about you, defined under the GDPR as Article 9 special categories of data. This data, if provided, may be associated with your religious or philosophical beliefs, your sexual orientation, your political opinions, your trade union membership, your race or ethnicity, or information about your health, genetic makeup and biometric markers. If you provide us this information, you do so by choice and under no compulsion whatsoever. We commit to safeguard your data and will only use it according to the purposes set forth in this Privacy Notice and according to legal limitations.
How We Process Your Data
Our Organisation will only process your data according to the allowance permitted by law. In most instances, we will only use your data in the following situations:
• When you provide us with your consent to process your personal data, which may be revoked by you at any time and for any reason;
• When it may be necessary for our legitimate interest;
• When we may need to respond to a legal requirement or regulatory action; and
• Where we need to fulfil our obligation to provide training when you enrol into one of our training programmes.
If you have any further questions about how we process your data, or if you want to revoke your consent, please contact us at firstname.lastname@example.org.
Lawful Basis for Processing
In the following table, we describe ways your personal information may be used; each of these uses are tied to a legal basis for processing. Further, we have also outlined wherever we have a legitimate interest to process your data where appropriate.
It is also possible that we may process your personal information via more than one lawful basis depending upon the purpose for which we are using it. If you have questions about the lawful basis by which we are processing your data, please contact us.
|Activity||Personal Data||Lawful Basis|
|Online training enrolment||(a) Identity
|Performance of a contract with you|
Relationship management including:
(a) Asking you for feedback;
(b) Notifying you about changes to our terms and conditions;
(c) Notifying you about changes to our Privacy Notice;
(d) Sending you communication through our newsletter.
(e) Asking you to update your contact information.
(f) Communicating with you about the service.
|(a) Performance of a contract with you;
(b) To comply with a legal obligation;
(c) For legitimate interests, such as to keep records up
dated, and to study how customers use services.
|Eligibility evaluation as a trainee or trainer.||(a) Identity
(c) Special Categories of Personal Data
|Necessary for legitimate interests such as running the Organisation and operating recruitment practices.|
|Administration and protection of the Organisation and its website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.||(a) Identity
|(a) Necessary for legitimate interests, such as running the business, provision of administration and IT services, network security, prevention of fraud and in the context of a business re-organisation or group restructuring exercise.
(b) Necessary to comply with a legal obligation.
|Delivery of relevant website content and information, and to measure or understand the effectiveness of the information we serve to you.||(a) Identity
(e) Marketing and communications
|Necessary for legitimate interests to study how trainees use services, to develop them, to grow the organisation and to inform communication strategy.|
|Employing analytics to improve the website, services, marketing, and relationships.||(a) Technical
|Necessary for legitimate interests to define types of individuals for offerings, to keep the website updated and relevant, and to develop offerings and to inform marketing strategy.|
|Submitting suggestions and recommendations about offerings that may be of interest.||(a) Identity
|Necessary for legitimate interests to develop offerings and grow reach.|
Explanation of Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at email@example.com.
Performance of Contract means processing your data where it is necessary for the performance of an agreement to which you are a party or to take steps at your request before entering into such an agreement.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
This website may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice or other relevant information of every website you visit.
Communication & Marketing
We will make every effort to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us, purchased services from us or if you provided us with your details when you subscribed to our newsletter and, in each case, you have not opted out of receiving that marketing.
We won’t share your information with any other organizations for marketing, market research or commercial purposes, and we don’t pass on your details to other websites.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transaction.
When we might change how we use your data
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process or disclose your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Transferring your data
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA including MailChimp whose servers are located in the US. MailChimp participates in and is certified under the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long we will use your data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. With respect to information you provide to us in relation to an application for a job, we may keep this information for up to twelve years to make the processes by which we evaluate and assess candidates more efficient.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to this statement
Youth With A Mission Harpenden will occasionally update this Statement of Privacy to reflect company and customer feedback. Youth With A Mission Harpenden encourages you to periodically review this statement to be informed of how Youth With A Mission Harpenden is protecting your information.
Youth With A Mission Harpenden welcomes your comments regarding this Statement of Privacy. If you believe that Youth With A Mission Harpenden has not adhered to this Statement, please contact Dale Lambert at firstname.lastname@example.org. We will use commercially reasonable efforts to promptly determine and remedy the problem. Our Data controller can be contacted on +44 (0)1582 463300