How we use your information
- people who visit our websites and social media channels
- people who email us
- people who use our services
Under the General Data Protection Regulation individuals have the right to make a request for information, rectification, erasure, restriction, transfer, and/or object to the processing of their data. If this concerns you, please see more information about your rights and how to use them below.
People who visit our website
We use a third-party service, lcn.com, to host our website openchange.co.uk. We collect anonymous information through lcn.com as well as the third-party service wordpress.com about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. For more information about how lcn.com and WordPress processes data, please see their privacy notices.
When someone visits our website we also use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone.
People who e-mail us
Our email provider – lcn.com – uses a Secure Sockets Layer (SSL) to encrypt and protect email traffic. Messages are sent using SSL between Open Change and our email server. However, you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software.
People who use Open Change services
Open Change offers certain services to the public, such as an occasional e-newsletter. We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have signed up to our newsletter to carry out a survey to find out if they are happy with the content they receive. It will not be disclosed or shared for any other purpose. When people do subscribe to our services, they can cancel their subscription at any time and are given an easy way of doing this.
People who receive our e-newsletter
We use a third party provider, MailChimp, to deliver our occasional e-newsletters. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see MailChimp’s privacy notice.
Access to your data
Under the General Data Protection Regulation individuals have the right to make a request for information, rectification, erasure, restriction, transfer, and/or object to the processing of their data. Find out more about your rights on the Information Commissioner’s Office website.
A request for any of the above can be done verbally or in writing. In order to fulfil the request we must be able to verify your identity and may ask for further details about you and your contact with us. We will respond to a request within one calendar month of receiving it, free of charge. However, if the request is complex or there are numerous requests we may extend this deadline by a further two months and/or charge a fee, we will notify you if this is the case and explain why.
Complaints or queries
Open Change tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading, or inappropriate.
Data Protection Policy
Company means Open Change Ltd.
GDPR means the General Data Protection Regulation.
Responsible Person means Mike Press, company director.
Register of Systems means a register of all systems or contexts in which personal data is processed by the Company.
Last updated 12 November 2018
1. Data protection principles
The Company is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- 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;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- 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;
- 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
- 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.”
2. General provisions
- This policy applies to all personal data processed by the Company.
- The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- The Company shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.
- The Register of Systems shall be reviewed at least annually.
- 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.
4. Lawful purposes
- All data processed by the company 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).
- The Company shall note the appropriate lawful basis in the Register of Systems.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
- 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 Company’s systems.
5. Data minimisation
- The Company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- The Company shall take reasonable steps to ensure personal data is accurate.
- 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.
7. Archiving / removal
- To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
- The archiving policy shall consider what data should/must be retained, for how long, and why.
- The Company shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
- 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.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
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, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
END OF POLICY