Privacy and Cookie Policy Customer's personal details and how we use themWe work closely with customers, families, members, advocates and other agencies, such as the NHS and social services. Please read our How We Use Your Information leaflet for further information. This Privacy and Cookie Policy covers how we record and use your personal data that you have provided via this website. Please also read our Customer Confidentiality Policy which covers how we treat and record customer personal data relating to our services. We also have a Independent Lives Recruitment Privacy Notice which explains how we use your personal data for recruitment purposes. 1. Introduction 1.1 We are committed to safeguarding the privacy of our website visitors in this policy we explain how we will handle your personal data. 1.2 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. 1.3 This privacy policy was last updated on 10 March 2020 2. Credit 2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com). 3. How we use your personal data gathered on this website 3.1 In this Section 3 we have set out: (a) the general categories of personal data that we may process; (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data (c) the purposes for which we may process personal data; and (d) the legal bases of the processing. 3.2 We may process data about your use of our website and services("usage data"). The usage data may include your IP address, geographicallocation, browser type and version, operating system, referral source,length of visit, page views and website navigation paths, as well asinformation about the timing, frequency and pattern of your service use.The source of the usage data is our analytics tracking system. This usagedata may be processed for the purposes of analysing the use of the websiteand services. The legal basis for this processing is our legitimate interests,namely monitoring and improving our website and services. 3.3 We may process your account data ("account data"). The account datamay include your name and email address. The source of the account data isyou. The account data may be processed for the purposes of operating ourwebsite, providing our services, ensuring the security of our website andservices, maintaining back-ups of our databases and communicating withyou. The legal basis for this processing is consent OR the performance of acontract between you and us and/or taking steps, at your request, to enterinto such a contract. 3.4 We may process your information included in your personal profile onour website ("profile or personal data"). The profile data may include yourname, address, telephone number, email address, profile pictures, gender,date of birth, and social media ids. The profile data may be processed forthe purposes of enabling and monitoring your use of our website andservices. The legal basis for this processing is consent OR the performance ofa contract between you and us and/or taking steps, at you request, to enterinto such a contract. 3.5 We may process [your personal data that are provided in the course ofthe use of our services] ("service data"). The service data may includeinformation you have provided to apply for an advertised job, to add a jobto the database of PA roles, or to add your details to the database ofPersonal Assistants looking for work. The source of the service data is you.The service data may be processed [for the purposes of operating ourwebsite, providing our services, ensuring the security of our website andservices, maintaining back-ups of our databases and communicating withyou]. The legal basis for this processing is consent OR the performance of acontract between you and us and/or taking steps, at your request, to enterinto such a contract. 3.6 We may process information that you post for publication on ourwebsite or through our services ("publication data"). The publication datamay be processed for the purposes of enabling such publication andadministering our website and services. The legal basis for this processing isconsent OR the performance of a contract between you and us and/or takingsteps, at your request, to enter into such a contract. 3.7 We may process information contained in any enquiry you submit to usregarding products and/or services ("enquiry data"). The enquiry data maybe processed for the purposes of offering, marketing and selling relevantproducts and/or services to you. The legal basis for this processing isconsent. 3.8 We may process information relating to transactions, includingdonations or purchases of goods and services that you enter into with usand/or through our website ("transaction data"). The transaction data mayinclude your contact details, your card details and the transaction details.The transaction data may be processed [for the purpose of supplying thepurchased goods and services and keeping proper records of thosetransactions]. The legal basis for this processing is the performance of acontract between you and us and/or taking steps, at your request, to enterinto such a contract and our legitimate interests, namely our interest in theproper administration of our website and business. 3.9 We may process information that you provide to us for the purpose ofsubscribing to our email notifications and/or newsletters ("notificationdata"). The notification data may be processed for the purposes of sendingyou the relevant notifications and/or newsletters. The legal basis for thisprocessing is consent. 3.10 We may process information contained in or relating to anycommunication that you send to us ("correspondence data"). Thecorrespondence data may include the communication content and metadataassociated with the communication. Our website will generate the metadataassociated with communications made using the website contact forms. Thecorrespondence data may be processed for the purposes of communicatingwith you and record-keeping. The legal basis for this processing is ourlegitimate interests, namely the proper administration of our website andbusiness and communications with users. 3.11 We may process any of your personal data identified in the otherprovisions of this policy where necessary for the establishment, exercise ordefense of legal claims, whether in court proceedings or in an administrativeor out-of-court procedure. The legal basis for this processing is ourlegitimate interests, namely the protection and assertion of our legal rights,your legal rights and the legal rights of others. 3.12 In addition to the specific purposes for which we may process yourpersonal data set out in this Section 3, we may also process any of yourpersonal data where such processing is necessary for compliance with a legalobligation to which we are subject, or] in order to protect your vitalinterests or the vital interests of another natural person. 3.13 Please do not supply any other person's personal data to us, unless weprompt you to do so. 4. Providing your personal data to others 4.1 We may disclose your personal data to any member of our group ofcompanies (this means our subsidiaries, our ultimate holding company andall its subsidiaries) insofar as reasonably necessary for the purposes set outin this policy. 4.2 We may disclose your personal data to our insurers and/or professionaladvisers insofar as reasonably necessary for the purposes of obtaining andmaintaining insurance coverage, managing risks, obtaining professionaladvice and managing legal disputes or to the purchaser (or prospectivepurchaser) of any business or asset that we are (or are contemplating)selling. 4.3 We may disclose usage and service personal data to our websitesuppliers Raising IT insofar as reasonably necessary for the website serviceto be functional. 4.4 Financial transactions relating to our website and services are OR maybe handled by our payment services providers, [PayPal, Stripe]. We willshare transaction data with our payment services providers only to theextent necessary for the purposes of processing your payments, refundingsuch payments and dealing with complaints and queries relating to suchpayments and refunds. You can find information about the payment servicesproviders' privacy policies and practices at: - Stripe (URL https://stripe.com/gb/privacy) - GoCardless (URL https://gocardless.com/legal/privacy/) - Paypal (URL https://www.paypal.com/ie/webapps/mpp/ua/privacy-full) 4.5 Your data may also be available to our website provider (Raising IT) toenable us and them to carry out analysis and research on demographics,interests and behaviour of our users and supporters to help us gain a betterunderstanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to dataavailable from other sources. Your personally identifiable data will only beused where it is necessary for the analysis required, and where yourinterests for privacy are not deemed to outweigh their legitimate interestsin developing new services for us. In the case of this activity the follow will apply:1. Your data will be made available to our website provider2. The data that may be available to them include any of the data wecollect as described in section 3 above.3. Our website provider will not transfer your data to any other third party,or transfer your data outside of the EEA.4. They will store your data for maximum of [7] years.5. This processing does not affect your rights under sections 10 or 16 of thisprivacy policy. 4.6 In addition to the specific disclosures of personal data set out in thisSection 4, we may also disclose your personal data where such disclosure isnecessary for compliance with a legal obligation to which we are subject, orin order to protect your vital interests or the vital interests of anothernatural person. 5. Retaining and deleting personal data 5.1 This Section 5 sets out our data retention policies and procedure,which are designed to help ensure that we comply with our legal obligationsin relation to the retention and deletion of personal data. 5.2 Personal data that we process for any purpose or purposes shall not bekept for longer than is necessary for that purpose or those purposes. 5.3 We will retain and delete your personal data as follows: (a) [personal data category] will be retained for 7 years at the end ofwhich period it will be deleted from our systems. 5.4 Notwithstanding the other provisions of this Section 5, we may retainyour personal data where such retention is necessary for compliance with alegal obligation to which we are subject, or in order to protect your vitalinterests or the vital interests of another natural person. 6. Amendments 6.1 We may update this policy from time to time by publishing a newversion on our website and will clearly indicate when this policy was lastupdated. 6.2 You should check this page occasionally to ensure you are happy withany changes to this policy. 6.3 We may notify you of changes to this policy by email or post. 7. Your rights 7.1 You may instruct us to provide you with any personal information wehold about you; provision of such information will be subject to: (a) the payment of a fee (currently fixed at GBP 10) if before 28 May 2018after which no fee will apply; and (b) the supply of appropriate evidence of your identity (for this purpose,we will usually accept a photocopy of your passport certified by a solicitoror bank plus an original copy of a utility bill showing your current address). 7.2 We may withhold personal information that you request to the extentpermitted by law. 7.3 You may instruct us at any time not to process your personalinformation for marketing purposes. 7.4 In practice, you will usually either expressly agree in advance to ouruse of your personal information for marketing purposes, or we will provideyou with an opportunity to opt out of the use of your personal informationfor marketing purposes. 8. Third party websites 8.1 Our website includes hyperlinks to, and details of, third partywebsites. 8.2 This privacy policy only governs our websites and we are notresponsible for the privacy policies that govern third party websites evenwhere we have provided links to them. If you use any link on our websitewe recommend you read the privacy policy of that website before sharingany personal or financial data. 8.3 We operate a number of social media pages including Facebook,Twitter, LinkedIn, You Tube). Although this policy covers how we will useany data collected from those pages it does not cover how the providers ofsocial media websites will use your information. Please ensure you read theprivacy policy of the social media website before sharing data and make useof the privacy settings and reporting mechanisms to control how your data isused. 9. Personal data of children 9.1 Our website and services are targeted at persons over the age of 18. 9.2 If we have reason to believe that we hold personal data of a personunder that age in our databases, we will delete that personal data. 10. Updating information 10.1 Please let us know if the personal information that we hold about youneeds to be corrected or updated. 11. Acting as a controller 11.1 We are registered as Data Controllers with the Information Controller’s Office (ICO), and you can find our details here: Independent Lives (Disability) https://ico.org.uk/ESDWebPages/Entry/ZA021854 Independent Lives (Trading) Limited https://ico.org.uk/ESDWebPages/Entry/ZA064111 12. About cookies 12.1 A cookie is a file containing an identifier (a string of letters andnumbers) that is sent by a web server to a web browser and is stored by thebrowser. The identifier is then sent back to the server each time thebrowser requests a page from the server. 12.2 Cookies may be either "persistent" cookies or "session" cookies: apersistent cookie will be stored by a web browser and will remain valid untilits set expiry date, unless deleted by the user before the expiry date; asession cookie, on the other hand, will expire at the end of the user session,when the web browser is closed. 12.3 Cookies do not typically contain any information that personallyidentifies a user, but personal information that we store about you may belinked to the information stored in and obtained from cookies. 13. Cookies that we use 13.1 We use cookies for the following purposes: (a) authentication - we use cookies [to identify you when you visit ourwebsite and as you navigate our website (b) status - we use cookies to help us to determine if you are logged intoour website (c) personalisation - we use cookies to store information about yourpreferences and to personalise the website for you (d) security - we use cookies as an element of the security measures usedto protect user accounts, including preventing fraudulent use of logincredentials, and to protect our website and services generally (e) analysis - we use cookies to help us to analyse the use andperformance of our website and services (f) cookie consent - we use cookies to store your preferences in relation tothe use of cookies more generally Please contact us if you require any more information on the types ofcookies used. 14. Cookies used by our service providers 14.1 Our service providers use cookies and those cookies may be stored onyour computer when you visit our website. 14.2 We use Google Analytics to analyse the use of our website. GoogleAnalytics gathers information about website use by means of cookies. Theinformation gathered relating to our website is used to create reports aboutthe use of our website. Google's privacy policy is available at:https://www.google.com/policies/privacy/. Managing cookies 15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links: (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome); (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera); (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer); (e) https://support.apple.com/kb/PH21411 (Safari); and (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge). 15.2 Blocking all cookies will have a negative impact upon the usability of many websites. 15.3 If you block cookies, you will not be able to use all the features on our website. 16. Our details 16.1 This website is owned and operated by Independent Lives using awebsite platform licensed from Raising IT. 16.2 We are registered in England and Wales under registration numberCharity No: 1153815 Registration in England No: 8654797 Independent Lives(Disability)and our registered office is at 11 Southfield House, LiverpoolGardens, Worthing, West Sussex BN11 1RY, UK. 16.3 Our principal place of business is at 11 Southfield House, LiverpoolGardens, Worthing, West Sussex BN11 1RY, UK. 16.4 You can contact us: (a) by post, using the postal address given above; (b) using our website contact form; (c) by telephone, on 01903 219 482 (d) by email, using [email protected] Data protection officer 17.1 Our data protection officer's contact details are: Katherine Wynne, [email protected] Data protection registration 18.1 We are registered as a data controller with the UK Information Commissioner's Office. 18.2 Our data protection registration number is: Independent Lives (Disability) - https://ico.org.uk/ESDWebPages/Entry/ZA021854 Independent Lives (Trading) Limited - https://ico.org.uk/ESDWebPages/Entry/ZA064111 Complaints 19.1 If you have a complaint about our organisation please refer to thecomplaints leaflet for guidance on how to raise a complaint. 19.2 If you have a complaint about us, or the treatment of your data, youcan contact the Charity Commission. The Charity Commission is theindependent watchdog for charities. You can make a complaint about acharity on their website at www.charity-commission.gov.uk. 19.3 If you've got a complaint about our fundraising activities you can alsocomplain to the Fundraising Standards Board (FRSB). To find out whether acharity is an FRSB member and how to go about making a complaint, go tothe FSRB public website at www.givewithconfidence.org.uk.