Customer's personal details and how we use them

We 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, geographical
location, browser type and version, operating system, referral source,
length of visit, page views and website navigation paths, as well as
information about the timing, frequency and pattern of your service use.
The source of the usage data is our analytics tracking system. This usage
data may be processed for the purposes of analysing the use of the website
and 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 data
may include your name and email address. The source of the account data is
you. The account data may be processed for the purposes of operating our
website, providing our services, ensuring the security of our website and
services, maintaining back-ups of our databases and communicating with
you. The legal basis for this processing is consent OR the performance of a
contract between you and us and/or taking steps, at your request, to enter
into such a contract.

3.4 We may process your information included in your personal profile on
our website ("profile or personal data"). The profile data may include your
name, address, telephone number, email address, profile pictures, gender,
date of birth, and social media ids. The profile data may be processed for
the purposes of enabling and monitoring your use of our website and
services. The legal basis for this processing is consent OR the performance of
a contract between you and us and/or taking steps, at you request, to enter
into such a contract.

3.5 We may process [your personal data that are provided in the course of
the use of our services] ("service data"). The service data may include
information you have provided to apply for an advertised job, to add a job
to the database of PA roles, or to add your details to the database of
Personal Assistants looking for work. The source of the service data is you.
The service data may be processed [for the purposes of operating our
website, providing our services, ensuring the security of our website and
services, maintaining back-ups of our databases and communicating with
you]. The legal basis for this processing is consent OR the performance of a
contract between you and us and/or taking steps, at your request, to enter
into such a contract.

3.6 We may process information that you post for publication on our
website or through our services ("publication data"). The publication data
may be processed for the purposes of enabling such publication and
administering our website and services. The legal basis for this processing is
consent OR the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract.

3.7 We may process information contained in any enquiry you submit to us
regarding products and/or services ("enquiry data"). The enquiry data may
be processed for the purposes of offering, marketing and selling relevant
products and/or services to you. The legal basis for this processing is
consent.

3.8 We may process information relating to transactions, including
donations or purchases of goods and services that you enter into with us
and/or through our website ("transaction data"). The transaction data may
include your contact details, your card details and the transaction details.
The transaction data may be processed [for the purpose of supplying the
purchased goods and services and keeping proper records of those
transactions]. The legal basis for this processing is the performance of a
contract between you and us and/or taking steps, at your request, to enter
into such a contract and our legitimate interests, namely our interest in the
proper administration of our website and business.

3.9 We may process information that you provide to us for the purpose of
subscribing to our email notifications and/or newsletters ("notification
data"). The notification data may be processed for the purposes of sending
you the relevant notifications and/or newsletters. The legal basis for this
processing is consent.

3.10 We may process information contained in or relating to any
communication that you send to us ("correspondence data"). The
correspondence data may include the communication content and metadata
associated with the communication. Our website will generate the metadata
associated with communications made using the website contact forms. The
correspondence data may be processed for the purposes of communicating
with you and record-keeping. The legal basis for this processing is our
legitimate interests, namely the proper administration of our website and
business and communications with users.

3.11 We may process any of your personal data identified in the other
provisions of this policy where necessary for the establishment, exercise or
defense of legal claims, whether in court proceedings or in an administrative
or out-of-court procedure. The legal basis for this processing is our
legitimate 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 your
personal data set out in this Section 3, we may also process any of your
personal data where such processing is necessary for compliance with a legal
obligation to which we are subject, or] in order to protect your vital
interests or the vital interests of another natural person.

3.13 Please do not supply any other person's personal data to us, unless we
prompt 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 of
companies (this means our subsidiaries, our ultimate holding company and
all its subsidiaries) insofar as reasonably necessary for the purposes set out
in this policy.

4.2 We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining and
maintaining insurance coverage, managing risks, obtaining professional
advice and managing legal disputes or to the purchaser (or prospective
purchaser) of any business or asset that we are (or are contemplating)
selling.

4.3 We may disclose usage and service personal data to our website
suppliers Raising IT insofar as reasonably necessary for the website service
to be functional.

4.4 Financial transactions relating to our website and services are OR may
be handled by our payment services providers, [PayPal, Stripe]. We will
share transaction data with our payment services providers only to the
extent necessary for the purposes of processing your payments, refunding
such payments and dealing with complaints and queries relating to such
payments and refunds. You can find information about the payment services
providers' 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) to
enable us and them to carry out analysis and research on demographics,
interests and behaviour of our users and supporters to help us gain a better
understanding of them to enable us to improve our services.

This may include connecting data we receive from you on the website to data
available from other sources. Your personally identifiable data will only be
used where it is necessary for the analysis required, and where your
interests for privacy are not deemed to outweigh their legitimate interests
in 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 provider
2. The data that may be available to them include any of the data we
collect 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 this
privacy policy.

4.6 In addition to the specific disclosures of personal data set out in this
Section 4, we may also disclose your personal data where such disclosure is
necessary for compliance with a legal obligation to which we are subject, or
in order to protect your vital interests or the vital interests of another
natural 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 obligations
in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be
kept 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 of
which period it will be deleted from our systems.

5.4 Notwithstanding the other provisions of this Section 5, we may retain
your personal data where such retention is necessary for compliance with a
legal obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another natural person.

6. Amendments

6.1 We may update this policy from time to time by publishing a new
version on our website and will clearly indicate when this policy was last
updated.

6.2 You should check this page occasionally to ensure you are happy with
any 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 we
hold 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 2018
after 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 solicitor
or 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 extent
permitted by law.

7.3 You may instruct us at any time not to process your personal
information for marketing purposes.

7.4 In practice, you will usually either expressly agree in advance to our
use of your personal information for marketing purposes, or we will provide
you with an opportunity to opt out of the use of your personal information
for marketing purposes.

8. Third party websites

8.1 Our website includes hyperlinks to, and details of, third party
websites.

8.2 This privacy policy only governs our websites and we are not
responsible for the privacy policies that govern third party websites even
where we have provided links to them. If you use any link on our website
we recommend you read the privacy policy of that website before sharing
any 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 use
any data collected from those pages it does not cover how the providers of
social media websites will use your information. Please ensure you read the
privacy policy of the social media website before sharing data and make use
of the privacy settings and reporting mechanisms to control how your data is
used.

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 person
under 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 you
needs 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 and
numbers) that is sent by a web server to a web browser and is stored by the
browser. The identifier is then sent back to the server each time the
browser requests a page from the server.

12.2 Cookies may be either "persistent" cookies or "session" cookies: a
persistent cookie will be stored by a web browser and will remain valid until
its set expiry date, unless deleted by the user before the expiry date; a
session 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 personally
identifies a user, but personal information that we store about you may be
linked 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 our
website and as you navigate our website

(b) status - we use cookies to help us to determine if you are logged into
our website

(c) personalisation - we use cookies to store information about your
preferences and to personalise the website for you

(d) security - we use cookies as an element of the security measures used
to protect user accounts, including preventing fraudulent use of login
credentials, and to protect our website and services generally

(e) analysis - we use cookies to help us to analyse the use and
performance of our website and services

(f) cookie consent - we use cookies to store your preferences in relation to
the use of cookies more generally

Please contact us if you require any more information on the types of
cookies used.

14. Cookies used by our service providers

14.1 Our service providers use cookies and those cookies may be stored on
your computer when you visit our website.

14.2 We use Google Analytics to analyse the use of our website. Google
Analytics gathers information about website use by means of cookies. The
information gathered relating to our website is used to create reports about
the use of our website. Google's privacy policy is available at:
https://www.google.com/policies/privacy/.

15. 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 a
website platform licensed from Raising IT.

16.2 We are registered in England and Wales under registration number
Charity No: 1153815 Registration in England No: 8654797 Independent Lives
(Disability)and our registered office is at 11 Southfield House, Liverpool
Gardens, Worthing, West Sussex BN11 1RY, UK.

16.3 Our principal place of business is at 11 Southfield House, Liverpool
Gardens, 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]

17. Data protection officer

17.1  Our data protection officer's contact details are: Michael Barford, [email protected]

18. 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

19. Complaints

19.1 If you have a complaint about our organisation please refer to the
complaints leaflet for guidance on how to raise a complaint.

19.2 If you have a complaint about us, or the treatment of your data, you
can contact the Charity Commission. The Charity Commission is the
independent watchdog for charities. You can make a complaint about a
charity on their website at www.charity-commission.gov.uk.

19.3 If you've got a complaint about our fundraising activities you can also
complain to the Fundraising Standards Board (FRSB). To find out whether a
charity is an FRSB member and how to go about making a complaint, go to
the FSRB public website at www.givewithconfidence.org.uk.