The privacy and security of your personal information is extremely important to us. This Privacy Promise explains how and why we use your personal data, to make sure you stay informed and can be confident about giving us your information.

 

Up to date

We’ll keep this promise updated to show you all the things we do with your personal data. This promise applies if you’re a supporter of the Trust ; member, donor, volunteer, customer, supporting parent/carer or legal guardian, employee, ex- employee, governor, trustee, supplier, facilities user, health, education or social care partner, placement trainee, student, pupil, child, young person. Additionally when you use any of our services, visit our website, message us on social media, email, call or write to us.  In certain circumstances we may also provide an additional privacy notice, which will always refer to this promise.

We will only provide this Privacy Promise to you once, generally at the start of our relationship with you. However if this Privacy Promise is updated substantially, then we may provide you with details of the updated version. You are encouraged to check back regularly for updates.

Collecting specific, relevant personal information is a necessary part of us being able to provide you with any services you may request from us or just managing our relationship with you.

 

You have certain rights in relation to your personal information, for example the right to be provided with the personal information held about you and details of its use and the right to have certain of your personal information either erased or anonymised, commonly referred to as the right to be forgotten.

 

We will never sell your personal data that we hold to another party and will only share it with organisations we work with when it’s necessary and the privacy and security of your data is assured.

 

When we hold or use your personal information we do so as data controller, in the majority of circumstances.

 

A data controller is a person or organisation which controls how personal information is processed and used. A data processor is a person or organisation which processes and uses personal information in accordance with the instructions of another party, i.e. the data controller.

In this promise, whenever you see the words ‘we’, ‘us’, ‘our’, ‘Seashell Trust’, it refers to the legal entity, Seashell Trust, Company Registration number 042216714

 

Seashell Trust is an education & care charity founded in 1823 in Manchester; originally for the education of deaf children.

 

Today, we offer specialist school and college services; Royal School & Royal College, Manchester, providing highly specialist education and care for over 120 severely disabled children and young people, all of whom have consequent complex learning and communication difficulties.

 

In addition, we provide specialist, registered care homes for children and young adults to ensure that their needs are met when they cannot live with their own family. Children and young people may be resident in our care homes for short periods, including short breaks, or in the longer term, with a view to moving on to adulthood and more independent living.  The homes are a place for children and young adults to develop and grow.

 

We also provide Sport services, Outreach therapy and specialist training service provision, family services, and fundraising.

 

Seashell Trust is a registered charity (Reg. Charity number 1092655) and our ICO registration number is Z1633500.

 

If you have any questions in relation to this privacy promise or how we use your personal data they should be sent to the Data Lead : Seashell Trust, Stanley Road, Cheadle Hulme, Cheshire, SK8 6RQ Tel 0161 6100100, email: data@seashelltrust.org.uk

Information which identifies you, or which can be identified as relating to you personally will be collected and used by us. We will only collect the personal data that we need.

 

The personal data you give us may include the following classifications: personal details, family details, lifestyle and social circumstances, membership details, goods and services details, financial details, education and employment details, including background checks and work place welfare.

 

Due to the nature of the services that we provide we do collect special categories of personal data in addition to other personal data. These may include: physical or mental health details, racial or ethnic origin, religious or other beliefs of a similar nature, sexual orientation, criminal history, occupational health information, dietary requirements, medical diagnosis/history, family medical details and description, behaviour details, GP details etc. We have further safeguards in place for these special categories of data.

 

We collect personal data in connection with members, staff, volunteers, trustees and governors, complainants, supporters’ enquirers, advisers and representatives of other organisations, event attendees, facilities users, vendors and suppliers, clinical and teaching work placement professionals.

Information which identifies you, or which can be identified as relating to you personally will be collected and used by us. We will only collect the personal data that we need.

 

The personal data you give us may include the following classifications: personal details, family details, lifestyle and social circumstances, membership details, goods and services details, financial details, education and employment details, including background checks and work place welfare.

 

Due to the nature of the services that we provide we do collect special categories of personal data in addition to other personal data. These may include: physical or mental health details, racial or ethnic origin, religious or other beliefs of a similar nature, sexual orientation, criminal history, occupational health information, dietary requirements, medical diagnosis/history, family medical details and description, behaviour details, GP details etc. We have further safeguards in place for these special categories of data.

 

We collect personal data in connection with members, staff, volunteers, trustees and governors, complainants, supporters’ enquirers, advisers and representatives of other organisations, event attendees, facilities users, vendors and suppliers, clinical and teaching work placement professionals.

 

Personal data provided by you

Your personal data can be provided to us in many ways, communicating with us: by phone, email or post, through our website or social media, and meetings. Additionally you may give us your personal data by completing forms, and using forms on our website and other applications when booking for events.

 

For example:

 

  • Personal details (name, date of birth, email, address, telephone, and so on) when applying for our products and services;
  • Financial information (payment information and whether donations are gift-aided);
  • Becoming a student or applying to live at Seashell Trust (or being part of a child or young person’s support network) – medical history, medical diagnosis, current prescriptions etc.

 

If you are the parent / carer / legal guardian or a member of a team around a child or young person who uses our services, or who volunteers for us, your details and your relationship with that child/ young person will also be recorded.

 

Personal data created by your involvement with us

 

Your activities and involvement with us will result in personal data being created. This could include details of how you’ve helped us by volunteering or being involved with our activities or if you have provided further medical, education, care related information for one of our children and young people etc.

 

Information we generate

 

Whilst you maintain a relationship with us we could supplement the data initially collected at the start of our relationship. For example, this may be through completion of forms, collection of additional registration details for additional services you choose to be involved in.

 

We conduct research and analysis on the information we hold, which can in turn generate personal data. For example, by analysing your interests and involvement with our work we may be able to build a profile which helps us decide which of our communications are likely to be of most interest to you.

 

Information from third parties

 

As part of the application process to join our Education, and Residential Care Services, Medical and Therapy Services we request information via you from any previous Education, Medical, Therapy and Residential Care providers and any additional information you feel would contribute to the provision of our services to you. We may seek further clarification with those parties regarding this information.

 

Sensitive personal data

At times we will collect sensitive personal data to enable us to provide our services to you and to allow us to comply with relevant employment, equal opportunities and similar legislation.

 

Online Identifiers

 

We do not currently use cookies on our website. We are not responsible for cookies on any sites that are signposted from our website.  We collect general performance statistics from our social media channels. No person specific data is collected.

 

For students and residents at Seashell Trust we also record the MAC address and IP address of their own devices when connecting to our services.

 

Staff, Volunteers, Governors and Trustees, people ‘working ‘with our Children and Young People

 

We collect extra information about you (e.g. references, criminal records checks, details of emergency contacts, medical conditions etc.). This information will be retained for legal or contractual reasons, to protect us and for safeguarding purposes.

 

Collection and use of images

 

Seashell Trust is using the lawful basis of ‘legitimate interests’ for photos including people, with the exception of:

 

  • Photographs / filming for identification and security purposes, health and safety purposes and learning, teaching, service assessment purposes. In these circumstances the lawful basis is ‘for the performance of contract’
  • Where people will be named or quoted in the photographs / film and it is not part of their contract with us. In this circumstance the lawful basis is ‘consent’. We only ask for consent where other lawful basis are not applicable, and do so considering the additional requirements of current Mental Capacity Legislation.

 

Handling your payment card information

 

Where we collect this sensitive information over the internet, or when using hand held card processing terminals we us partner services that encrypt the data sent. Seashell Trust uses external Payment Card Industry (PCI) compliant providers to collect this data on our behalf. We do not hold any PCI data on our systems.

To make sure that we always have the most up to date information about you, we may from time to time request that you confirm your personal details in the records that we hold.

 

How long will we keep your personal information?

 

We will not retain any information for longer than is necessary in relation to the purposes for which it was originally collected, or for which it was further processed, subject to all relevant legal obligations of the Trust for example the collection of Gift Aid or to support certain financial transactions. We retain personal data in accordance with our data retention schedules.

We store the majority of your data on our own servers. This is held in line with our Information Security and Data Protection policies.

 

Where we work with service providers to process and hold your data for us we will ensure this is defined in a contract/sharing agreement and we will take reasonable steps to make sure that your data is treated securely in accordance with this privacy promise. We will endeavour to protect your personal data and ensure that it will be held in compliance with European data protection regulations.

 

The personal information collected from you may be transferred to, and stored at a destination outside of the European Economic Area (EEA). By submitting your personal data, you agree to this transfer, storing and processing outside of the EEA. Where in-country accreditation certificates are available for Data Protection and Information Security we will seek to use the companies holding these certifications.

 

In cases where we use external websites provided by other organisations e.g. Twitter, Facebook, Blue Octopus, Kinetic then we would ask that you consult their privacy policies.

We have the right to disclose your identity to any third party claiming to own any content that you post or send

 

If we believe that any content sent or posted by you is inappropriate or the content is in breach of any laws, (e.g. potentially defamatory content), we may use your personal information to inform relevant third parties, such as Internet Service Providers, or law enforcement agencies).

When we use an external service provider to process data on our behalf, we disclose only the personal information that is necessary to deliver the service and will have a contract in place that requires the provider to comply with Seashell Trust and GDPR data protection and information security requirements.

 

We may disclose your personal information to third parties if we are legally obliged to; or other agreements; or to protect the rights, property, or safety of the Seashell Trust and persons associated with the Trust.

 

Additionally we share details with various other parties:

 

Whilst you are living at Seashell Trust: Local and Central Government, Ofsted, Public Health, CQC, Activity providers, Department of Health, Health and Safety Executive, NHS services, and multi teams around a young person, safeguarding boards, Seashell Trust staff and representatives.

 

Whilst you are learning at Seashell Trust:  Department for Education, Public Health, Health and Safety Executive, Department of Health, Ofsted, NHS Services, exam accreditation boards, multi-disciplinary teams around a  child or young person, activity providers, our governors, technology learning solution providers, safeguarding boards, Seashell Trust staff and representatives, professional services consultants, regulatory body inspectors.

 

Whilst you are working at Seashell Trust: Ofsted, HMRC, Public Health,  Health and Safety Executive ( HSE) Local Authorities, Department for Work and Pensions, Payroll services, Financial Audit services, Staff benefit package providers, Learning and development providers, accreditation providers, activity providers, Health and Safety, background check and reference service providers, Legal Services,  Law Enforcement bodies, Trade union –where you are a member, Safeguarding boards, our Trustees, Seashell Trust staff and representatives, work experience establishments, current, past and prospective employers, parents and prospective parents, Professional Services consultants, regulatory body inspectors.

 

Whilst you are volunteering at Seashell Trust: Volunteer portal provider, Public Health,  background check and reference providers, Seashell Trust staff and representatives, law enforcement bodies, regulatory body inspectors, Health and Safety Executive.

 

Whilst you are supporting us at Seashell Trust: HMRC – Gift Aid,  shared with our authorised users, helping at events where applicable, event partners, Trust fund providers where applications are made, offsite location providers for Health and Safety purposes, Fundraising Regulators, Health and Safety Executive, Seashell Trust staff and representatives

 

Whilst you are using Seashell Trust sports and community services: Seashell Trust staff and representatives, Public Health, NHS Services, activity providers, background check and reference providers, , law enforcement bodies, regulatory body inspectors, partnership activity providers, safeguarding boards, Health and Safety Executive, Software providers, multi teams around a child or young person

 

Whilst you are using Seashell Trust Outreach services: Seashell Trust staff and representatives, Public Health, Service Commissioners, Local Authority MDT teams where commissioned by a Local Authority, Health and Safety Executive, Safeguarding Boards, NHS Services, activity providers, learning and development providers, accreditation providers, offsite location providers for Health and Safety purposes.

If you wish to exercise any of your rights as listed below please write to us via the data@seashelltrust.org.uk email address, or to the Data Lead at our postal address on the website:

 

  • Access your personal data – ask for a copy of your personal data at any time
  • Ask us to correct, delete or update your personal information
  • Ask to send your personal information to you or another organisation
  • To object to automated decision making
  • To restrict processing if this is contested or unlawful

 

Any request that you make will be considered in accordance with all applicable data protection laws and regulations. No administration charge will be made for considering or complying with a request, unless it is deemed to be excessive in nature.

 

Once verification of identity and entitlement to obtain or exercise the rights has been completed by us, we will complete the request to timescale.

We reserve the right to make changes to the privacy policy. We recommend that each time you access the website you check the policy to review sections that are important to you. Where significant changes are made we will notify you by email.

If you have any questions and concerns about this policy and our practices, or if you wish to file a complaint, please contact our Data Lead via data@seashelltrust.org.uk or calling 0161 610 0100. Or in writing to: Data Lead, Seashell Trust, Stanley Road, Cheadle Hulme SK8 6RQ.

 

You also have the right to lodge a complaint with the Information Commissioners Office (ICO) if you believe your data has been processed in a way that does not comply with existing data protection legislation. You can do so by calling the ICO helpline on 0303 123 1113 or via their website https://ico.org.uk. However we are here to help and would encourage you to contact us to resolve your complaint first.

If you want to find out more information, please contact us today

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