You can download and print a copy of this Privacy Notice HERE.
1. Privacy Notice
1.1. At the Apuldram Centre we, as the Data Controller, are committed to
safeguarding and preserving your privacy and personal data. This notice
explains what happens to any personal data that you provide to us and has
been updated to comply with the new legislation called the General Data
Protection Regulation (GDPR) which came into effect on 25th May 2018. We
do update this notice from time to time so please do review this notice
regularly.
​
2. Website
2.1. When someone visits our website we use a third party service, Google
Analytics, to collect standard internet 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 and the IP address information is
anonymised.
2.2. In visiting our website, we may collect and process the following data about
you:
2.3. Information provided voluntarily by you. For example, when you register for
our newsletter
2.4. Information that you provide when you communicate with us by any means.
​
3. Cookies
3.1. Cookies provide information regarding the computer used by a visitor. We
may use cookies where appropriate to assist us in improving our website.
Cookies are small text files that are placed on your computer by websites that
you visit. They are widely used in order to make websites work, or work more
efficiently, as well as to provide information to the owners of the site.
3.2. You can adjust the settings on your computer to decline any cookies if you
wish. This can be done within the “settings” section on your computer.
​
4. Third Party Links
4.1. On occasion we include links to third parties on our website. Where we
provide a link it does not mean that we endorse or approve that site’s policy
towards visitor privacy. You should review their privacy notice before sending
them any personal data.
​
5. Newsletters
5.1. We use a third-party provider, Mailchimp, to deliver our e-newsletters. We
gather statistics around email opening and clicks using industry standard
technologies to help us monitor and improve our e-newsletter.
​
6. Social media
6.1. We use a third-party provider, Hootsuite to manage our social media
interactions.
6.2. If you send us a private or direct message via social media the message will
be stored by Hootsuite for 6 months. It will not be shared with any other
organisations.
​
7. Email
7.1. All incoming and outgoing emails are stored on our Microsoft Office 365
hosted service.
7.2. We monitor any emails sent to us, including file attachments, for viruses or
malicious software. Please be aware that you have a responsibility to ensure
that any email you send is within the bounds of the law.
​
8. CCTV
8.1. We use CCTV across the Day Centre site of the Apuldram Centre. The
CCTV data is only used for security and safety purposes. The images
captured by the CCTV system will be retained for a maximum of 30 days,
except where the image identifies an issue and is retained specifically in the
context of an investigation/prosecution of that issue.
​
9. 100 Club
9.1. Members of our 100 Club monthly draw have their contact and bank details
stored securely, so that we can contact them if they win a prize and to make
the payment of that prize to their bank accounts.
​
10. Contract Gardening
10.1. Customers of our contract gardening service have their contact details
stored securely, so that we can perform the gardening service, contact them
if necessary if arrangements need to change and for invoicing them for the
service.
​
11. Complaint and Enquiry Processes
11.1. When we receive a complaint from a person, we make up a file
containing the details of the complaint. This normally contains the identity of
the complainant and any other individuals involved in the complaint. We will
only use the personal information we collect to process the complaint.4
11.2. We usually must disclose the complainant’s identity to whoever the
complaint is about. This is inevitable where, for example, the accuracy of a
person’s record is in dispute. If a complainant doesn’t want information
identifying him or her to be disclosed, we will try to respect that. However, it
may not be possible to handle a complaint on an anonymous basis.
11.3. We will keep personal information contained in complaint files in line
with our retention policy. This means that information relating to a complaint
will be retained for either two years from closure, or, if appropriate, two years
after the person has left our care and support provision. It will be retained in a
secure environment and access to it will be restricted.
11.4. Similarly, where enquiries are submitted to us we will only use the
information supplied to us to deal with the enquiry and any subsequent
issues and to check on the level of service we provide.
11.5. If you want to make a complaint about the way we have processed
your personal information, you can contact the Information Commissioner’s
Office (ICO), the organisation which oversees data protection law,
at https://ico.org.uk/concerns
​
12. Recruitment Process
12.1. All the information you provide during the process will only be used for
the purpose of progressing your application, or to fulfil legal or regulatory
requirements if necessary.
12.2. We will use the contact details you provide to us to contact you to
progress your application. We will use the other information you provide to
assess your suitability for the role you have applied for.
​
13. Application Stage
13.1. We will ask you for your personal details including name and contact
details. We will also ask you about your employment history, your education
and training, your driving licence details, your referees, a criminal records
declaration to declare any unspent convictions and your right to work in the
UK.
​
14. Assessments
14.1. We might ask you to participate in assessment days; complete tests or
occupational personality profile questionnaires; and/or to attend an interview
– or a combination of these. Information will be generated by you and by us.
For example, you might complete a written test or we might take interview
notes. This information is held by the Apuldram Centre.
​
15. Conditional Offer
15.1. If we make a conditional offer of employment we will ask you for
information so that we can carry out pre-employment checks. You must
successfully complete pre-employment checks to progress to a final offer. We
are required to confirm the identity of our staff, their right to work in the United
Kingdom and seek assurance as to their trustworthiness, integrity and
reliability.
15.2. You will therefore be required to provide:
• Proof of your identity – you will be asked to attend our office with
original documents, we will take copies
• Proof of your qualifications – you will be asked to attend our office with
original documents, we will take copies
• We use a third party provider, ARC, to complete an application for an
enhanced disclosure check on yourself using the Disclosure and
Barring Service, which will also verify your declaration of unspent
convictions
• We will contact your referees, using the details you provide in your
application, to obtain your references.
15.3. If we make a final offer, we will also ask you for the following:
• Bank details - to process salary payments
• General Practitioner’s details - in case we need to contact them
• Emergency contact details - so we know who to contact in case you
have an emergency at work.
​
16. Recruitment Decision
16.1. Final recruitment decisions are made by the hiring managers. All of the
information gathered during the application process is taken into account.
16.2. You can ask about decisions made about your application by
contacting the hiring manager.
16.3. If you are unsuccessful for the position you have applied for, we may
ask if you would like your details to be retained in our talent pool for a period
of six months. If you say yes, we may proactively contact you should any
further suitable vacancies arise.
​
17. Information Retention Period
17.1. If you are successful, the information you provide during the application
process will be retained by us as part of your employee file for the duration of
your employment plus 6 years following the end of your employment. This
includes your criminal records declaration, fitness to work, records of any
security checks and references.
17.2. If you are unsuccessful at any stage of the process, the information you
have provided and any information generated throughout the assessment
process, for example interview notes, will be retained for 6 months from the
closure of the campaign.
​
18. Payroll and Pension Services
18.1. If you are employed by the Apuldram Centre, relevant details about you
will be provided to HJS who provide payroll and pension services to the
Apuldram Centre. This will include your name, bank details, address, date of
birth, National Insurance Number and salary.
18.2. You will be auto enrolled into the NEST stakeholder pension scheme if
you meet the qualifying criteria.
​
19. Recruitment Services
19.1. For some vacancies, we may advertise through a third party
recruitment agency. They will collect the application information and might
ask you to complete a work preference questionnaire which is used to assess
your suitability for the role you have applied for, the results of which are
assessed by recruiters. Information collected by them will be retained in line
with their retention periods.
​
20. Data Processors
20.1. Data processors are third parties who provide elements of our service
for us. We have contracts in place with our Data Processors, which means
that they cannot do anything with your personal information unless we have
instructed them to do it. They will not share your personal information with
any organisation apart from us. They will hold it securely and retain it for the
period we instruct.
​
21. Your Rights
21.1. Under the General Data Protection Regulations you have rights as an
individual which you can exercise in relation to the information we hold about
you.
21.2. You can read more about these rights here:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-
gdpr/individual-rights/
​
22. Access to Personal Information
22.1. The Apuldram Centre tries to be as open as it can be in terms of giving
people access to their personal information. Individuals can find out if we hold
any personal information by making a ‘subject access request’ under the
Data Protection Act 1998. If we do hold information about you we will:
• give you a description of it
• tell you why we are holding it
• tell you who it could be disclosed to
• let you have a copy of the information in an intelligible form.7
22.2. To make a request to the Apuldram Centre for any personal
information we may hold you need to put the request in writing addressing it
to our Data Protection Officer using the address provided below. We may
charge a small administration fee to process this request.
22.3. If you agree, we will try to deal with your request informally, for
example by providing you with the specific information you need over the
telephone.
22.4. If we do hold information about you, you can ask us to correct any
mistakes by contacting the Data Protection Officer.
​
23. Disclosure of Personal Information
23.1. In many circumstances we will not disclose personal data without your
consent, however, when we investigate a complaint or a safeguarding
concern, for example, we may need to share personal information with the
person concerned.
23.2. Where it is legally required or necessary, we may share your personal
data with:
• West Sussex County Council – to meet contractual and
safeguarding requirements
• Our regulator CQC – to allow them to undertake their inspection
work
• Our auditors – as required as part of their audit processes
• Police forces, courts, reconciliation services, tribunals – to assist in
their work
• The DBS – in respect of our safeguarding responsibilities
• Suppliers, designated professionals, and service providers – to
enable them to provide their service.
23.3. We will not share any of the information you provide with any third
parties for marketing purposes.
23.4. We may process your personal information using web services hosted
outside the European Economic Area (EEA), but the organisations we use for
this are compliant with GDPR. The information you provide will be held
securely by us and/or our Data Processors, whether the information is in
electronic or physical format.
​
24. CCTV
24.1. If you wish to view CCTV footage, please follow the steps below in
order to make your request:
Act now
24.2. Footage is only held for 30 days, so please make your request as soon
as possible.
24.3. Please provide us with detailed information about yourself sufficient for
us to be able to prove who you are along with details such as location, time,8
and what incident you are trying to view. This will enable us to locate and
save the footage most relevant to you. Once secured, we will provide you
with a reference number for the footage.
24.4. We have one calendar month to provide you with the information or to
state why we cannot do so.
24.5. If you are not the only person in the footage, we will only release
footage to you directly if we don't have any privacy concerns.
24.6. These concerns will be because one or more of the following apply:
• The length of footage is too long, meaning that the amount of
personal information captured is too great. Generally, requests for
footage should be limited to half an hour
• There is a high likelihood of individuals being identified
• The risk of prejudice to those individuals if re-identification occurs is
high
• The individuals in the footage have a higher expectation of privacy
due to the location of the camera
• The incident captured is of a sensitive nature (e.g., a criminal
offence or road traffic accident)
24.7. If there are other people in the footage and we have privacy concerns,
we will not be able to release the footage to you directly.
24.8. If we cannot release the footage to you directly, the Police or your
insurance company have powers to request this information on your behalf,
and we may be able to release it to them instead.
Process
24.9. Upon receipt of your request an authorised person will locate the
footage and secure a copy to ensure that it is not overwritten.If it is possible
to provide a print by redacting the information that gives rise to our concerns,
then we will do so.
24.10. Once it has been established that the footage does not give rise to any
concerns a series of prints will be made.
The live CCTV footage will not be provided other than to the Police.
25. Contact Us
25.1. If you want to request further information about our Privacy Notice you
can either email us at info@apuldram.org or write to the Data Protection
Officer at:
The Apuldram Centre
Common Farm
Appledram Lane South
Chichester
West Sussex
PO20 7PE