This policy is for Clanrye Group staff, participants registered on programmes with Clanyre Group, and users of Clanrye Group’s website.
Clanrye Group intends to be transparent about why we need the personal details we request from you when you engage with us, and how we will use those details. This policy explains when and why we collect personal information about you. We aim to be clear and transparent and act in a way that you would reasonably expect.
Clanrye Group will hold and process, both electronically and manually, personal data relating to you which is necessary for the performance of this contract and for other lawful processing reasons such as where it is in Clanrye Group’s legitimate interests and where it is necessary for compliance with a legal obligation.
Such personal data includes, without limitation, your employment application, references, bank details, performance appraisals, holiday and sickness and other absence records, expenses information, salary reviews, remuneration details, data regarding employment benefits and other records which may include sensitive personal data (also known as special categories of data) relating to your health.
Special categories of data are defined as personal data relating to racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition, sexual life, biometric data or genetic data.
Clanrye Group collects personal data about you for a variety of reasons which include:
- To be able to contact you and process data on your behalf e.g. for processing salary payments; contact details in the event of an emergency.
- To generate funding from Funders. To be able to run the programmes we offer we need to provide them with personal data on the participants we support, and the staff employed on the programme.
- To enable us to market our programmes effectively to targeted audiences.
Clanrye Group may make your personal data available to any third parties that provide products or services to the Organisation (such as HR and Payroll system administrators, pension administrators and benefits providers), regulatory authorities or as may be required by law.
Please read this policy carefully and any other documents referred to in this policy, to understand how we collect, use and store your personal information.
- Who we are
- Where do we collect information from
- What information do we collect
- What might we do with your information
- How we update your information
- Who might we share your information with
- How to access, correct or delete your information
- How we keep your data safe
- How long we store your data for
- Further information
- Website Terms and Conditions
- Links to and from Clanrye Group’s website
- Following a link to another website
- Following a link to www.clanryegroup.com from another website
- Where your data is processed and stored
- Your rights
- Contact us or make a complaint
- Changes to this policy.
- Who we are
Clanrye Group Ltd was established in 1982 and since that time has been providing quality training, accredited qualifications and employment opportunities to individuals furthest removed from the labour market to tackle disadvantage and improve skills and employment for all, especially those from marginalised groups. We are an Industrial & Provident Society (IP266) with Charitable Status (Charity Number: XR21830) and operate a social enterprise.
Clanrye Group is registered as Data Controllers with the Information Commissioner’s Officer (ICO) under the Data Protection Act 1998, Registration Number: Z7737452
2. Where do we collect information from?
We collect information in the following ways:
Information you give us
- Clanrye Group may obtain personal information from you when, for example, you complete a form to join one of our programmes, apply to become a volunteer, take part in an event, or join our staff and provide us with information for payroll.
Information from Third Parties
- Clanrye Group may obtain information about you from a referral source when you join one of our programmes or join our staff.
- We use Google Analytics software to collect information about how you use www.clanryegroup.com. This includes IP addresses. The data is anonymised before being used for analytics processing. Google Analytics processes anonymised information about:
- the pages you visit on www.clanryegroup.com
- how long you spend on each www.clanryegroup.com page
- how you got to the site
- what you click on while you are visiting the site
- We do not store your personal information through Google Analytics (for example your name or address).
We will not identify you through analytics information, and we will not combine analytics information with other data sets in a way that would identify who you are.
We continuously test and monitor our data protection controls to make sure they are effective and to detect any weaknesses.
Information in the public domain
Clanrye Group may obtain some information from publicly available sources such as, newspaper articles or open postings on social media such as Facebook and LinkedIn.
3. What information do we collect?
The types of personal information that Clanrye Group collects from our internal systems may include:
- Your title, name, gender and date of birth
- Your contact details (address, email, phone number and social media contact details)
- Family and spouse/partner details, relationships to other supporters
- Your professional activities and employment details
- Current interests and activities
- Contact preferences
- Media articles about you
- Your IP address, location, browser type and information on how you interact on our website
- Your bank or credit card details in line with payment card industry standards
- Any other information provided by yourself at the request of Clanrye Group.
Personal data is defined as data which relates to a living individual who can be identified from that data or other information which in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about individual and any indication of the intentions of the data controller or any other person in respect of the individual.
The regulations also define “sensitive personal data” as personal data relating to the racial or ethnic origin of the data subject; their political opinions; their religious (or similar) beliefs; trade union membership; their physical or mental health condition; their sexual life; the commission or alleged commission by them of any offence; or any offence committed or alleged to have been committed by them, the disposal of such proceedings or the sentence of any court in such proceedings.
In some circumstances, the personal information that Clanrye Group collects may include information that is considered “sensitive data”. Where this information is collected, we will tell you so you know why it is needed and we will ensure it is kept for the minimal period.
4. What might we do with your information?
- If you are a participant on one of Clanrye Group progammes, we will use your information to run, fund, develop and evaluate our progammes. This may include newspaper articles and photographs (for which we will obtain your consent). If you avail of our social enterprise, we will mainly use your data to:
- Provide you with the services, products or information that you asked for.
- Keep a record of your relationship with us and record the contact we have with you
- Ensure we know how you prefer to be contacted
- Gather feedback to improve our services, for example our email alerts
- Respond to any feedback you send us (if you have asked us to)
- Send email alerts to users who request them
- Allow you to access our services and make transactions
- Provide you with information about local services
- Monitor use of the site to identify security threats
- The information we collect through Google Analytics to see how you use www.clanryegroup.com. and digital services is to:
- Make sure the site is meeting the needs of its users
- Make improvements, for example improving the site search function.
5. How we update your information
We continuously review records to ensure your data is as accurate as possible and would ask you to let us know if your contact details change.
6. Who might we share your information with?
We are committed to protecting your data and therefore it will never be disclosed or sold to external organisations, other than those acting as agents and data processors carrying out work on our behalf. Where we enter into a relationship with an external third party, any such arrangements will be subject to a formal agreement between Clanrye Group and that organisation to protect the security of your data. The external party will only act under our instructions and we maintain full responsibility for your data.
Third Parties may include:
- IT companies who manager our IT systems.
- Funders who require data in relation to participants and staff in order to permit monitoring of financial and non-financial data against outcomes as required by Article 125.2(a) and Article 140 of the Common Provisions Regulation 1303/2013.
- Media – for which we would obtain your consent.
- Awarding Bodies to include OCN; OCNNI; OCR, RHI, CCEA, BCS, Skills & Education Group.
7. How to access, correct or delete your information
The Data Protection Act 1998 allows you to request a copy of the personal information relating to you which is kept by Clanrye Group.
If your contact details change, or if you believe that the information that Clanrye Group holds about you is out of date or inaccurate, please get in touch with us and provide us with the correct details.
Please address all your requests to your tutor/line manager or email the HR Office (firstname.lastname@example.org)
Upon receipt of a Subject Access Request, Clanrye Group shall have a maximum period of 30 days within which to respond.
Cookies identify your browser, and basic information that you have shared with Google to our servers when you visit our website. They do not identify you as an individual. If you do not want to accept cookies you can easily disable this function by changing the settings on your Internet browser.
9. How we keep your data safe
We aim to ensure that there are appropriate, physical, technical and managerial controls in place to protect any personal information you may provide to us; for example: our online forms containing personal data are encrypted and our network is protected and monitored.
Within our offices all Clanrye Group staff receive training on handling data securely.
Where we use external companies to collect or process data on our behalf, we carry out comprehensive checks on them before we work with them and ensure that contracts are in place that set out our expectations and requirements as set out in point 6 above.
Despite all of our precautions no data transmission over the internet can be guaranteed to be 100% secure. So, whilst we will always strive to protect your personal information, we cannot guarantee the security of any information which you disclose to us and so wish to draw your attention that you do so at your own risk.
10. How long we store your data for
We will hold your personal information on our systems for as long as is necessary for the relevant activity and as long as the law requires us to do so.
11. Further information
The laws governing how your personal data can be used are:
- The General Data Protection Regulation (GDPR) and Data Protection Act 2018
- The Privacy and Electronic Communications Regulations 2003
You can also contact the Information Commissioner’s Office at ico.org.uk to find out more or report a concern. They are the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals. We work with them to make sure that we collect, store and use your information appropriately and act in the way you would expect us to.
12. Website – Terms and Conditions
Access to and use of this website is provided by Clanrye Group and is subject to the terms and conditions accessible on our website https://www.clanryegroup.com/terms-and-conditions
No data transmission over the Internet can be guaranteed to be 100% secure. Therefore, Clanrye Group cannot guarantee that personal or sensitive information remains confidential during transmission over the Internet. All e-mails sent to Clanrye Group will be monitored and checked to ensure our systems operate effectively.
The personal information we collect from you online is stored by us on databases protected through access controls, firewall technology and other appropriate security measures. However, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damage or liability relating to such incidents. We are committed to doing all that we can to keep your data secure. We have set up systems and processes to prevent unauthorised access or disclosure of your data.
We also make sure that any third parties that we deal with keep all personal data secure which they process on our behalf.
14. Links to and from Clanrye Group’s website
www.clanryegroup.com contains links to other websites.
This privacy notice only applies to www.clanryegroup.com and does not cover other government services and transactions that we link to.
15. Following a link to another website
16. Following a link to www.clanryegroup.com from another website
17. Where your data is processed and stored
We design, build and run our systems to make sure that your data is as safe as possible at all stages, both while it’s processed and when it’s stored.
18. Your rights
You have the right to request:
- information about how your personal data is processed
- a copy of that personal data
- that anything inaccurate in your personal data is corrected immediately.
You can also:
- raise an objection about how your personal data is processed
- request that your personal data is erased if there is no longer a justification for it
- ask that the processing of your personal data is restricted in certain circumstances.
If you have any of these requests, get in contact with our Privacy Team.
19. Contact us or make a complaint
Contact our HR office if you:
- have a question about anything in this privacy notice
- think that your personal data has been misused or mishandled
Contact us by email at: email@example.com or by sending a letter to the HR Office, Clanrye Group, Drumalane Mill, The Quays, Newry, BT35 8QS.
Although every reasonable effort has been made to ensure that the information on the Clanrye Group website is accurate at the time of publication, visitors who use this website and rely on any information do so at their own risk. Clanrye Group does not warrant its accuracy and disclaims any liability to any third party for any injury, damage, loss or inconvenience arising as a consequence of any use of or the inability to use any information on this website to the fullest extent permitted at law.
Clanrye Group endeavours to ensure that the information on this website is correct but does not accept any liability for error or omission.
21. Changes to this policy
If these changes affect how your personal data is processed, Clanrye Group will take reasonable steps to let you know.