Privacy

INTRODUCTION
1. Difference North East respects your privacy and is committed to protecting your personal data. The purpose of this privacy policy is to explain how we will use any personal data we collect about you, the rights you have over any personal data we hold about you, and to tell you about the policies and procedures that we have in place to respect your privacy and keep your personal data secure.
2. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are folly aware of how and why we are using your data. This privacy notice supplements any other privacy notices and is not intended to override them.
KEY INFORMATION
1. Data Controller: Difference North East, a charity registered in England and Wales with registered number 1170789 (Difference, we, us or our in this privacy notice) is the data controller for the purposes of applicable data protection law.
2. Complaints: If you have any questions or complaints relating to this privacy notice, including any requests to exercise your legal rights, please email us at info@differencenortheast.org.uk. You also have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues and whose website you can access at www.ico.org.uk. Please contact us in the first instance so that we might seek to resolve any issues for you.
3. Updates: It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.
4. Third-Party Websites: This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
THE DATA WE COLLECT ABOUT YOU
1. Personal Data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.
2. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
  1. Contact Data includes email address and telephone number.
  2. Correspondence Data includes information you send to us by email, survey, social media or customer service communications.
  3. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  4. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  5. Usage Data includes information about how you use our website.
3. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data means data that may be derived from your Personal Data but does not directly or indirectly reveal your identity and is not therefore considered Personal Data in law. If we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy notice.
SENSITIVE PERSONAL DATA
1. Sensitive Personal Data means data concerning race, ethnicity, political opinions, religious or philosophical beliefs, sexual orientation and data concerning physical or mental health. We do not collect Sensitive Personal Data other than data concerning physical health.
2. We collect data about your opinions on our website in, among other places, ‘our mystery shopper’ form and through our ‘enabling/disabling experience’ survey question on the homepage. In accordance with applicable law we apply stricter control when processing this data. We only process this data where:
  1. you have given your explicit consent to the processing for one or more of the purposes set out in paragraph 6.2 below; or
  2. you have made the Sensitive Personal Data public.
3. The Sensitive Personal Data which we collect is stored on a secure database, to which only a limited number of members of staff have access. It is deleted when no longer relevant, is never shared with third parties and is available to you at any point shoold you wish to see it. Please email us at info@differencenortheast.org.uk if you have any questions on how we collect and store this data.
HOW WE COLLECT YOUR PERSONAL DATA
1. We use different methods to collect data from and about you including through:
  1. Direct Interactions: You may give us your Identity Data and Contact Data when you create an account on our website, subscribe to our service or publications, request marketing to be sent to you, give us feedback or correspond with us in any other way.
  2. Automated Technologies: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies.
HOW WE USE YOUR PERSONAL DATA
1. Purposes: We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data to manage and administer our website in a safe and secure manner. This includes, among other things, your use of our ‘Experiences’ section of the Difference website.
2. In addition, we may use your Personal Data:
  1. To communicate with you by email about your use of our website or any content you upload to our website;
  2. to send you important information regarding the website including notices, security alerts, and support and administrative messages;
  3. to provide better content, services and marketing to you;
  4. to profile individual and demographic trends of people using or posting on our website;
  5. where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
  6. where we need to comply with a legal or regulatory obligation.
3. Legal Basis: We use your Personal Data on the following legal bases:
  1. your consent;
  2. in our Legitimate Interests including to improve the performance and content on our website or in order to enhance users’ experiences of the website; and/or
  3. to comply with a legal obligation.
4. One of the legal bases for us processing/using your Personal Data is that such use/processing is in the Legitimate Interests of Difference. Legitimate Interest means the interest of Difference in conducting and managing our website to enable us to give you the best and most informative content on our website and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our Legitimate Interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our Legitimate Interests against any potential impact on you in respect of specific activities by contacting us.
5. If you would like further information about the purposes for which we use your Personal Data and/or the legal bases on which we use it, please email us at info@differencenortheast.org.uk and we will be in touch as soon as we can.
6. Email Updates: You will receive marketing communications from us if you have requested information from us or if you opted to receive our email updates when signing up to be a member of our website.
7. Third-Party Marketing: We will not share your Personal Data with any third party company without your express consent.
8. Opting Out: Where we rely on your consent to process your Personal Data (e.g. marketing), you may withdraw your consent at any time by emailing info@differencenortheast.org.uk. You can ask us or third parties to stop sending you marketing messages at any time by emailing us at info@differencenortheast.org.uk.
9. Cookies: You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
10. Change of Purpose: We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please contact us if you woold like an explanation as to how the processing for the new purpose is compatible with the original purpose.
11. We will notify you if we need to use your Personal Data for an unrelated purpose and we will explain the legal basis which allows us to do so.
12. Please note that, where required or permitted by law, we may process your Personal Data without your knowledge or consent.
DISCLOSURES OF YOUR PERSONAL DATA
1. We may have to share your Personal Data with the following parties for the purposes set out in paragraph 6 above:
  1. Professional advisers acting as processors or joint controllers including auditors and insurers who provide accounting and insurance and services along with any other professionals who provide professional services or advice.
  2. Service providers acting as processors who provide IT and system administration services.
2. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
DATA SECURITY
1. We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties on a need to know basis. They will only process your Personal Data in accordance with our instructions and they are subject to a duty to ensure that your Personal Data remains confidential.
DATA RETENTION
1. We will only retain your Personal Data for as long as is necessary to folfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
2. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
3. In some circumstances you can ask us to delete your data. For further details, please see paragraph 11.1(c) below.
4. In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
1. You have the right to:
  1. Request access to your Personal Data. This is commonly known as a data subject access request. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfolly processing it.
  2. Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  3. Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfolly exercised your right to object to processing (see paragraph 11.1(d) below), where we may have processed your information unlawfolly or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  4. Object to processing of your Personal Data where we are relying on a Legitimate Interest (or those of a third party) and there is something about your particolar situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  5. Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawfol but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  6. Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  7. Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfolness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
2. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in such circumstances.
3. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
4. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particolarly complex or if you have made a number of requests. We will do our best to keep you updated as much as possible in such circumstances.
5. Please contact us at info@differencenortheast.org.uk if you wish to exercise any of your rights.
CONTACT US
1. If you have any comments or queries in relation to this privacy policy, please email us at info@differencenortheast.org.uk and we will get back to you as soon as we can.