Privacy Policy

Introduction

Age Cymru understands that your privacy is important, and we care about how personal data is used. We respect and value the privacy of everyone who comes into contact with Age Cymru and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and the rights of all individuals' rights under the law.

This policy applies to individuals whose personal data is processed by Age Cymru, including those who use our website, use our services or volunteer with us. This policy does not apply to employees of Age Cymru and the personal data that we collect and use in the course of an employees employment. If you are an employee of Age Cymru please refer to the Intranet for the relevant privacy information.

Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

Key terms used in the policy

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Age Cymru, a registered charity in England and Wales and a company limited by guarantee. For more information on Age Cymru please see section 2 below.
Our data protection officer	Amanda O’Shea. Amanda’s email address is amanda.oshea@agecymru.org.uk
Personal data	Any information relating to an identified or identifiable individual.
Special category personal data	Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic data, biometric data (where used for identification purposes), data concerning health, sex life or sexual orientation.

Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic data, biometric data (where used for identification purposes), data concerning health, sex life or sexual orientation.

Who is Age Cymru

Age Cymru is the national charity for older people in Wales. We are a registered charity and a company limited by guarantee.
Registered Office: Ground Floor, Mariners House, Trident Court, East Moors Road, Cardiff CF24 5TD.

Charity Number: 1128436
Company Number: 0683728

Who do we collect data from?

We collect data from those individuals who use our website, who use our services, who volunteer with us or who provide services or goods to us. This includes:

Trustees
Volunteers
Sub-contractors
Suppliers
Customers and service users (those who use our services/make enquiries with us for example, users of our Information and Advice service)
Users of our website
Those individuals who may take part in our surveys or events.

We request individuals aged 16 or under‚ obtain the permission of their parent/guardian's whenever providing us with personal information.

Personal data we collect about you

The personal data we collect about you depends on the reason that you are interacting with us. We will typically collect and use the following personal data about you:

When you use our services:

Your name and contact information, including email address and telephone number;
If you use our advice or advocacy services, then in order to ensure we provide you with the correct support, we may need to collect special category data about you, for example we may need to ask questions about your health, including any disabilities, your financial status and whether you are receiving any benefits;
Any issues that you may be experiencing, what we have agreed between us to resolve them and any actions taken.
We can collect data through surveys/research but consent will be sort if further contacted is to be made.

Where you volunteer with us, or are one of our Trustees (or apply to be a volunteer or Trustee):

Your name and contact information, including email address and telephone number;
Information and/or documents to enable to us to check and verify your identity;
Depending on the nature of your involvement we may need to ask you to complete a DBS check;

Where you make a donation to us or raise money on our behalf:

Your name and contact information, including email address and telephone number when provided;

Where you are supplying us with goods and or services:

Your name and company/corporate contact details;
Where appropriate bank details.

When you engage with us at events/use our website we may collect:

Information about how you use our website, IT, communication and other systems
Your responses to surveys, and intelligence gathering campaigns

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you or otherwise being able to develop your relationship with Age Cymru.

How your personal data is collected

We collect most of this personal data directly from you—in person, by telephone, text or email, surveys or forms you complete and/or via our website.

However, we may also collect information:

From publicly accessible sources, eg Companies House;
Directly from third parties, such as those who provide us with DBS checks;
If another party has contacted Age Cymru on your behalf, then we may collect your personal data from them (for example if they call our Information and Advice line with your consent);
from cookies on our website - for more information on our use of cookies, please see our cookie policy.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

where you have given consent;
to comply with our legal and regulatory obligations;
for the performance of a contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party; or
any information disclosed to Age Cymru about suspected abuse or neglect will be subject to the legal duty of confidentiality. Although this normally means that it will not be shared, there may be situations where the public interest requires disclosure.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Providing our services to you Keeping you up to date with information about our services, including notifying you of changes to planned services	Depending on the nature of the services we are providing, our lawful grounds for using your personal data will be: - To perform our contract with you or to take steps at your request before entering into a contract – this applies where we have entered into a contract with you in respect of the services; - In our legitimate interests of carrying out charitable activities and providing services as a charity - this will apply where we have not entered into a contract with you.
Process donations you make to us or funds you raise for us	In our legitimate interests of carrying out charitable activities and providing services as a charity.
Sharing information with emergency services where it is necessary to protect life or health or preventing and detecting/reporting safeguarding issues and making necessary reports	- Where is it necessary to protect life or health or to take steps in respect of safeguarding issue which requires us to share the personal data; - To comply with a statutory obligation that we are subject to.
Conducting checks to identify our Volunteers (including Trustees) and verify their identity	Depending on the circumstances.
Other activities necessary to comply with legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by the Charity Commission	- to comply with our legal and regulatory obligations; - for our legitimate interests of running a charity.
Gathering and providing information required by or relating to audits or enquiries and to comply with the information requirement of those who provide us with Grant Funding	To comply with our legal and regulatory obligations.
Ensuring business policies are adhered to, eg policies covering security and internet use	For our legitimate interests - to make sure we are following our own internal procedures so we can deliver the best service to you.
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests - to be as efficient as we can so we can deliver the best service to you at the best price.
Statistical analysis to help us manage our business, eg in relation to financial management, understanding those who are using our services and the reach of the charity	For our legitimate interests or providing charitable services to older people in Wales.
Preventing unauthorised access and modifications to systems	Depending on the circumstances: - for our legitimate interests - to prevent and detect criminal activity that could be damaging for you and/or us; - to comply with our legal and regulatory obligations.
Protecting the security of systems and data used to provide our services	To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us.
Statutory returns	To comply with our legal and regulatory obligations.
Ensuring safe working practices	Depending on the circumstances: - to comply with our legal and regulatory obligations; - for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
Marketing our services and those of selected third parties to: —existing and former customers; —individuals who have previously expressed an interest in our services.	For our legitimate interests, ie to promote our business to existing and former customers.
External audits and quality checks, eg for ISO or Investors in People accreditation, Investing in Volunteers, Advocacy Quality Mark, Charity Quality Standard and IAQP and the audit of our accounts to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ above.	Depending on the circumstances: - for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards; - to comply with our legal and regulatory obligations.

How and why we use your special category personal data

As set out in section 4 above, we may sometimes collect data from you that is special category data to which additional protections apply under data protection law. Where we process special category data, we will also ensure we are permitted to do so under data protection laws, meaning that we will either:

we have your explicit consent;
the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
the processing is necessary to establish, exercise or defend legal claims.

Marketing

If you're someone who uses our services, used to use our services or have made enquiries about our services then we will use your personal data to send you updates (by email, text message, telephone or post) about our services, including recent programmes and activities that we have carried out.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by contacting enquiries@agecymru.org.uk

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.

Who we share your personal data with

We routinely share personal data with:

third parties we use to help deliver our services to you;
other third parties we use to help us run our business, eg marketing agencies or website hosts;
third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
our insurers and brokers;
Where we are required to do so under the terms of any Grant Funding received – with the Grant Funding provider;

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

our external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
our professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency - usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

We may on occasion share basic demographic and service information with Age UK the national charity so they can help us monitor and ultimately improve the services we provide. The information we share will not include your name or your contact details, unless you give us your consent to do so for a specific purpose, such as sharing your story. When we do share this information, we do so under the lawful basis of legitimate interest.

Where your personal data is held

Personal data may be held at our offices and those of our service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used.

Different retention periods apply for different types of personal data. Further details on this are available in our Data Retention Policy.

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal data
Rectification	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consents	If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. You may withdraw consents by contacting. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you'd like to exercise any of those rights, please:

Write to us at: Age Cymru, Mariners House, Trident Court, East Moors Road, Cardiff CF24 5TD; or

Email us: enquiries@agecymru.org.uk

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner in the UK:

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on and last updated July 2023.

We may change the Privacy Notice from time to time. This may be required if, for example, if the law changes, or if we change our business in a way that affects how we process your personal data.

Links to other websites

Our website may contain links to other websites run by other organisations. This policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other websites even if you access those using links from our website.

In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the privacy policy of that third-party site.

How to contact us

You can also contact us or our Data Protection Officer by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Postal address: Age Cymru, Mariners House, Trident Court, East Moors Road, Cardiff CF24 5TD

Email address: enquiries@agecymru.org.uk

Our Data Protection Officer: amanda.oshea@agecymru.org.uk