1. Introduction
The Deafblind UK Group (“Deafblind UK”, “Deafblind UK Trading”, “we”, “us”, “our”) are committed to protecting your privacy and meeting our legal obligations when you share your personal data with us when expressing an interest in, or apply for, one of our volunteering roles.
This privacy notice explains what personal data we collect and use relating to volunteering and associate candidates (“you”, “your”) whilst performing your duties as a volunteer and/or or during the recruitment process.
As an information-led organisation, we place great importance on ensuring the quality, confidentiality, integrity, and availability of the data we hold, and in meeting our data protection obligations where we process personal data. We are committed to protecting the security of your personal data. We use a variety of technical and organisational measures to help protect your personal data from unauthorised access, use or disclosure.
We are registered with the UK supervisory authority, Information Commissioner’s Office (“ICO”) in relation to our processing of Personal Data under registration numbers Z5842389 (Deafblind UK) and ZA316890 (Deafblind UK Trading).
We update this privacy notice from time to time in response to changes in applicable laws and regulations, to our processing practices and to the services we offer. When changes are made, we will update the date at the top of this document.
2. What personal data do we process?
Personal data means any information about an individual from which that person can be identified, therefore does not include data where the identity of the person has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection.
When you express an interest in volunteering with Deafblind UK, apply for a volunteering role, or submit your CV (or similar information) to us, whether directly or through an agency, or attend an interview in person or by remote means, we will collect your personal data. This may include (but is not limited to):
- Name and contact details (address, mobile phone number and email address);
- Company details (where applicable);
- Date of birth and gender;
- Work history and employment positions held;
- Salary, other compensation, and benefits information;
- Nationality / visa / work permit information (where applicable);
- Academic and professional qualifications, education, and skills;
- Photographs you may submit with your application;
- Demographic information;
- Records we create during interviews or correspondence with you;
- Results of screening checks such as references or DBS checks (where applicable); and
- Any other information you choose to give us.
We may also collect special category data in accordance with the Equality Act 2010. We will only do this, for example, to make reasonable adjustments to enable all candidates to apply for vacancies, attend interviews. This is also necessary to ensure we meet our legal obligations when recruiting.
3. Purposes and bases for using your personal data
We will only use your personal data when the law allows. Most commonly, we will use your personal information in the following circumstances:
- Where it is necessary for the purposes of the agreement/contract in which we have entered
- Where we need to comply with a legal obligation
- Where it is in our legitimate interests (or those of a third party) to do so
- We may also use your data in the following situations, which are likely to be rare:
- With your consent
- Where we need to protect your vital interests (or someone else’s)
- Where it is needed in the public interest
During and after the end of our relationship, we may use your personal data for the following purposes and on the following lawful bases:
| Purpose | Lawful Basis for Processing |
| To respond to your volunteering enquiry and/or application. | We have a legitimate interest to contact you regarding your enquiry and/or application, to arrange an interview and to inform you of your progress through the recruitment process. |
| To assess your suitability for the role. | Processing is necessary for taking steps to enter into an agreement with you or for the performance of our contract with you. |
| To make reasonable adjustments for you during the interview process and comply with our legal obligations under the Equality Act 2010. | Processing is necessary for us to comply with our legal obligations.
For special category data, the additional basis that we rely on relates to our obligations in the field of employment and the safeguarding of your fundamental rights. |
| To conduct screening checks including checking your identity and your right to work in the UK. | Processing is necessary for us to comply with our legal obligations.
For special category data, the additional basis that we rely on relates to our obligations in the field of employment and the safeguarding of your fundamental rights. |
| To contact unsuccessful applicants about future suitable vacancies. | Processing is necessary through our legitimate interest of searching for suitable candidates for future volunteering roles, based on their skills set out in the records we hold about candidates. |
To manage, administer and maintain our relationship, which includes;
|
We process this personal data in the performance of the contract between us and to fulfil our legal obligations.
It is in our legitimate interests to manage your performance and provide personal development and training opportunities. When processing your special category data, we do so under our obligations and responsibilities. In some circumstances we may also process this data with your explicit consent or in your vital interests if unable to give consent. |
Emergency health and welfare reporting to emergency services, next of kin and other interested parties,
We may also process health and welfare data for our own internal purposes such as ensuring your health and safety in the workplace including the monitoring of the health of our volunteers for the purpose of ensuring our offices are a safe environment to work in. |
It is necessary to meet our legal obligations (to make reasonable adjustments to your workplace) and to protect your vital interest that we process the personal information of both you and your next of kin, in case of emergency.
When processing your special category data, we do so under our obligations and responsibilities. We may also process your special category data for the purposes of public health. When we do so we ensure that any individual handling this data is bound by a duty of confidentiality. |
For the purposes of business management and planning, which includes but is not limited to;
|
It is in our legitimate interests that we process this personal data to identify areas for improving volunteer retention, develop new products and services and manage the business. |
To manage, administer and maintain our relationship, which includes;
|
It is in our legitimate interests before, during, and after the end of our relationship, to process this volunteer data.
We may also process this personal data in the performance of the contract between us and to fulfil our legal obligations. When processing your special category data, we do so we do so under our obligations and responsibilities.
|
| To send you newsletters and other promotional material | We will process this personal data where you have provided consent for us to do so |
4. Sensitive personal data
We will only process sensitive ‘special category’ personal data where we meet one of the conditions required by law for doing so. This includes complying with legal obligations or exercising specific rights in the field of employment law. We may also ask for your explicit consent to process some special categories of personal data.
We process special categories of personal data when we collect or process information about your physical or mental health, or disability status, to fulfil our duty of care for volunteers under Section 3 of the Health and Safety at Work Act 1974.
5. Sharing of your information
We may share your data with service providers and suppliers to our business who process data on our behalf. In such cases, our service providers and suppliers are data processors and may only use the data in line with our instructions and not for any other purpose. This and other obligations are agreed in the written contract between Deafblind UK and the service providers and suppliers.
Where we need to transfer or store your personal data outside the UK, we will only do so relying on either an Adequacy Regulation (the UK equivalent of an EU Adequacy Decision), the UK International Data Transfer Agreement (the UK equivalent of the EU-approved Standard Contractual Clauses), or another approved international data transfer mechanism, which contractually oblige third party organisations in those countries to comply with the same data protection standards as legislated within the UK.
Within Deafblind UK, your personal data will only be shared with those who need to have access to it, which will primarily be our HR personnel, hiring managers and IT staff.
6. How long will we retain your information?
Initially, we will only retain your personal data for only as long as is necessary for the recruitment process.
However, if your candidacy is successful and you take up a volunteering position, we shall retain your personal data for as long as is necessary to fulfil the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements. Details of retention periods applicable to volunteers are set out in our Data Retention & Destruction Policy and Schedule.
If your candidacy is not successful, we will retain your CV, application details and interview notes for 6 months from the date we notified you we would not move forward with your application, to inform you about any future volunteering roles we have that may be of interest to you. Please let us know if you would like us to delete your records before our retention period lapses and we will do so.
We will also retain personal data where it is necessary to comply with our legal obligations or as necessary in relation to legal claims. This is rare but may mean we need to retain your data for longer than 6 months.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a volunteer, we will retain and securely destroy your personal information in accordance with our Data Retention & Destruction Policy and Schedule.
7. How we protect personal data
Deafblind UK takes the security of your data seriously. We have implemented appropriate technical and organisational measures to safeguard your personal data and protect it from accidental or unlawful destruction, loss or alteration and from unauthorised disclosure or access.
Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of the data.
8. Your rights
Individuals whose personal data we process have the following rights:
- You have the right of access to your personal data and can request copies of it and information about our processing of it
- If the personal data we hold about you in incorrect or incomplete, you can ask us to rectify or add to it
- Where we are using your personal data with your consent, you can withdraw your consent at any time
- Where we are using your personal data because it is in our legitimate interests to do so, you can object to us using it this way
- In some circumstances, you can restrict our processing of your data, request a machine-readable copy of your personal data to transfer to another service provider and compel us to erase your personal data
- Automated decision-making. You have the right not to be subject to a decision based solely on automated processing which will significantly affect you.
If you wish to exercise any of your rights, please write to us at [email protected].
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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
In addition to the above, please note that you have the right to make a complaint at any time to the ICO if you are concerned about the way in which we are handling your personal data.
The Information Commissioner’s Office can be contacted online at https://ico.org.uk/make-a-complaint/ or by telephone on 0303 123 1113.
9. Your duty to update us
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.
10. What if you do not provide personal data to us
You have an obligation when volunteering with Deafblind UK to provide us with your personal data. You are required to report absences and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide us with data in order to exercise your statutory rights. Failing to provide the data may mean that you are unable to exercise your statutory rights.
Certain information, such as contact details, your right to work, security checks and payment details for example, may be required to enable Deafblind UK to enter into an agreement with you and pay you expenses (where applicable). If you do not provide the required information, this will hinder or prevent us from administering the rights and obligations arising as a result of our relationship.
11. Automated Decision Making
We do not make decisions based solely on automated decision making.
12. Contact
You can contact Deafblind UK in relation to data protection and this privacy notice by emailing [email protected] or writing to us using the address below:
The Data Protection Manager
Deafblind UK
167-169 Great Portland Street
5th Floor
London
W1W 5PF