Volunteer and Student Privacy Notice

Data Controller: Harbour Drug and Alcohol Services, Hyde Park House, Mutley Plymouth, PL4 6LF

Governance Team: Harbour Drug and Alcohol Services, Hyde Park House, Mutley, Plymouth, Devon, PL4 6LF. Tel: 01752 434343 Email: thcpltd.dpo@nhs.net

Harbour collects and processes personal data relating to its students and volunteers to manage the student and volunteering relationship. We are committed to being transparent about how we collect and use your personal data to meet our data protection obligations.

This Privacy Notice aims to provide you with a clear explanation of the personal data which Harbour holds and the purpose[s] for which it is held.

What information does Harbour collect?

We collect and process a range of information about you. This may include (as appropriate to the student or volunteering role):

your name, address and contact details, including email address and telephone number
your nationality and information about your entitlement to volunteer in the UK
the details of your student or volunteering agreement including start date
details of your qualifications, skills, experience and employment history including start and end dates, with previous employers and with the organisation
an assessment of your suitability for the activity you are volunteering to do
information about your next of kin, dependants and emergency contacts
information about your criminal record
details of any safeguarding incidents in which you have been involved
information about your eligibility to drive and any associated insurance or MOT documents for your private vehicle
details of your availability for volunteering and attendance
information regarding any training you receive
equal opportunities monitoring information, including information about your martial or civil partnership status, ethnic origin, sexual orientation, health and religion or belief.
email correspondence

Harbour may collect this information in a variety of ways. For example, data might be collected through:

Volunteer and student application forms
passport
driving licence
from forms completed by you at the start of or during volunteering (such as contact detail forms) from correspondence with you or through interviews, meetings or other assessments.

In some cases, Harbour may collect personal data about you from third parties, such as references from organisations who have engaged you as a volunteer or student and information from criminal records checks permitted by law.

Data will be stored in a range of different places, including in your volunteering file and in our IT systems.

Why does Harbour process personal data?

Your personal data will be processed to enable us to enter into a volunteer/student agreement with you.

Harbour also needs to process data to ensure that it is complying with its legal obligations, for example to comply with health and safety laws.

In other cases, Harbour may have a legitimate interest in processing personal data before, during and after the end of the volunteering/student relationship.

Processing volunteer/student data allows Harbour to:

run volunteer recruitment and appointment processes
maintain accurate and up-to-date volunteer records and contact details (including details of who to contact in the event of an emergency)
obtain appropriate legal or HR advice, to ensure that it interprets and complies with duties in relation to legislation and its own policies, processes and procedures in a fair and reasonable manner
ensure that volunteers/students are receiving appropriate reimbursement of expenses
ensure effective general business administration
respond to and defend against legal claims
maintain and promote equality in the workplace
Training and Development
Consulting and communicating

Where Harbour processes other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring. Data that is used for these purposes is anonymised or is collected with the express consent of volunteers/students, which can be withdrawn at any time. Volunteers/students are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.

We do not need your consent if we use special categories of personal data in order to carry out our legal obligations. In some circumstances however we may ask for your consent to allow us to process certain particularly sensitive data. In these circumstances we will provide you with sufficient information about how your data will be used for you to make a choice about whether to provide your consent. You will have full control over your decision to give or withhold consent, and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time, with no consequences.

Who has access to your data?
Your data will be shared with colleagues within Harbour where it is necessary for them to undertake their duties.

This includes:

relevant managers for the purposes of supervision
the administration team for co-ordination of volunteering activities, maintaining volunteer records and for accessing details in an emergency
the finance team for processing payment of expenses
IT staff who require your information to set up IT systems

Harbour may be required to share your data with third parties such as the local authority, police, Disclosure and Barring Service DBS to comply with legal obligations. These arrangements are also governed by a duty of confidentiality.

Harbour will not share your data with third parties for any other purpose without your express consent.

Harbour will not transfer your data to countries outside the European Economic Area.

How does Harbour protect data?

Harbour takes the security of your data seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the performance of their duties.

Control measures include:

Secure filling cabinets in locked spaces with restricted access
IT passwords
IT access restrictions administrated by key personnel
Server systems with layered restricted access audited regularly
All portable equipment with passwords and encryption
Procedure for wiping and resetting equipment
Working from home procedures

Where Harbour engages third parties to process personal data on its behalf, they do so on the basis of written instructions under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

For how long does Harbour keep data?

In line with data protection principles, we only keep your data for as long as we need it for.

We will keep your data for a period after your volunteering/student relationship has ended. Retention periods can vary depending on why we need your data. This may be determined by law. The periods for which your data is held after the end of volunteering/student placement are set out in our Data Retention Policy.

Automated decision-making (making a decision solely by automated means without any human involvement)
Volunteering decisions are not based on automated decision-making.

Your rights

As a data subject, you have a number of rights. These are:

the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
the right of access. You have the right to access the data that we hold on you and to receive a copy of your data and information about where it was sourced. To do so, you should make a subject access request. You can read more about this in our Data Protection Policy
the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
the right to ask Harbour for your data to be erased, for example if you believe there is no longer any need for your data to be held for its original purpose, or if you decide to withdraw any consent that you have given for your data to be processed
the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
the right to portability. You may transfer the data that we hold on you to another organisation for your own purposes
you have the right to object to the way we use your data if you do not agree that we are using it for our legitimate interests
You have the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in ways that adversely affects your legal rights.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you would like to exercise any of these rights, please contact the HR Officer within Harbour Drug and Alcohol Services, Hyde Park House, Mutley, Plymouth, Devon, PL4 6LF, 01752 434343.

If you believe that Harbour has not complied with your data protection rights, you can complain to the Information Commissioner. Their contact details can be found on their website (www.ico.org.uk).