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NCS Privacy Policy - Last updated 17/05/2018

NCS Trust CIC (NCS) is more than just a youth programme. Yes, we do run a three phase social action programme for 15 to 17 year olds, but in doing so we strive to build bridges across social divides and ladders to opportunity. We bring young people together in common purpose to change their perspectives and lives for good. As a consequence, we are very protective of our young people and staff delivering these opportunities, but also the information about each person connected with NCS.

We understand that you care about your own personal privacy interests, and we take that seriously too. This Privacy Policy describes NCS policies and practices regarding the collection and use of your personal data, and sets out your privacy rights. We recognise that information privacy is an ongoing responsibility, and so we will, from time to time, update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies.

How we collect and use (process) your personal data

Summary

NCS collects personal data about young people and delivery staff, amongst others. We need this information to manage the programme and ensure it is carried out in a safe manner. To do this, NCS collects two types of personal data:

  1. Personally identifiable information (PII) - data which can be used to identify and contact a ‘living individual’ connected to programme e.g. name, address and email address.
  2. Special category information -  personal data that pertains to, but is not limited to, medical, racial or sexual and political life detail, and biometric data such as facial images and voice recordings. This enables us to keep young people safe and healthy, and allows us to support our mission in respect of social cohesion and mobility.

We do not sell personal information to any organisations. We only share data with third parties who are facilitating or enabling the delivery of NCS services.

Detail

Purposes for processing your data

NCS processes your data legitimately to provide you with the goods or services you have requested or purchased from us. We also use this information to refine our goods and services to better tailor them to your needs and to communicate with you about other services NCS offer e.g. post-programme opportunities.

Personal data you give to us:

Programme

When young people express an interest in, or sign up for programme, NCS collect information including (but not limited to) name, address email address, personal mailing address, and mobile phone number. We process personal data to deliver programme benefits to young people, and to inform them of NCS events and other benefits or opportunities associated with the NCS experience.  NCS may also use this information to help understand those attending programme’s needs and interests to better tailor products and services to the individual.

When delivery staff sign up to deliver a programme, NCS will collect information including (but not limited to) name, employer’s name, your work address, your email address, a personal mailing address, and a mobile phone number. Due to working with young people, NCS will also ask delivery staff if:

  • they have a current Disclosure and Barring Service (DBS) certificate;
  • if not, are willing to undergo a DBS check;
  • if they have previously worked on NCS programme;
  • if yes, for what delivery partner.

Live events

NCS runs many programme and post-programme events (for example, graduate extension opportunities and regional youth boards) throughout the year. If you express an interest in attending one of these events, NCS will access the information in your contact details to provide you with information and services associated with the event.

If you are an external participant at these events, NCS will collect information about you including your name, employer’s name, contact information, and your photograph. We may also collect information provided by event attendees who evaluated your performance as an external participant. 

Publications

NCS conduct surveys with young people to produce original research on the effects of the programme on attendees, and society in general. Participation in surveys is voluntary, if you have not been asked, you have not taken part. Although responses to the surveys have names removed, it is anonymous, we still keep this data secure as all other information.

NCS also publish case studies of young people with a particularly interesting story through, or as a consequence of, attending programme. Participation in case studies is voluntary and consent is sought at the start of any of these conversations and before publication. Young people have the ability to withdraw from this activity at any time.

Payment card information

The purchase of goods or services from NCS using a payment card is typically carried out with the parents or guardians of those attending programme. Payment card information is provided directly by users, via the NCS website or over the phone to our customer contact agent. NCS does not, itself, process or store the card information, it is entered into the appropriate system as instructed and then deleted or destroyed.

We strongly encourage all NCS contacts not to submit payment information by email. 

Contacting you

NCS will contact you directly if you have expressed an interest in attending programme, or any of our other post-programme events. This can be via telephone, text, email or social media.

From time to time, NCS may also contact you directly with news and opportunities on continuing your NCS journey, and benefits that may become available through our partners. To view a full list of NCS Partners, visit this link. If you have any questions around this list, please contact us at dataprotectionofficer@ncstrust.co.uk.

At all times, you have the right to not receive any of these communications from NCS.

If this is the case please phone our contact centre (0800 197 8010) who will help you select which communications you do not want - email, telephone, text or social media.

 

Contacting NCS

When you contact NCS, we will use the information you give us within the communication only for the purposes you describe. That can be:

  • to respond to questions or inquiries;
  • to notify you of NCS conferences, publications, or other services;
  • or to keep a record of any complaints, data protection requests and similar matters.

We will treat this data in the most secure and safe manner we can.

For the specific requests below, please email NCS at dataprotectionofficer@ncstrust.co.uk:

  • for NCS to stop communicating with you completely;
  • to stop processing your data or;
  • to “erase” your personal information.

Note: if you ask NCS not to contact you by email at a certain email address, NCS will retain a copy of that email address on record only in order to comply with your no-contact request.

 

Use of the NCS website

Summary

The NCS website collects, and stores safely, certain information automatically. The information may include your internet protocol (IP) address, the region or general location where your computer or device is accessing the internet, and other usage information about the use of the NCS website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. NCS also uses cookies on our website. It does not track users when they cross to third party websites and does not provide targeted advertising from those third parties.

 

Cookies Policy

Detail

A cookie is a small file and holds a certain amount of data, which our website can send to your browser. It may then be stored on your computer's hard drive and can be accessed by our web server. This cookie data can then be retrieved and can allow us to customise our web pages and services accordingly. It's important to clarify that cookies do not collect any personal data stored on your hard drive or computer.

To find out more about cookies, visit this site.

Our cookies fall into two main types:

  • ‘strictly necessary’ cookies, without which we could not provide functionality directly requested by the user, and
  • ‘performance cookies’, used to improve our site.

Google Analytics (GA), the cookies of the second category, do not collect your personal information; rather, NCS look at aggregate data of how popular pages are, how long people spend on a page on average, and so forth, in order to target improvements to our site (e.g. streamlining or signposting a user journey which shows high drop-off). Further information on GA cookies can be found here.

Third party cookies

Where we have content embedded from third-party sites (such as Facebook and Youtube), those sites may set their own cookies. The contents and lifespan of these cookies are not under our control. Please visit these sites for further information on their privacy and cookie policies.

How to disable cookies

If you would prefer not to receive any cookies from us, you can configure your browser to reject them. Where your browser is configured to accept cookies we shall take this as consent to use cookies as outlined on this page. Please note that blocking cookies may result in parts of our website no longer functioning properly for you.

 

When and how we share information with others

Summary

We will only share data with those organisations we absolutely have to, i.e. those that enable the services we offer - NCS programme, post-programme opportunities etc. This may include NCS contractors and their subcontractors, government bodies, fraud detection organisations, strategic partners of NCS (including any organisation running or supporting all or part of NCS in the future).

Detail

The personal information collected from you is stored appropriately in one or more databases hosted by third parties (databases) located in the European Economic Area (EEA), or in locations, and with companies, where a formal agreement of ‘adequacy’ is in place  - i.e. a supervising authority has judged controls to be sufficiently strong to protect personal data. These third parties do not use or have access to your personal information for any purpose other than enabling NCS to achieve the goals of social cohesion, mobility and engagement, and to make the NCS programme as efficient as possible.

This includes our distribution partners who are responsible for running programme and delivering the NCS service to young people. They will not share your data outside of the agreement made with NCS, or without first seeking the approval of NCS (e.g. the young person decides to change the geographic location, and therefore third party (partner) providing NCS programme).

We do not otherwise reveal your personal data to third parties for their independent use unless:

you request or authorise it; the information is provided to comply with the law (for example, to comply with a search warrant or court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; the information is provided to our agents, vendors or service providers who perform functions on our behalf; to address emergencies or acts of God; or to address disputes, claims, or to persons demonstrating legal authority to act on your behalf.

NCS may also gather aggregated data about young people and web site visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, and/or other third parties for marketing or promotional purposes.

The NCS website uses interfaces with social media sites such as Facebook, LinkedIn, Twitter and others. If you choose to "like" or share information from the NCS website through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your site visit to your personal data.

Data subject rights

Summary

The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects. A good explanation of the rules for the UK is available on the website of the Information Commissioner’s Office.

This Privacy Policy is intended to provide you with information about what personal data NCS collects about you and how it is used. If you have any questions, please contact us at dataprotectionofficer@ncstrust.co.uk

If you wish to confirm that NCS is processing your personal data, or to have access to the personal data NCS may have about you, please contact us at dataprotectionofficer@ncstrust.co.uk

Detail

You may also request the following information about your personal data and NCS:

why we process your personal data; the categories of personal data concerned; who else outside NCS might have received your personal data from the us; what was the source of your personal data was if you didn’t provide it directly to NCS; and how long it will be stored.

Additional rights you have as the data subject or owner of your personal data:

you have a right to correct (rectify) the record of your personal data maintained by NCS if it is inaccurate;  you may request that NCS erase that data or cease processing it, subject to certain exceptions; you may also request that NCS cease using your data for direct marketing purposes; when technically feasible, NCS will - at your request - provide your personal data to you or transmit it directly to another controller. If access cannot be provided within a reasonable time frame, NCS will provide you with a date when the information will be provided. If for some reason access is denied, NCS will provide an explanation as to why access has been denied.

Security of your information

To help protect the privacy of data and PII you transmit through use of this site, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to only those employees who need to know that information to provide services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' responsibilities towards your privacy.

Data storage and retention

Your personal data is stored by NCS on the servers of organisations engaged specifically for that purpose, i.e. secure cloud-based storage of data; these are located in the EEA. NCS retains data for the duration of the young person’s, or other stakeholders, relationship with NCS.

For more information on where and how long your personal data is stored, or for any of the other rights you have, please contact the NCS data protection officer at dataprotectionofficer@ncstrust.co.uk

Changes and updates to the Privacy Policy

Summary

As our organisation changes over time, this Privacy Policy and Conditions of Use are expected to change as well. We reserve the right to amend the Privacy Policy at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy at this Site. We may email periodic notices of interest, including notification of these changes, but you should check our website frequently to see the current Privacy Policy that is in effect and any changes that may have been made to it.

Detail

By using this website, you agree to the terms and conditions contained in this Privacy Notice and Conditions of Use and/or any other agreement that we might have with you. If you do not agree to any of these terms and conditions, you should not use this website or any NCS services. You agree that any dispute over privacy or the terms contained in this Privacy Notice and Conditions of Use, or any other agreement we have with you, will be governed by the laws of the United Kingdom (UK). You also agree to arbitrate such disputes in the UK, and to abide by any limitation on damages contained in any agreement we may have with you.

Data Protection Officer

NCS is headquartered in London, in the United Kingdom (UK). NCS has appointed an internal data protection officer for you to contact if you have any questions or concerns about NCS personal data policies or practices. Their name and contact information are as follows:

Martin Fell

NCS Trust

The Pembroke Building

Kensington Village

Avonmore Road

London W14 8DG

Email: dataprotectionofficer@ncstrust.co.uk

Phone: +44(0)7757 682679 

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