This policy is effective from 24 May 2018.
When we say ‘processing of information’, this includes the collection, use, storage and protection of data. Childline Gibraltar is the ‘data collector’ for the purposes of this policy and the policy extends to its trustees, staff, donors, volunteers and service users who are our “data subjects”.
About data processing
Organisations are allowed to process data if they have a legal basis for doing so. There are six available lawful bases for processing. Childline Gibraltar processes data on the following four bases, which vary depending on whether you are a staff member or a service user:
- Vital interests: the processing is necessary to protect or safeguard children.
- Consent: you have given us clear consent (permission) to process your personal data for a specific purpose.
- Contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
- Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.
Where Childline Gibraltar is relying on solely consent as the basis for processing data, we are required to obtain your explicit consent and you can modify or withdraw this consent at any time by notifying us in writing, although this may affect the extent to which we are able to provide services to or interact with you in future.
Parental/guardian consent is not required where the processing is related to preventative or counselling services offered directly to a child. The information we hold on our young service users is held on the basis of vital interest.
What information do we collect about you?
We collect information (data) necessary for Childline Gibraltar to pursue its charitable objectives, together with fundraising and marketing, running events, keeping our supporters informed of our activities and the effective running of Childline Gibraltar as an operational and fundraising charity through its trustees, staff and volunteers.
Your well being is our number one priority and therefore Childline Gibraltar collects and processes the data that you give us. That can be your name, your age, your address, the issues you have discussed with us and any other information you have given us. Remember, you don’t have to give us any personal information to use our Helpline service but, if you do, we will use it to try to help you or for statistical information.
Donors and volunteers
Data collected and processed may include, but not be limited to:
- Names and contact information such as telephone numbers, email and postal addresses
- Donor and volunteer records and preferences, including, where necessary, bank or payment details and tax status in order to process payments from you and claim Gift Aid
- Administrative details including dietary requirements or preferences, medical information, passport data and photos for participants in events or guests or participants at other fundraising or promotional events
- Such other information that is relevant and necessary for Childline Gibraltar to carry out its activities, charitable purposes and legal obligations.
How will we use the information about you?
There are a few reasons we may disclose your personal information to third parties. We may do that when:
- We are legally obliged to;
- We feel it would be in the best interest of our service users;
- To protect the rights, property or safety of Childline Gibraltar, our donors or others.
This includes exchanging information with local authorities or social services for the purposes of the provision of health, legal or social care or treatment.
Our service is confidential. That means we won’t be telling anyone else about what you’ve said. It can happen that we are worried about your safety or another child’s safety and then we may need to get you or the other child help. At that point we will share your personal information with other agencies. We will only do this when we believe you or someone else is in danger of significant harm.
We also use your data anonymously in a data report, like our Annual Report.
Donors and volunteers
Childline Gibraltar uses the data collected to maintain accurate internal records of donors, event participants and supporters, staff and others. These records facilitate our activities in raising funds and awareness about our work through campaigns and events. We may use your personal information to send you information about Childline Gibraltar and our activities which we think may be of interest to you.
Access to information and correction (and refusal)
If we are holding your data purely on the basis of consent, you can request details of your personal information which we hold about you. Any such request must be submitted in writing. You can request deletion of your data at any time in writing, subject to any overriding legal requirement for its retention. However, Childline Gibraltar may keep certain data on a suppression list to prevent further unwanted contact or data processing.
You may choose to restrict the collection or use of your personal information, but this may inhibit or limit the way in which Childline Gibraltar is able to interact with you. You may, at any time, change your mind about what information we hold about you, or if we continue to hold it at all, subject to any legal obligation on Childline Gibraltar to retain data.
You are responsible for the accuracy of data you have provided to Childline Gibraltar. If you believe that any information we are holding on you is incorrect or incomplete, please write to us as soon as possible. We will promptly correct any information found to be incorrect.
You can obtain further information about Data Protection and privacy laws by visiting the Gibraltar Regulatory Authority’s website www.gra.gi.
If you want to know what information we have collected about you or if you want to have that information deleted, you can write to us. For legal reasons we may not be able to delete the information you would like to have deleted. It may be that we ask you to prove that you are indeed the person you say you are before we give you access to the information you have requested. We only do this to make sure we give the information to the right person.
Donors and volunteers
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the data we process. Persons processing data on behalf of Childline Gibraltar do so in accordance with this policy and on the basis that Childline Gibraltar is satisfied that they can and will adhere to our high standards for data protection and security. These include enhanced policies and protocols for the processing of particularly sensitive data.
Any sensitive information that does not otherwise need to be retained (such as credit or debit card details) are redacted or destroyed once used.
Please note that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
How to contact us
You have the right to lodge a complaint with the Gibraltar Regulatory Authority (“GRA”) if you believe your data has been processed in a way that does not comply with the GDPR. You can do so by calling the GRA on 200 74636 or via email to firstname.lastname@example.org.