Data Protection Policy

Contents

  1. Introduction 3
  2. Scope 3
  3. Purpose 3
  4. GDPR Privacy Notice 3
  5. Legal Requirements 3

5.1. The basis on which we process information about you 4

  1. Principles 4
  2. Roles and Responsibilities 5
  3. Data Processing and Management 5

8.1. Information we process because we have a contractual obligation with you. 5

8.2. Information we process with your consent. 6

8.3. Information we process for legitimate interests. 6

8.4. Information provided on the understanding that it will be shared with a third party. 7

8.5. Communicating with us 7

8.6. Affiliate and business partner information. 8

8.7. Cookies 8

8.8. Personal identifiers from your browsing activity 9

8.9. Information we obtain from third parties. 9

8.10. Third-party advertising on our website 9

8.11. Data may be processed outside the European Union 9

8.12. Use of the site by children 10

8.13. Encryption of data sent between us 10

8.14. Retention period for personal data 10

  1. Data Subject Rights 11
  2. Data Security 11

10.1. How you can complain 11

  1. Data Breach Notification 12
  2. Training and Awareness 12
  3. Document Review and Control 12


Introduction

Maternity Engagement Action (MEA) is dedicated to safeguarding the privacy and security of personal data. This policy details our obligations and procedures to ensure compliance with the General Data Protection Regulation (GDPR). We are committed to protecting your privacy and the confidentiality of your personal information.

Our policy is not just an exercise in complying with the law but a continuation of our respect for you and your personal information. We undertake to preserve the confidentiality of all information you provide and hope you reciprocate.


Scope

This policy applies to all personal data processed by Maternity Engagement Action (MEA) and its employees, volunteers, and contractors. It pertains to personal data collected through all formats, including digital and paper-based.


Purpose

The purpose of this policy is to inform you about how we collect and process any information that we collect from you or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.


GDPR Privacy Notice

This is the Maternity Engagement Action CIC (MEA) privacy notice. 

In this document, “we”, “our”, or “us” refer to Maternity Engagement Action CIC. We are company number 13104291, registered in The United Kingdom. 

Our registered office is at Urban Works, 69 Steward Street, Birmingham, B18 7AF.


Legal Requirements

GDPR and UK GDPR protect data. Their purpose is to protect the rights and privacy of individuals and ensure that personal data is not processed without their knowledge and, wherever possible, without their consent. The Act requires MEA to register that they hold personal data and acknowledge the right of ‘subject access’ – clients, mums, volunteers, and staff must have the right to access copies of their data.

 

Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).

The law requires us to tell you about your rights and our obligations regarding processing and controlling your data. We do this now by requesting that you read the information at http://www.knowyourprivacyrights.org.

 

Except as set out below, we do not share, sell, or disclose any information collected through our website to a third party.

The basis on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information and to notify you of the basis for each category.

If the basis on which we process your personal information is no longer relevant, we shall immediately stop processing it.

If the basis changes, we shall notify you of the change and any new basis under which we have determined that we can continue processing your information if required by law.

Principles

MEA adheres to the following GDPR principles:


  • Lawfulness, Fairness, and Transparency: Personal data shall be processed lawfully, fairly, and transparently.
  • Purpose Limitation: Personal data shall be collected for specified, explicit, and legitimate purposes and not further processed in an incompatible manner.
  • Data Minimization: The collection of personal data shall be adequate, relevant, and limited to what is necessary for the purposes for which they are processed.
  • Accuracy: Personal data shall be accurate and, where necessary, kept up to date.
  • Storage Limitation: Personal data shall be kept in a form which permits identification of data subjects for no longer than is required for the purposes for which the personal data are processed.
  • Integrity and Confidentiality: Personal data shall be processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and accidental loss, destruction, or damage using appropriate technical or organisational measures.
  • Accountability: MEA is responsible for and must be able to demonstrate compliance with the GDPR.


Roles and Responsibilities

  • Data Protection Officer (DPO): The DPO oversees data protection strategy and implementation to ensure compliance with GDPR requirements. Unless otherwise stated, the HR/Admin officer will act as the DPO.
  • Management: Ensure all company policies and procedures related to GDPR are updated and adequately implemented.
  • Employees and Volunteers: Must understand and adhere to this policy and other related procedures.


Data Processing and Management

We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:

  • Your identity includes information such as first name, last name, title, date of birth, and other identifiers you may have provided.
  • Your contact information includes billing address, delivery address, email address, telephone numbers and any other information you have given us for communication or meeting.
  • The technical data includes your internet protocol (IP) address, browser type, time zone setting, and other technology on the devices you use to access this website.
  • Marketing data includes your preferences for receiving marketing from us, communication preferences, and responses and actions related to your use of our services.
  • We may aggregate anonymous data for various purposes. Anonymous data does not identify you as an individual and is not considered personal information in law.
  • However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information. We will use it for this privacy notice.

Information we process because we have a contractual obligation with you.

When you sign up, purchase, or agree to our terms, a contract is formed between you and us. We need to process the information you provide to fulfil our obligations under that contract, some of which may be personal. We may use it to:

  • verify your identity for security purposes.
  • sell products/services to you.
  • provide you with our services.
  • provide suggestions and advice on products, services and how to obtain the most from our website.

 

We process this information based on whether there is a contract between us or whether you have requested that we use the information before we enter a legal contract. We shall continue to process this information until the contract between us ends or is terminated by either party under the contract terms.

Information we process with your consent.

Through specific actions when there is otherwise no contractual relationship between us, such as browsing our website or asking us to provide you with more information about our business, including our products and services, you give your consent to us to process personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

If you have given us explicit permission to do so, we may, from time to time, pass your name and contact information to selected associates whom we consider may provide services or products you would find helpful.

 

We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at admin@maternityengagement.uk However, if you do so, you may not be able to use our website or our services further.


Information we process for legitimate interests.

We may process information if there is a legitimate interest, either to you or to us, in doing so.

Where we process your information on this basis, we do so after having considered the following:

  • whether the same objective could be achieved through other means
  • whether processing (or not processing) might cause you harm
  • whether you would expect us to process your data and whether you would, in the round, consider it reasonable to do so.

For example, we may process your data on this basis for:

  • record-keeping for the proper and necessary administration of our company Maternity Engagement Action CIC.
  • responding to unsolicited communication from you to which we believe you would expect a response.
  • protecting and asserting the legal rights of any party
  • insuring against or obtaining professional advice that is required to manage Maternity Engagement Action risk.
  • protecting your interests where we believe we have a duty to do so


Information provided on the understanding that it will be shared with a third party.

Our website allows you to post information with a view to that information being read, copied, downloaded, or used by others. Examples include:

  • posting a message on our forum.
  • tagging an image.
  • Click on an icon next to another visitor’s message to convey your agreement, disagreement, or thanks.

 

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do not specifically use this information except to allow it to be displayed or shared. We store it and reserve the right to use it in the future in any way we decide.

 

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

 

If your request is reasonable and there is no legal basis for us to retain it, then at our discretion, we may agree to your request to delete the personal information you posted. You can request by contacting us at info@maternityengagement.co.uk


Communicating with us

When you contact us, whether by telephone, through our website, or by e-mail, we collect the data you provide so that we can reply with the information you need.

We will record your request and reply to increase our organisation’s efficiency.

We keep personally identifiable information associated with your message, such as your name and email address, to track our communications with you and provide high-quality service.


Affiliate and business partner information.

This is information you give us in your capacity as an affiliate of us or as a business partner.

It allows us to recognise visitors you referred to us and credit you with the commission due for such referrals. It also includes information enabling us to transfer the commission to you.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the information and the terms of our relationship. 

We expect any affiliate or partner to agree to reciprocate this policy.


Cookies

Cookies are small text files that your web browser places on your computer’s hard drive when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another. Cookies allow a website to provide you with a personalised experience and provide the website owner with statistics about how you use the website so that it can be improved.

 

Some cookies may last a defined period, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose and prevent or limit their use. Our website uses cookies. These are placed by software on our servers and by software operated by third parties whose services we use.

 

When you first visit our website, we ask whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

 

If you choose not to use cookies or prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

  • to track how you use our website.
  • to record whether you have seen specific messages we display on our website.
  • to keep you signed in on our site.
  • to record your answers to surveys and questionnaires on our site while you complete them.
  • to record the conversation thread during a live chat with our support team.


Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

 

We record your geographical location, Internet service provider, and IP address. We also record information about the software you use to browse our website, such as the type of computer or device and the screen resolution.

 

We use this information in the aggregate to assess the popularity of our website’s pages and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data could be used to identify you personally, even if you are not signed in to our website.

Information we obtain from third parties.

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data indirectly derived from your personal information from third parties whose services we use.

No such information is personally identifiable to you.


Third-party advertising on our website

Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.

 

They may also use other technology, such as cookies or JavaScript, to personalise the content and measure the performance of their adverts.

We do not have control over these technologies or the data these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.


Data may be processed outside the European Union

Our websites are hosted in the United Kingdom.

We may also occasionally use outsourced services in countries outside the European Union in other aspects of our business.

 

Accordingly, data obtained within the UK or any other country could be processed outside the European Union. For example, some of our website’s software may have been developed in the United States or Australia.

We use the following safeguards concerning data transferred outside the European Union:

  • The processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.
  • The data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union [, specifically that in the United Kingdom]
  • we comply with a code of conduct approved by a supervisory authority in the European Union [, specifically that in the country of The United Kingdom]
  • we are certified under an approved certification mechanism in the GDPR.
  • both our organisation and the processor are public authorities between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to the protection of your information

Use of the site by children

We do not sell products or provide services for purchase by children, nor do we market to children.

If you are under 18, you may use our website only with consent from a parent or guardian.

Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity in your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

  • to provide you with the services you have requested.
  • to comply with other laws, including for the period demanded by our tax authorities.
  • to support a claim or defence in court.


Data Subject Rights

Individuals have the following rights regarding data processing and the data that is recorded about them:

  • Access: Individuals have the right to know what data is being collected and how it’s being used, and they may request a copy of their data.
  • Rectification: Individuals have the right to request that incorrect or incomplete data be updated.
  • Erasure: Individuals have the right to request the deletion of their data when it is no longer necessary for the purpose for which it was collected. If you wish us to remove personally identifiable information from our website, you should contact us to make your request at info@maternityengagement.co.uk. This may limit the service we can provide to you.
  • Restrict Processing: Individuals have the right to request that the processing of their data be stopped.
  • Data Portability: Individuals have the right to obtain and reuse their data across different services.
  • Object: Individuals have the right to object to processing their data in certain circumstances.


Data Security

At MEA, we take data security seriously. We will implement technical and organisational measures to ensure security appropriate to the risk, including measures to prevent unauthorised access, alteration, loss, or destruction of personal data.


How you can complain

You should let us know if you are unhappy with our privacy policy or have any complaints.

If a dispute is not settled, we hope you will agree to attempt to resolve it by engaging in good faith with us in mediation or arbitration. 

If you are dissatisfied with how we process your personal information, you can complain to the Information Commissioner’s Office (ICO). You can do this at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.



Data Breach Notification

All data breaches must be reported immediately to the DPO or relevant supervisor. If the breach is likely to risk individuals’ rights and freedoms, it will be reported to the appropriate authorities within 72 hours of discovery.


Training and Awareness

All employees and volunteers will receive training on GDPR fundamentals and this policy. Regular updates and additional training will be provided as necessary.



Document Review and Control

This policy will be reviewed annually or as required to remain current with legislative changes and MEA’s practices.

VERSION

DATE PRODUCED

DEVELOPED BY

APPROVED BY

Version 1.0

September 2022

Amanda Smith

Amanda Smith

Version 2.0

May 2024

Gbemisola Adebunmi

Amanda Smith

    
    

 

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