The statement will pertain to all parties unless otherwise stated.
We care about your privacy and are committed to protecting your personal data. Here are our joint promises to you:
- To only collect personal information from you when it improves your experience of the
- To ask for and record your consent for collecting personal information.
- To never sell your personal information to third parties.
- To explain why we are asking for personal information when we ask for it (unless it is obvious).
- To protect your data and store it safely.
- To respect your wishes and rights in regard to our storage of your data.
Please do not send your requests for support and help for health and wellbeing services in Cornwall to the platform technology providers, Made Open.
In addition, and further to the promises above, Age UK Cornwall & The Isles of Scilly promise:
- To only collect anonymised data for reporting and bids to share with only trusted third parties, such as registered organisations or funding bodies which we have a connection. This allows us to improve the services Age UK Cornwall & The Isles of Scilly provides through collaboration and our partnership with Inclusion Matters.
- To only collect personal information from you when you request support or help from us with your consent. This information will be passed internally and securely to our Inclusion Matters helpline and/or community coaches.
- To not send on marketing communications unless you have opted in to them. The only communications we will send you will be in regard to major updates to Cornwall Link or about your listing or membership, as agreed in the Terms and Conditions.
Our address is:
School House Office,
Market Street, Devoran,
You can contact us by emailing firstname.lastname@example.org or phoning us on +44 (0)1872 862547.
We are a limited company registered in England and Wales (our registration number is 4309700). We are also registered with the Information Commissioner’s Office for data protection purposes (our registration number is Z2818556).
All data captured via our platform is securely stored with our internet hosting provider Cloud Above Ltd, of:
1 King Mark House,
Made Open have licenced this platform to Age UK Cornwall & The Isles of Scilly of:
Chapel Hill, Truro,
Age UK Cornwall & The Isles of Scilly are a registered charity.
Made Open are delivering this service to Age UK Cornwall & The Isles of Scilly, who are using this platform to deliver Cornwall Link.
All the personal data we collect is outlined in the table below:
|Data type||What this means|
|Location data||Your neighbourhood or region (optional)|
|Marketing data||Your public profile (optional)|
|Activity data||Activity information (automatic)|
|Exchange data||Additional data required to join the timebank (mandatory)|
We also collect, use and share “aggregated data” such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but it will not constitute personal data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity.
No special categories of personal data
We do not collect any “special categories of personal data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
You are able to tag categories, such as health data, to your personal profiles, which you may want to keep private from public view – the platform offers this feature should you need or want to use it. Some personal data will still be available on public view such as your name and occupation.
The data controllers (Made Open and Age UK Cornwall & The Isles of Scilly) will still be able to access the data attached to your profile if you make it private; however, we will not collect or use personal data for any reason. The data controllers may need to access your profile data to help you with site assistance and the tags help us with anonymised data reporting.
We will only use your personal data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
What is our “legal basis” for processing your personal data?
The General Data Protection Regulation (GDPR) requires us to ensure that we have a legal basis for using your personal data. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests (“Legitimate Interests”). More detail about the specific legitimate interests we use your personal data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the purpose in question (“Consent”).
Generally, we do not rely on your consent as a legal basis for using your personal data (other than in the context of direct marketing communications).
Made Open have organised a table set out below to cover the legal bases we rely on in respect of the relevant purposes for which we use your personal data:
|Purpose||Categories of personal data involved||Why do we do this||Our legal basis for this use of data|
|Registering an account||
Identity and contact data:
|Setting up your profile||
Identity and marketing data:
|To raise your profile to other users of the platform.||Legitimate interest|
|Setting up your Best Match||
To quickly match you to relatable activities and members using the ‘Best Match’ button.To allow you to share some or all of your location, skills and interests onto your public profile.
Activity and contact data:
To describe your activity in more detail and enable other members or a platform administrator to contact you.
|To let you manage your connections.||Legitimate interest|
|Joining the exchange||
|To help the platform administrator determine whether you are eligible to join the exchange.||Legitimate interest|
Identity, contact, behavioural and marketing data:
In addition, and further to the points above, Age UK Cornwall & The Isles of Scilly - the site maintainers - may process your personal information under a ‘legitimate interest’ lawful basis. Whenever we do so, we take into account your rights and interests and will not process your personal information if we feel that there is an imbalance. Some examples of where we have a legitimate interest to process your personal information are where we contact you about our work via post, use anonymised personal information for data analytics, conducting research to better understand who our supporters are, improving our services, for our legal purposes (for example, dealing with complaints and claims), or for complying with guidance from the Charity Commission.
We may use your information to:
Cornwall link users:
- recommend services and activities/groups
- provide you with information or services that you have requested from us or which we feel may interest you, if you have given us consent to get in contact with you
Cornwall Link contributors:
- add and manage your listing or volunteering opportunity.
- sharing you listing with Cornwall Link users.
- carry out any requests or obligations arising from any contact you may have with us
- enable you to participate in any interactive features our service offers, as and when you choose to do so
- notify you of any changes to our service
- keep a record of your relationship with us
- seek your views / comments on our listings in order to improve them
We will not share your information with third parties for marketing purposes.
It may be necessary to pass your information to a 3rd party with your consent (e.g. if you wish to volunteer for another organisation via the Site, when you ask our Helpline to pass your contact details on to a group, or with your consent; for the purposes of evaluating your progress with your GP or other professional). We will only share the necessary personal information in these cases. In most circumstances you will pass your own details on to services and activity providers yourself
We will not sell or rent your information to third parties.
Your information will be used for the purposes described. Third parties will only receive personal information about you when you have consented or when protecting our legitimate business interest (Made Open) or registered charity interest (Age UK Cornwall & The Isles of Scilly). Scenarios where we may disclose your personal information include:
- When sharing it with our employees to improve the platform’s user experience or where you have identified a request for help or assistance in accessing support.
- When required to do so by law or required by safeguarding practices.
- In the event that Made Open sell our business or business assets.
- In the event that Age UK Cornwall & The Isles of Scilly need to move the management of Cornwall Link to one of our community partners and/or an external agency.
- In order to establish, exercise or defend our legal rights.
- To protect the rights, property or safety of Made Open, Age UK Cornwall & The Isles of Scilly, our clients, or others.
Except as described, we will not provide or sell your personal information to third parties.
The table below describes who we share your personal data with (including ourselves), what we share and why we share it. We do not and will not transfer your personal data to any parties located outside the European Economic Area.
|Who we share data with||What we share||Why we share it|
|Made Open Communications Ltd||
For the purposes of the General Data Protection Regulation (GDPR) and Data Protection Act 1998, the data controller responsible for collecting information is Made Open.
Age UK Cornwall
Made Open have licenced this platform to Age UK Cornwall.
This personal data enables associates of Age UK Cornwall to perform their duties as platform administrators.
|Cloud Above Ltd||Technical data||
All data captured via our software service is securely stored with our internet hosting provider Cloud Above Ltd.
We – the site maintainers - may also share anonymised data to our Inclusion Matters partners, agencies with which we collaborate and funding bodies.
We respect people’s data and take care to ensure that your personal data is stored safely and securely. We store all your personal information on our secure UK based servers, which:
- Use strong password protection.
- Have regular security patches and system updates.
- Have an industry standard Firewall policy.
- Use authentication.
- Apply user auditing.
We have industry recognised security measures in place to prevent our platform from being hacked including: password hashing and salting, SQL injection projection techniques applied to all data input forms, regular updates and security reviews.
Transmitting information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the site. Any transmission is at your own risk.
You are responsible for keeping your password and user details confidential. We will not ask you for your password (except when you log in). We ask you not to share your password with anyone.
We will only retain your personal data until either of the following happens (or unless a longer retention period is required by law):
- You decide to delete your account.
- You wish to enact your right to be forgotten.
- The website is terminated.
By law you have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you; for example, if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent. This right only exists where we are relying on consent to process your personal data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our platform. We will advise you if this is the case at the time you withdraw your consent.
This relates specifically to the site maintainers (Age UK Cornwall & The Isles of Scilly) who populate, manage and approve content for the site.
Information can be gathered in the following ways:
- Following your registration to the platform and completion of the forms on site.
- A request given into our Helpline, community coaches or partners. They will be passed onto the relevant staff member to complete, which may involve adding information to the site with your consent.
- From email communications or public service announcements, forums and sites, whereby the information is already in the public sphere. All information will be accredited to their owner and communications will be made to allow individuals to check the information and/or claim this content via registration wherever possible. We cannot guarantee a timeframe of this notification. If you do not wish to be included in the database, please contact us to delete the information.
- This platform is not intended for children below 16 and we do not knowingly collect data relating to such children.
- If you do not want information on your profile about you public-facing, you have the option to keep this information private.
Age UK Cornwall & The Isles of Scilly follow a strict procedure for flagging safeguarding issues to the appropriate agencies for investigation. If you notify us of a personal safeguarding issue, we will be responsible for logging an incidence, even if you have not given us your permission to do so. The incidence will be investigated.
If you are acting on behalf of someone else, we will signpost you to the appropriate agencies to log a safeguarding incidence and we are happy to provide advice if required. We, however, can not act on your behalf to make the safeguarding log due to the fact you are the witness.
As the safeguarding issues vary, we will be tracking the issues accordingly and will discuss with our safeguarding officer.
If the incidence involves a crime, we will contact the authorities immediately.
Personal data from third parties
- This platform does not currently collect any personal data from third parties. For members joining our exchange, we may reference check you from third party sources. This will only be done with your permission, using the references you have provided. This is to protect your and our (as a collective) legitimate interests - allowing you to make exchanges freely once authorised, and allowing us to provide an extra safeguarding check for the benefit of all our members.
- We may collect information from public sources.
What happens if we need more personal data?
- Where we need to process your personal data either to comply with the law, or to meet the terms and conditions of use we have with you, and you fail to provide that data when requested, we may have to stop you using our platform. We will notify you if this is the case at the time.
From the platform owners:
- This platform does not and will not send out any marketing messages from third parties. You can ask us to stop sending you marketing messages at any time by signing into the platform and checking or unchecking relevant boxes to adjust your marketing preferences and / or by following the opt-out links on any marketing messages sent to you.
- Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of use of our platform.
From the site maintainers:
- Age UK Cornwall & The Isles of Scilly will only communicate directly with you in limited circumstances when required to update information on Cornwall Link or inform you of site changes. However, you have the right to opt out of receiving communications from us at any time by contacting the Helpline on 01872 266388 or email@example.com or by contacting Cornwall Link Digital directly on the platform. You can also use these methods to change the way we contact you at any time. In order to opt out of receiving communications, it is necessary to retain some of your details to ensure we don’t contact you again in the future. Your details will only be used for this purpose.
- We may supply a newsletter for Cornwall Link members to update users of content on the site or member news. You have the right to opt in and out of this as you see fit, and you will not be added to the list unless you have given express permission to be included in the mailing list.
- If you want to exercise any of the rights described above, please contact us by emailing firstname.lastname@example.org and email@example.com
- Typically, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
- We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.