Privacy and Data Protection Statement

1. GDPR

The EU General Data Protection Regulation (GDPR) effective from May 2018 gives all EU citizens more rights and protections for their personal data, to minimise the possibility of theft and fraud.

These regulations include provisions for the following areas:

• The right to be informed: Organisations must publish a privacy notice, in addition to explaining transparently how they use this personal data.
• The right of access: Individuals will have the right to demand details of any of their data that an organisation may hold. This information must be provided within one month of request at no charge to the individual.
• The right to rectification: If a person’s data is incorrect or incomplete, he or she has the right to have it corrected. If the organisation that holds the information has passed any of that information to third parties. The organisation must inform the third party of the correction and inform the person which third parties have their personal data.
• The right to be forgotten: A person may request the removal of his or her personal data in specific circumstances.
• The right to restrict processing: Under certain circumstances, an individual can block the processing of his or her personal data.
• The right to data portability: A person can access their data for their own use anywhere they prefer.
• The right to object: A person can object to the use of their personal data for most purposes.

a) Our core principles regarding user privacy and data protection

• User privacy and data protection are inviolable human rights
• We have a duty of care to people contained within our data
• Data is a liability: it should only be collected and processed when absolutely necessary
• We despise spam in all its forms
• We will never sell, rent or otherwise distribute or make public any personal information

b) Relevant legislation

Alongside our business and internal computer systems, the BHIMS website is designed to comply with the following national and international legislation with regards to data protection and user privacy:

• UK Data Protection Act 1988 (DPA)
• EU Data Protection Directive 1995 (DPD)
• EU General Data Protection Regulation 2018 (GDPR)

2. Data Protection Act

In carrying out our day to day activities BHIMS process and store personal information relating to our supporters and we are therefore required to adhere to the requirements of the Data Protection Act 1998.

BHIMS takes its responsibilities under this act very seriously and ensures personal information we obtain is held, used, transferred and otherwise processed in accordance with that Act and all other applicable data protection laws and regulations including, but not limited to, the Privacy and Electronic Communication Regulations.

3. This website collects and uses personal information for the following reasons:

3.1 Forms and email links

Should you choose to contact us using the contact form or an email link like, none of the data that you supply will be stored by this website or passed to be processed only by any of the third party data processors defined in section 4 below.

Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.

We use online forms to help you contact us. The information collected by these forms is send to us via email and stored in the website’s database, long enough to enable us to manage our processes.

If the form includes a payment, some information will be passed onto out third party data processors, CAF (see section 4 below). In these cases we will also store your computers IP address to help protect against fraud.

We delete any information when it is no longer needed.

4. Credit, Debit card payment information

We use CAF online Bank to process personal data on your behalf. CAF online bank process payments from CAF online bank for any services or products purchased.

Supplier Financial information is retained by CAF online bank. We do not retain supplier financial information in other format as part of the purchasing process.

CAF online bank monitors every transaction, 24/7 to prevent fraud, email phishing and identity theft. Every transaction is heavily guarded behind CAF online bank's advanced encryption. If something appears suspicious, their dedicated team of security specialists will identify suspicious activity and help protect you from fraudulent transactions.

Security includes:

• Text Alerts to us
• Secure Websites
• Inactivity Timeouts after log in by us
• Secure Identification and Log in
• Up to date technology

Your data as mentioned below is encrypted before transmission to prevent misuse of the transmitted data by third parties. Secure Socket Layer (SSL) is a security technology which guarantees that your personal data, including bank account information, login data and
payment method, are securely transferred via the Internet. The data is encrypted so that is only readable by the CAF online bank’s payment system.

Your data which is encrypted, is as follows:

• personal data (address data, telephone number, etc.)
• login data (username and password)
• all methods of payment selected, credit card and bank account

CAF online bank has been carefully chosen as it complies with the legislation set out in section 2.0.

5. Information sharing and disclosure

We will not sell or swap your information with any third party.

We may share your information with our data processors. These are trusted partner organisations that work with us in connection with BHIMS.

All our trusted partners are required to comply with data protection laws and our high standards and are only allowed to process your information in strict compliance with our instructions. We will always make sure appropriate contracts and controls are in place and we regularly monitor all our partners to ensure their compliance.

We may disclose your personal information to third parties if we are required to do so through a legal obligation (for example to the police or a government body); to enable us to enforce or apply our terms and conditions or rights under an agreement; or to protect us, for
example, in the case of suspected fraud or defamation.

We do not share your information for any other purposes.

6. The accuracy of your information

We aim to ensure that all information we hold about you is accurate and, where necessary, kept up to date.

If any of the information we hold about you is inaccurate and you advise us or we become otherwise aware, we will ensure it is amended and updated as soon as
possible.

7. Storing your information

Although most of the information we store and process stays within the UK, some information may be transferred to countries outside the European Economic Area (EEA).

This may occur if, for example, one of our trusted partners servers are located in a country outside the EEA. These countries may not have similar data protection laws to the United Kingdom (UK) however, we will take steps with the aim of ensuring your privacy continues to be protected as outlined in this privacy policy.

We will keep your information for as long as required to enable us to operate our services but we will not keep your information for any longer than is necessary. We will take into consideration our legal obligations and tax and accounting rules when determining how
long we should retain your information. When we no longer need to retain your information we will ensure it is securely disposed of at the appropriate time.

Our websites use cookies to help them work well and to track information about how people are using them. More information on cookies can be found below.

For all areas of our website which collect personal information, we use a secure server. Although we cannot 100 per cent guarantee the security of any information you transmit to us, we enforce strict procedures and security features to protect your information and
prevent unauthorised access.

Our website contains links to other websites belonging to third parties and we sometimes choose to participate in social networking sites including but not limited to Twitter and YouTube. We may also include content from sites such as these on our website however, would advise that we do not have any control the privacy practices of these other sites.

You should make sure when you leave our site that you have read and understood that site’s privacy policy in addition to our own.

9. Cookies

What are cookies?

Cookies are small text files that are placed on your computer by websites that you visit.

They are widely used in order to make websites work, or work better, as well as to provide information to the owners of the site. A cookie often contains a unique number, which can be used to recognise your computer when a user of your computer returns to a website that
it visited previously.

How does BHIMS use cookies?

We use cookies to enhance the online experience of our visitors, to better understand how our websites are used.

Your rights

Our cookies do not store financial information or information which is capable of directly identifying you (such as your name or address). You have the right to choose whether to accept these cookies.

You can exercise this right by amending or setting the controls on
your browser to reflect your cookie preferences. However, please note that if you choose to refuse cookies you may not be able to use the full functionality of this website.

Changing your cookie preferences

The "Help" menu in the toolbar of most web browsers will tell you how to change your browser's cookie settings, including how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether.

An online guide is available if you have difficulties trying to change your browser settings.

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-managecookies

Cookie terminology

• We have classified our cookies into two broad types - 'first party cookies' and 'third partycookies':
• We use Google Analytics cookies which help us monitor the site and improve it to make your experience better.
• We also use some social media cookies which allow you to interact with our website through various social media sites such as Facebook, Twitter and You Tube.

Our content management system will also set cookies without which the site could not function.

In addition, cookies may be either 'session cookies' or 'persistent cookies'. Your computer automatically removes session cookies once you close your browser. Persistent cookies will survive on your computer until an expiry date specified in the cookie itself, is reached.

We do not use third party cookies that track your usage this and other websites to serve advertising.

10. Data breaches

In the event of a breach of security leading to the accidental or unlawful destruction, loss,
alteration, unauthorised disclosure of, or access to, personal data, the BHIMS shall promptly assess the risk to people’s rights and freedoms and if appropriate report this
breach to the ICO (more information on the ICO website).

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/personal-data-breaches/

11. Changes to the policy

This policy replaces all previous versions and is correct as of the date at the end of this web page.

We will regularly review and update this Privacy and Data Protection Statement and will update, modify, add or remove sections at our discretion. Any changes will be notified to you through on this page. Your continued use of our website, any of our services and/or
the continued provision of personal information after we have posted the changes to these terms will be taken to mean you are in agreement with those changes.

12. Your rights

You have the right to:

• request a copy of the information we hold about you
• update or amend the information we hold about you if it is wrong;
• change your communication preferences at any time;
• ask us to remove your personal information from our records;
• object to the processing of your information for marketing purposes; or raise a
  concern or complaint about the way in which your information is being used.

If you wish to find out more about these rights, or obtain a copy of the information we hold about you, please contact our Data Controller:

Service Manager
Brighton & Hove Independent Mediation Service
Ecclesden
Grove Hill
Brighton
BN2 9NG

01273 700812

[email protected]

If you have any questions or queries about this Privacy and Data Protection Statement,
please contact our Data Protection Officer / Data Controller using the above address and
contact details.