1. Policy Statement
1.2. The Black Country Consortium is a not-for-profit organisation established to promote and deliver economic, cultural and social well-being within the Black Country and to increase physical activity. We represent the Black Country both nationally and internationally. To achieve these objectives, it hosts a number of organisations.
1.3. Within the context of this policy where we refer to the Black Country Consortium Limited (“BCC Ltd”), we refer to BCC Ltd and its hosted organisations being
· Black Country Local Enterprise Partnership (including the Growth Hub and Invest Black Country);
· Active Black Country; and
· Black Country Skills Factory
For ease and simplicity, in this policy, reference to “we”, “our” and “us”
refers collectively to BCC Ltd and its hosted organisations.
1.4. We operate a number of websites and these are:
· Black Country Consortium Limited
· Black Country Local Enterprise Partnership
· Black Country Growth Hub
· Black Country OnTrack WM
· Active Black Country
· Active Black Country.Coaching
· Black Country Skills Factory
· Black Country manufacture your future
1.5. Full contact details for BCC Ltd and its hosted organisations is:
The Deckhouse, Waterfront West, Dudley Road, Brierley Hill DY5 1LW
2. Information that we collect from you
2.1. The information that we collect from you will vary depending upon the context of your interactions with us and the service that we are providing. It may include but is not limited to:
· Contact details to include name, address, telephone number and e-mail address;
· Image captured through filming or photography where you attend an event arranged or promoted by us or one of our partners;
· Demographic data such as your date of birth, gender, educational background and employment history;
· Family, lifestyle and social information;
· Financial details; and
· Any other information that may be collected in the course of our interactions with you
In certain cases, we may process special category information such as health, ethnicity, religion or other beliefs.
3. When do we collect your Personal Data?
3.1. We collect your personal data in the following ways:
· When you visit any of our websites and sign up to use any of our services
· When you engage with us on social media
· When you complete a form with us to provide details
· When you download or install any of our apps
· When you contact us by any means e.g. queries, complaints
· When you book on an event with us e.g. training event, sports event, networking event or seminars
· When you choose to complete any surveys that we send to you
· When you give a third-party permission to share data that they hold about you with us
· When you engage with us and complete any engagement forms to enable us to deliver a service to you
· When you provide documents to verify your identity
4. Purposes of the Processing
4.1. We collect personal data in order to deliver the best service to you. This can be to:
· Contact you by e-mail, phone or post;
· Obtain your opinion on our services;
· Understand what we can do for you and to direct you to the relevant partner or organisation that will best support you;
· Carry out research by us or third parties in order to inform our knowledge base and assist with our representation of the Black Country
· Analyse information that we collect so that we can improve the delivery of our services;
· Process financial transactions; and
· For all other purposes consistent with the proper performance of our business
We may also e-mail you about activities, events, surveys or press releases issued by our partner organisations where we think that these may be of interest you. We do not pass your personal data onto our partner organisations.
5. The Lawful bases for processing personal data
5.1. We do not capture or store any personal information about individuals who access our websites, except where you voluntarily choose to give us your personal details via e-mail or by signing up to receive our e-newsletter or other material/information from us.
5.2. We will collect and process personal data in accordance with the General Data Protection Regulation EU 2016/679 and the Data Protection Act 1998 (“the Data Protection Regulations”).
5.3. The Data Protection Regulations allow us to collect personal data in certain circumstances:
· Consent – This applies where you have given us explicit consent to collect and process your data. An example is when you sign up to receiving our e-newsletters
· Contractual Obligation – In certain circumstances, we need your personal data to comply with our contractual obligations. An example is when you may make an application for a grant or receive a grant. In this case, we require your personal details to process the transaction
· Legal Obligation - Where the processing is necessary for us to comply with the law. An example is when we may pass on personal data in compliance with a court order
· Legitimate Interest – In certain circumstances, we will process your personal data where it is in our own interest or in the interest of a third party. In such a case, we will process personal data in a way that might be reasonably expected as part of running our business and which has minimal impact on your rights and freedoms. An example is where we require your personal data to report to a funding agency of services or support provided to you.
Legitimate Interest means our interests in managing and conducting our business to promote the economic, cultural, social well-being and physical activity in the Black Country. We have an interest in addressing skills gaps for businesses in the Black Country. We also have an interest in processing your information to carry out research by us or third parties in order to inform our knowledge base and assist with our representation of the Black Country.
When we process your information for legitimate interests, we will ensure that we consider and balance any impact upon you and your rights under the Data Protection Regulations.
6. Links to other Websites
6.1. Our websites may contain links to other websites including those of our partners. If you use the links to leave our site and connect to partner’s website, you should note that we do not have any control over third-party websites. Therefore, we do not accept any responsibility for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement.
7. Information Sharing
7.1. We may share your personal data across our hosted organisations and specific third parties. We will only do so if we consider that you would benefit from a service provided by another hosted organisation. Where we share your personal data, we will only do so where your privacy is protected and respected at all times. This will include IT companies who support and host our websites.
7.2. Where you take part in any discussion groups or forums, your comments may be seen by others.
7.3. Other examples specific to our hosted organisations are:
· Growth Hub – we will share your personal data with delivery partners who provide a service to you. Our delivery partners are the Black Country Local Authorities, Black Country Chamber of Commerce and University of Wolverhampton to include focus groups established by them. In this case, business data to include personal data is shared to provide you with the best form of business support. In such a case, we will seek to have a data sharing agreement in place with our delivery partners to ensure that privacy is protected at all times.
· We will share your personal data with the Department for Business, Energy and Industrial Strategy for research and evaluation purposes only. This may include matching to other data sources to understand more about organisations like yours and general patterns and trends, although business’s data will not be published or referred to in a way which identifies any individual or business. If you have any concerns in relation to how the information you provide relating to your business in particular personal data will be processed and disclosed, please contact us. We will ensure that your privacy is protected at all times.
· Black Country Skills Factory – we will share your personal data with the Education and Skills Funding Agency, an executive agency for the Department for Education for reporting purposes so that they can meet their statutory duties. We will share your data with organisations for education, training and employment related purposes. We also pass your personal data to the European Social Fund Managing Authority or their agents who may ask you to participate in research to inform them of the effectiveness of their programmes. You may find details of how your personal data is used by visiting the following link www.gov.uk/dwp/personal-information-charter
· Active Black Country – is a Country Sports Partnership working to provide opportunities for people of all ages to participate in sport across the Black Country. As such, data that we collect from you may be shared with Sport England to fulfil the conditions of our funding agreement. Where it is possible, we will anonymise your personal data but, in some cases, we may be required to submit personal data. For example, where we are supporting school games, we are required to provide details of children attending the programmes to include age, ethnicity and disability. This enables Sport England to monitor delivery and understand who we provide a service to.
· For events organised by us, we may require medical consent forms to enable us to plan, prepare and safely meet the needs of all participants. This information will be shared with partners or organisations that deliver the event or programme on our behalf. We will not keep this information for longer than necessary and once the event or programme is completed, we shall securely dispose of this personal data.
· In some instances, we will collect images of events for publicity and promotional use. We will obtain permission from participants and/or parents or carer where this involves children. We will share this personal data with partners or organisations that will arrange to provide publicity and promotional services to us. We will not sell this personal data to any third party. If you decide that you no longer want us to use your images, please contact the HR Manager and we will deal with your request as soon as possible.
· We also run a Sports Coaching programme where we provide grants to individuals to obtain sports coaching qualifications. In these cases, we will collect your personal data in order to process the grant application. Applications are completed via our website and personal data will be shared with our web service provider. Further examples include the Young Coach Academy, where we collect data upon registering with us to ensure coaches can receive further information about the Yong Coach Academy over the course of the academic year.
· Where you attend a conference, awards ceremony, training event or any other event hosted by us, we will collect your personal data to provide this service and to obtain feedback in order for us to improve our service.
· From time to time, we will conduct surveys in order to obtain feedback on our services. In some cases, we will engage a third party to conduct the survey and we will share your personal data with this organisation for this sole purpose only.
7.4. When requested by you, we may share your information with third parties who may send you details of goods and services that may be of interest to you. For example, if you attend an event, your information may be shared with a trainer/speaker or event sponsor.
7.5. We may share your personal data with Black Country Local Authorities and other organisations that provide or manage our funding in order to meet our legal duties.
7.6. We may share your information with other partners or organisations where it is necessary either to comply with a legal obligation or where permitted under the Data Protection Regulations e.g. where the disclosure is necessary for the purposes of prevention or detection of a crime.
7.7. We do not sell your information to any organisation.
8. How long do we keep your Personal Data?
9. Transfer of Data
9.1. We store and process your personal data within the European Economic Area (EEA). We do not transfer your data outside the EEA unless that country has adequate level of data protection.
10. Your Rights
10.1. You may request a copy of your personal data. Requests may be sent to the HR Manager at The Deckhouse, Waterfront West, Dudley Road, Brierley Hill DY5 1LW
10.2. If you believe that any of the information that we hold about you is incomplete or inaccurate, please contact us as soon as possible and we will investigate your concern. If we find that the information is inaccurate or incomplete, we shall address this as soon as possible.
10.3. When you have given us your consent to use your personal data, you have the right to withdraw your consent at any time
10.4. You have the right to object to profiling or any decisions made by us by automated means
10.5. You have the right to stop the use of your personal data for direct marketing activity at any time
10.6. If you feel that your data has not been handled correctly or you are unhappy with any response from us, you have the right to lodge a complain with the Information Commissioner. The contact details can be found at www.ico.org or you can call 0303 123 1113