NOW Group is committed to maintaining high standards in data protection and ensuring the privacy and security of your data. This privacy notice aims to provide you with information on how we gather, process and store your data in a concise and accessible format and therefore does not give full details of how we process your data. If you require any further detail on any aspect of this notice please contact our designated Data Protection Officer on dpo@nowgroup.org

 

Who are we?

Now Group provides a range of services that support people with learning difficulties and autism to realise their full potential and change their lives for the better. Our services focus on supporting people into employment, training, transition and volunteering and includes a family service to support new parents with a learning difficulty or autism. We also offer a range of solutions to businesses including corporate catering, recruitment and supported employment, social impact measurement and disability awareness customer service training.

 

NOW Group is registered in Northern Ireland. Charity number: XR23504 / Company number: NI043774

 

What is this notice?

In order to provide our Services, we may need to process Personal Data from time to time (that is information about someone who can be identified from the data). This Personal Data may be about you or other people. This notice explains how we will use the Personal Data we hold. 

 

A separate notice specifically aimed at our participants is also available if you would like a copy please visit our website or contact our Data Protection Officer at dpo@nowgroup.org

 

What personal data do we collect?

 

• Business contact information - If you provide us with goods or services or if you purchase goods or services from us we will collect the data from you that is necessary to carry out those transactions. This will include contact details, invoicing details, insurance details (for associates) and payment details where relevant.

• Café customer contact details (Covid 19 Contact Tracing) To meet Public Health Agency requirements for contact tracing during Covid 19 period we will collect name and telephone number and time of arrival of lead customer for all café sit in transactions unless these details have already been collected by host venue.

• Participant information - If you participate in any of our services we will collect contact details, education and employment history and in some cases medical or disability information where required to provide you with appropriate support. See Participant Privacy Notice for details.

• Job or volunteer applicant information - If you apply to work or volunteer with us we will collect contact details, education and employment history, references, equality monitoring information and details of unspent criminal convictions as relevant. We may need to confirm your identity for Access NI checks depending on your potential role in the organisation.

• Supporter Information - If you provide support to our participants by acting as a referral agent or offering work or voluntary placements we will collect contact details from you to enable us to communicate with you.

• Parent/carer information - If you have provided us with your details as a parent/carer of one of our participants we will retain your contact details in order to contact your for consent or in emergencies as relevant.

• Records of your interactions with us - this includes emails, meeting notes and details of the services we have provided to you or received from you.

 

Photographs or videos of events or activities -for use in printed and electronic media to promote our services.

• Quality monitoring information - we will collect data on your responses to our quality monitoring surveys. This information will only be gathered and stored with your consent.

• Marketing contact information - we will hold contact details in order to provide you with updates on our services. We will only hold this information for this purpose with your consent.

 

 

Information we collect from other sources -

• Survey Responses - We use Survey Gizmo to obtain feedback from you on the quality of our services. You can read Survey Gizmo's privacy notice here.

• Electronic Newsletters - We use Mailchimp to send newsletters to subscribers. You can read Mailchimp's privacy notice here.

• Standard internet log information such as your IP address and visitor behaviour patterns. We use Google Analytics to analyse website traffic. You can get more information on  Google's security and privacy principles here.

• User account records for our JAM Card app - we collect only contact details all other details such as usage and information on medical conditions is anonymised and cannot be connected with an individual user. Check the privacy policy for the app here.

• JAM Card E Learning Website – we collect the names of individuals who have completed the JAM Card training as evidence of completion. 

                                                                                                                            

How do we collect this data?

 

We collect your data when -

• You register to participate in our services

• You provide support to our participants through offering placement or referral opportunities

• You order goods or services from us

• We procure goods or services from you

• You apply for a job or volunteering opportunity with us

• You subscribe to our electronic newsletters

• You visit our website

• You register for our JAM Card app

• You register to complete JAM Card E learning course

• You attend one of our events

• For purposes of Covid 19 contact tracing only when you pay for sit in refreshments in Loaf Cafes unless the details have already been collected by the host venue. Only lead customer details are collected.

 

How do we use your personal data?

 

We use your personal data to 

• Provide you with goods or services

• Contact you for feedback or updates on our services

• Pay you for goods or services procured 

• Support our recruitment processes

• Connect you with our participants or connect our participants with you as relevant

 

Do we share your personal data?

 

We will not normally share your data with others with the exception of the following circumstances:

• On occasion our funders request access to contract/tender information to ensure that we are undertaking procurement in a fair manner. This could include all contract information. We have a legal obligation to share this with the funder if requested.

• We use external survey and newsletter services with your consent to contact you for quality monitoring and marketing. Details of the privacy notices for these services is available above.

• During Covid-19 restrictions we are required to share personal data of café customers with the Public Health Agency on request for the contact tracing service.

 

If you have any questions about who your data might be transferred to please send us an email at dpo@nowgroup.org

 

The lawful basis for processing your personal data

• Where we carry out transactions with you in the sale and procurement of goods and services we will use that contract as the lawful basis

• Where you have subscribed to our newsletters or agreed to be contacted for quality monitoring purposes we will use the consent that you give us as the lawful basis.

• For some financial transactions particularly relating to taxation, accounting legislation and equal opportunities monitoring we will use legal obligation as the lawful basis.

• The lawful basis for holding Personal data collected as required for Covid 19 contact tracing is that the processing is a legal obligation.

 

 

Security and retention of your data 

It is our policy to ensure that all personal data held by us is handled correctly and appropriately according to the nature of the information, the risk associated with mishandling the data, including the damage that could be caused to an individual as a result of loss, corruption and/or accidental disclosure of any such data, and in accordance with any applicable legal requirements.

 

We aim to hold the minimum amount of data needed to provide services to organisations and individuals. We have a data retention policy to ensure that we do not retain your data longer than necessary and that we dispose of it safely. In some cases ie accounting records, equal opportunities monitoring, and information required by our funders we are legally obliged to abide by statutory  retention periods.

 

Where we use external services and cloud services to store personal data we have assurance that these providers are fully compliant with relevant data protection legislation.

 

What rights do you have in relation to the personal data we hold?

 

You have the following rights in relation to the personal data we hold -

• Right to be informed: the right to be informed about what Personal Data the Controller collects and stores about you and how it’s used.

• Right of access: the right to request a copy of the Personal Data held, as well as confirmation of how we process your data

• Right of rectification: the right to require us to correct any Personal Data held about you which is inaccurate or incomplete.

• Right to be forgotten: in certain circumstances, you have the right to have your Personal Data erased from our records. 

• Right to restriction of processing: the right to ask us to restrict the processing carried out in respect of your data.

• Right of portability: the right to have your Personal Data transferred to another organisation in certain circumstances

• Right to object to direct marketing: the right to object where processing is carried out for direct marketing purposes (including profiling in connection with that purpose).

• Right to object to automated processing: the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects (or other similar significant effects) on the Data Subject.

 

If you wish to avail of any of these rights please contact dpo@nowgroup.org 

 

Cookies and Analytics

A cookie is a small text file that contains information a website transfers to your computer’s hard disk for record keeping purposes and allows us to monitor our site traffic patterns. Cookies tell us what website pages people visit and give us insight to help us improve our communications. We do not store any personal data.

 

Changes to this Privacy Notice

We may change this privacy notice to comply with changes in the law or changes in how we operate. We will alert stakeholders through our website and other channels if we make any significant changes.

 

Who do I complain to if I am not happy with how you process personal data about me?

 

If you have any questions or concerns about how we are using Personal Data about you, please contact our Data Protection Officer immediately at our registered address (see paragraph 1.1 above) or by email to dpo@nowgroup.org. 

 

If you wish to make a complaint about how we have handled Personal Data about you, you may lodge a complaint with the Information Commissioner’s Office by following this link: https://ico.org.uk/concerns/.