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Privacy Policy

Newid is a collaboration between Wales Council for Voluntary Action (WCVA) ,
Cwmpas and ProMo-Cymru (referred to in this notice collectively as “we” or “us”
or “the partnership”).

Newid promotes good digital practice across the third sector in Wales. We do
this by providing training, support and information.

In order to meet this goal we have collaborated on the development of two
databases (the Databases). One is a Participant Database System (PDS) (CRM)
system which we can use to store details of the organisations and participants
that we work with and record any interactions between us and these
organisations and the other is the newid.cymru website that is our primary
communication mechanism.

We can also record contact details for people who are interested in our work,
whether as individuals or on behalf of their organisations and use the PDS
system to manage our communications with them. The databases are separate.

We have developed this privacy notice in order to be as transparent as possible
about the Databases and the personal information contained within them. This
privacy notice has been written for the individuals whose personal information is
contained in the Databases (referred to in this notice as “you”). We treat data
privacy very seriously and comply with all aspects of the UK’s data protection
legislative framework which includes the European General Data Protection
Regulation (GDPR) and the UK’s own legislation.


What information does this privacy notice contain?

We ask that you read this privacy notice carefully as it contains important
information about:

  • what personal information is stored in the Databases
  • how and for what purposes the personal information held in the
    Databases is used (this is known as processing);
  • the lawful basis for such processing;
  • how and from where we collect your personal information;
  • who has access to the information contained in the Databases;
  • third parties with whom we may share your personal information;
  • how long we keep your personal information;
  • how you can manage your communication preferences; and where to find out more information about your privacy rights.

Data Controller

Although the Databases are managed by WCVA, the information in the
Databases is held on behalf of the partnership. We are joint data controllers of
the personal information contained in the databases. We have entered into a
Memorandum of Understanding (MOU) that governs our relationship in
connection with the Databases.

Each of the organisations that has signed up to the MOU has appointed a
contact who is responsible for the Databases. Full details of the organisations
and how to contact them can be found here.


Categories of Personal Information

The following categories of personal information are held in the Databases:
 first and last name
 your preferred salutation
 organisation
 job title
 contact address(es)
 contact email addresses(es)
 contact telephone number(s)
 details relevant to your search

 details of your interests in the third sector and communication
preferences
 your language preference (Welsh or English)
 Any accessibility requirements
We also keep details of any access requirements , if you have provided these to
us voluntarily.


What is the Personal Information Used For?

The main purpose of the Databases is to enable us to manage our
communications with people and organisations that wish to hear from us. Using
the personal information in the databases we can send communications that we
think will be of interest to you by email. The use of the shared central Databases
avoids unnecessary duplication. The Databases also have a facility which enable
you to manage the communications you receive more effectively.

We can also use the Databases to provide insight and analysis to help us to
continually improve the effectiveness of our communications, develop the
products and services we offer our member organisations, monitor the reach of
our communications and the diversity of the recipients and provide reports to
funders and regulators.


Sources of Information

The information contained in the Databases may be added to with information
that has come from a variety of sources including:
 information obtained directly from you
 information collected at events or training courses that we run
 information that is generated by us and recorded in the Databases, such
as your interests and communication preferences

The Legal Basis

We will only store your personal information in the databases where we can do
so lawfully. The data protection legislative framework provides for a limited
number of reasons for processing personal information.

We are relying on the following lawful bases to process general information:
 where we have your consent
 where our processing of your personal data is in the public interest
 where our processing of your personal data is necessary for our legitimate
interests or those of a third party and are not overridden by your privacy
rights.


In this case the legitimate interests are those of WCVA , Cwmpas and ProMo-
Cymru who have signed up to the MOU who wish to communicate with
interested people and organisations about their work and the services they
offer. We also have the legitimate interest of wishing to share resources and
work collaboratively by having effective central databases. We believe that this is
also in the public interest.

Your privacy rights are protected because the Databases store only basic
information about you, there is a strict protocol of who can access your personal
information and you have the ability to control your communication
preferences. You can also object to us storing and using your personal
information at any time as outlined below.

The data protection legislative framework contains specific provisions that
enable us to process information about your gender, racial or ethnic origin and
physical or mental health or condition in order to monitor diversity on an
anonymised basis.


Who can access your Personal Information

Although the Databases are a collaboration, not all staff members of the
partnership can access and use your personal information.

We have established a strict protocol, contained in the MOU, to ensure your
information is only accessed and used by partnership staff where:
 you have an existing relationship with the relevant partnership staff
member that predates the development of the Databases
 you have consented to receiving communications from the relevant
partnership member
 the partnership member has a specific legitimate interest in using your
information because for example, they are running an event in the area in
which you live or work


As WCVA are responsible for managing the Databases, a small number of WCVA
staff can access all of the information contained in the Databases.


Sharing your personal information with Third Parties

This section of the privacy notice provides details of third parties with whom we
may share the personal information contained in the Databases.

The Databases are hosted by third parties called Ghost Ipswich Software (IPSoft)
and Tripetto. Although they have access to the information in the Databases in
order to ensure that they are working effectively at all times, they are not
permitted to use the information for any reason.

We may also run anonymised aggregated reports off the databases and share
these with the Welsh Government. These reports may also be published. We will
not share your personal information with these bodies however or give them
access to the “raw” data on which the reports are based. The partnership may
appoint an external researcher to help us with this work, who would have access
to the information contained in the Databases.

The partnership may also appoint an internal or external evaluation to assess
the effectiveness of the Databases. The evaluator would have access to the
personal information contained in the Databases, but would not be able to use
any of the information.

We do not transfer personal information contained in the Databases outside the
European Economic Area (EEA). None of the service providers we use to help us
provide the Databases are based outside of the EEA.

Your Communication Preferences

The Databases offer us functionality that enables you to determine your
communication preferences, both with regard to the format of the
communication, the topic and which organisations you would like to hear from.
Please visit the link on the communication received to update or amend your
communications preferences at any time. Please note that it may take up to a
week for any changes to be processed.


Cookies

Cookies are files saved on your phone, tablet or computer when you visit a
website.

The newid.cymru website does not currently use any cookies.


How long we will keep your personal information

The data protection legislative framework places an obligation on us to review
the length of time for which we keep personal information. We are only able to
keep your personal information for as long as it is necessary for us to do so. We
appreciate that users may use the newid.cymru website infrequently as their

requirements evolve therefore we will keep users accounts active for 3 years
since their last activity.  


Individual Rights

You have a number of rights in relation to the personal information held in the
Databases. If you wish to exercise any of the rights, please contact WCVA in one
of the ways mentioned below.
 You have a right of access the personal information we hold about you
 You have the right to correct any information we have about you that you
think is wrong or incomplete
 You have the right to object to our use of your personal information for
direct marketing purposes. If you no longer want to receive
communications from us, please contact us. We will stop sending you
communications, but will continue to keep a record of you and your
request not to hear form us.
 You have the right to ask us to delete your information. You should be
aware that if we do this, we will have no record of the fact that you have
asked not to receive communications from us. It is therefore possible that
you may start receiving communications from us at some point in the
future, if we obtain your details from a different source.
 Where our processing of your personal information is based on your
consent, you have the right to withdraw it at any time. Please contact us if
you want to do so.


Contact Details

DPO@wcva.cymru


How to Complain

Please let us know if you are unhappy with how we have used your personal
information.

You also have the right to complain to the Information Commissioner’s Office.
Find out on their website how to report a concern here.


Changes to this Privacy Notice

This privacy notice was last updated on 10 July 2023. We keep this privacy notice
under regular review and may change it from time to time by updating this page
in order to reflect changes in the law and/or our privacy practices. We would
encourage you to check this privacy notice for any changes on a regular basis.