* Better and GLL adopt the following definition of a ‘volunteer’: ’ A person who does voluntary work on our behalf. It is undertaken by choice and is unpaid.’
1.0 Introduction
1.1 Greenwich Leisure Limited is a is a charitable social enterprise and registered society under the Co-operative & Community Benefit and Societies Act 2014 registration no. 27793R and our registered head office is Middlegate House, The Royal Arsenal, London, SE18 8SX.
1.2 GLL also trades under the name of “Better”, “North Country Leisure” (NCL) and “Gosling Leisure Limited”.
1.3 We are ‘controllers’ of the information that we collect from or about our staff, known as ‘personal data’. As controllers, we are responsible for the security and processing of that data. This Privacy Notice explains why and how we process your data.
1.4 The word ‘process’ covers most things that can be done with personal data, including collection, storage and destruction of that data.
1.5 Our Data Protection Officer (DPO) is Mr Philip Donnay whom you can contact through privacy@gll.org or at the above registered address or if you have any queries about this notice or any other matter relating to data protection.
2.0 Your personal data
2.1 Personal data is any information that relates to a living, identifiable person. This data can include your name, contact details, and other information we gather as part of the registration
2.2. Personal data can also include ‘special categories’ of data, which is information about a person’s race or ethnic origin, religious, political or other beliefs, physical or mental health, trade union membership, genetic or biometric data, sex life or sexual orientation. The collection and use of these types of data is subject to strict controls. There are also limitations on the way information about criminal convictions and offences can be processed.
2.3 As part of any volunteer recruitment process, GLL collects and processes personal data and special categories of data, relating to volunteer opportunities. GLL is committed to being transparent about how we collect and use that data and to meeting our data protection obligations.
3.0 The personal data collected by GLL
3.1 GLL collects and processes a range of personal information about you, which we categorise in the following way:
| Category | Examples |
|---|
| Basic personal information | Name, address, phone number, email address, date of birth, your availability to volunteer |
| Volunteer recruitment | Interview notes, evidence of skills and qualifications |
| Equality monitoring information | Age, disability, sex, race |
| Right to work information | Passport and visa details |
| Criminal convictions and offences | ID documents to process Disclosure and Barring Service checks |
| Health and disability information | Details of any disabilities for which we need to make reasonable adjustments |
| References | References supplied by previous employers or people known to you |
3.2 GLL collects this information through our volunteer management system. We collect personal data about you when you register on our volunteer management system, through personal data being entered or documents such as qualifications being uploaded. We also collect ID documents in order to process DBS checks when required.
4.0 Reasons for processing personal data
4.1 GLL needs to process most of your personal data in order to process your application to volunteer with us. In some cases, GLL needs to process some of the personal data to ensure that we are meeting our duty of care. For example, we may need to check that you are entitled to work in the UK.
4.2 GLL processes other elements of personal data because we have a legitimate interest in ensuring that volunteers are suitable for the role they wish to undertake. For example we process data about volunteer’s skills and experience to ensure we consider the best candidates for roles.
4.3 There is also a substantial public interest that permits the processing of certain personal data. An example is monitoring for the purposes of equality of opportunity and treatment. This data is not used to take action or make decisions about individuals. You are free to decide whether or not to provide the information and there are no consequences if you choose not to do so.
4.4 For some volunteer roles, GLL is obliged to seek information about criminal convictions and offences. Where GLL seeks this information, we do so because it is necessary for us to carry out our duty of care or contractual obligation in relation to the recruitment of volunteers.
4.5 By registering with the volunteer management system on our website we understand that you are actively soliciting contact from GLL about volunteer opportunities which match your field of interest. GLL will not use your data for any purpose other than the recruitment process, contact with you regarding the volunteering you are undertaking e.g. changes to session times, dates or any other relevant information and monitoring purposes such as recording of the number of volunteer hours undertaken. If you no longer to wish to remain on our volunteer management system then you can you can end your registration by going to your personal profile, going to the Close Account tab and following the steps to close your registration.
5.0 Access to personal data
5.1 Your information will be shared internally for the purposes of recruitment and on-going management of the volunteer opportunities you choose to undertake. This includes members of the HR team, interviewers involved in the recruitment process, and managers in the business area responsible for volunteers.
5.2 The volunteer management system is hosted by a third-party provider called Team Kinetic. GLL will not share your data with other third parties, unless your application to volunteer is successful. If you are successful you will be asked to share information with the Disclosure and Barring Service to obtain necessary criminal records checks.
5.3 GLL will not transfer your data to countries outside the European Economic Area (EEA).
6.0 Protection of personal data
6.1 GLL takes the security of your data seriously. We have internal policies and controls in place to ensure it is not lost, accidentally destroyed, misused, disclosed, or accessed except by our employees in the proper performance of their duties.
6.2 Your data is stored in the volunteer management system, and in other IT systems and databases, including the company’s email system.
6.3 Hard copies of documents containing personal information may be stored in secure cabinets with appropriately controlled access. Electronic data is hosted by our volunteer management system provider Team Kinetic who are required to comply with recognised standards and conduct regular testing.
6.4 Where GLL engages third parties to process personal data on our behalf, they are given written instructions, are under a duty of confidentiality and are obliged to implement appropriate measures to ensure the security of data.
7.0 Retention of personal data
7.1 If your application for volunteering is successful your data will remain on the volunteer management portal. If you are inactive for a period of 2 years then your account will be closed and personal data deleted.
7.2 If you register on the volunteer management system and then choose not to apply for any volunteer roles GLL will leave your account active for 2 years. After this period your personal data will be deleted and your account closed.
7.3 If your application for volunteering is unsuccessful your data will be deleted.
8.0 Your rights
8.1 As a data subject, you have a number of rights. You can:
Request access to your data (a subject access request);
Request that your data is erased;
Object to the processing of your data where GLL relies on its legitimate interests as the legal ground for processing;
Ask GLL to stop or restrict the processing of your data for a period.
8.2 If you wish to exercise any of your other rights please contact the Data Protection Officer.
8.3 If you believe that GLL has not complied with your data protection rights, you can complain to the Information Commissioner.
9.0 Obligations to provide personal data
9.1 You are under no obligation to provide personal data to GLL during the registration process. However, if you do not provide the data GLL may not be able to process your application or registration properly or at all.
9.2 You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.
10.0 Automated decision-making
Volunteer recruitment processes are never based solely on automated decision-making.
