In-dependence is committed to protecting your personal data when you use our services and website.

This privacy statement relates to our use of any personal data you provide, and contains details of how we collect, use, disclose, transfer and store your personal data in connection with your relationship with us and in particular for your use of our services.

In order to provide you with the most suitable service(s) for your needs, we are required to collect personal data about you. In-dependence is committed to safeguarding your personal data and is registered as a data controller with the Guernsey Data Protection Authority. This means that we are responsible for deciding how we hold and use personal data that relates to you.

For certain services we may be acting as a data processor, which means we are processing your personal data on behalf of a data controller, and once our relationship with you comes to an end your identifiable personal data will return to the controller.

Whenever you provide personal data we are legally obliged to use your data for a lawful purpose and the processing must be fair and transparent in line with the Data Protection (Bailiwick of Guernsey) Law, 2017. We are also required under the data protection legislation to notify you of the information contained in this Privacy statement.

It is important for you to read this Privacy Statement, together with any other privacy notice or statement we may provide on specific occasions when we are processing data related to you, so that you are aware of how and why we are using such information.

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Data protection principles

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In-dependence will comply with data protection law. This means that personal data we hold about you must be:

·      Used in a lawful, fair and transparent way;

·      Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;

·      Adequate, relevant and limited to what is necessary for those purposes;

·      Accurate and kept up-to-date;

·      Kept only for as long as necessary for the purposes we have told you about; and

·      Kept securely.

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What data will In-dependence collect about me?

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Personal data includes any information about an individual from which that person can be identified. It does not include anonymised data where the identity has been removed.

There are also "special categories" of data of more sensitive personal data that require a higher level of protection.

Access to our services via telephone/web link or in person require different types of information to be submitted. Most of the data we request is of a sensitive nature due to the nature of the work we provide, and will include information relating to health, substance use, offending behaviour, employment and relationships. This information is gathered so that we can make decisions about the most suitable service for your situation. 

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How will In-dependence use the data they collect about me?

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Our lawful purposes for processing will fall into one of the following categories, dependent upon the service you are accessing;

Schedule2. Part 2; 10.a.ii.  a person who in the circumstances owes a duty of confidentiality which is equivalent to that which would arise if the person were a health professional.

Schedule2 Part 2; 13.b. Where we are exercising a function of the States;

Schedule2 part 2. 14.d. The processing does not involve disclosure of the personal data to a third party without the consent of the data subject;

Schedule2. Part 2. 9. The processing is necessary in order to comply with an order or judgement of a court or tribunal having the force of the law in the Bailiwick.

Where data is obtained from someone other than you, this will be in most circumstances health and social care providers. In these circumstances you will be aware at the point of data collection who we may contact to enable us to complete the necessary work. Information is only shared if we have a lawful basis for doing so.

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What if I do not provide personal data to In-dependence?

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If you do not provide certain information requested, we may be unable to provide you with a service.

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How long will In-dependence keep my personal data?

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Unless the service you are accessing specifies otherwise personal data will be kept for a minimum period of 7 years post the end of our last formal contact with you.

Data may be kept for longer if, for example, there is a complaint and the data is required as part of the complaints process.

Personal data is held in electronic format, with some data kept in hard copy to enable certain working procedures to occur. Data is destroyed in hard copy once no longer required in that format and in order to minimize the potential for unauthorised access.

In order to prevent unauthorised or unlawful processing, In-dependence has put in place suitable physical, electronic and managerial procedures for both electronic and hard copy data to safeguard and secure the information that is collected and processed.

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What are my data protection rights?

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It is important the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes whilst you are a client of ours.

In certain circumstances you may have the right to:

• Request access to your personal data (data subject access request). This enables you to receive a copy of the personal data we hold about you;
• Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected;
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to use it.
• Request the restriction of processing of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it; or
• Request the transfer of your personal data to another party.

We will not charge a fee for providing access to your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with your request in such circumstances. In-Dependence may need to request specific information from you to help us to confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is another appropriate security measure to ensure that personal data is not disclosed to any other person who has no right to receive it.

In-Dependence complies with the Data Protection (Bailiwick of Guernsey) Law 2017. Personally identifiable information we receive about you via www.independence.gg will not be disclosed to any third party without your prior consent or the requestor's demonstrated legal authority to receive it. 

We won't share your information with any other organisations for marketing, market research or commercial purposes, and we don't pass on your details to other websites.

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Browsing

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We collect certain information about your computer and your interaction with the site when you browse www.independence.gg:

·      Your IP address, and details of which version of web browser you used

·      Information on how you use the site, using cookies

This data is not personally identifiable and by using the site you are agreeing to this data being collected. It is only used to help us monitor and improve the site (such as making updates to the popular pages buttons on the home page).

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Cookies

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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 more efficiently, as well as to provide information to the owners of the site. The table below explains the cookies we use and why.

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How do I change my cookie settings?

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Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

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People who call our helpline

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When you call our helpline we collect anonymous data which highlights the date the call was made and which substance the call related to. You cannot be identified from this data.

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People who email us

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You need to be aware that any emails you send us may not be protected in transit.

If you would like us to encrypt any electronic responses then you need to request this when you initiate contact. You will be required to subscribe to Egress Switch to open our response, and this service is free of charge.

We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

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People who make a complaint to us

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When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.

We usually have to disclose the complainant's identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person's record is in dispute. If a complainant doesn't want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the 'need to know' principle.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

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Job applicants, current and former employees

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In-dependence is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at info@independence.gg

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What will we do with the information you provide to us?

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All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us whether the information is in electronic or physical format.

We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.

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What information do we ask for, and why?

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We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

The information we ask for is used to assess your suitability for employment. You don't have to provide what we ask for but it might affect your application if you don't.

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Application stage

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We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.

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Shortlisting

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Our interview panel shortlist applications for interview. They will not be provided with your name or contact details.

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Recruitment Assessment

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We might ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; and/or to attend an interview - or a combination of these. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by In-dependence.

If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a period of six months. If you say yes, we would proactively contact you should any further suitable vacancies arise.

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Conditional offer

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If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in Guernsey and seek assurance as to their trustworthiness, integrity and reliability.

You will therefore be required to provide:

• Proof of your identity - you will be asked to attend our office with original documents, we will take copies.
• Proof of your qualifications - you will be asked to attend our office with original documents, we will take copies.
• You will be asked to complete a criminal records declaration to declare any unspent convictions.
• We will ask you to complete an application for an enhanced Criminal Record check via the Disclosure and Barring Service, which will verify your declaration of unspent convictions.
• We will contact your referees, using the details you provide in your application, directly to obtain references
• We will also ask you to complete a questionnaire about your health. This is to establish your fitness to work.

If we make a final offer, we will also ask you for the following:

• Bank details - to process salary payments
• Emergency contact details - so we know who to contact in case you have an emergency at work

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How long is the information retained for?

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If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.

If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign.

Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the campaign.

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How we make decisions about recruitment?

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Final recruitment decisions are made by members of our recruitment team. All of the information gathered during the application process is taken into account.

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Complaints or queries

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In-dependence tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our data collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.

If you want to make a complaint about the way we have processed your personal information, you can contact the Data Protection Commissioner, with the details below.

Block A

Lefebvre Court

Lefebvre Street

St Peter Port

GY1 2JP

info@odpa.gg

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Use of data processors

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Data processors are third parties who provide elements of our service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

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Links to other websites

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This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

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Changes to this privacy notice

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We keep our privacy notice under regular review. This privacy notice was last updated on 01 May 2019.

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How to contact us

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If you want to request information about our privacy policy you can email us: info@independence.gg.

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