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Privacy notice

Data privacy notice for clients, trainees, volunteers and event attendees of Digital Communities Wales

Your personal data – what is it?
Personal data means any data which identifies a living person. Processing personal data (collecting, storing, using, altering, sharing or destroying personal information) is governed by the General Data Protection Regulation 2016/679 (known as GDPR).

Who are we?
Digital Communities Wales: Digital Confidence, Health and Well-being is a project funded by Welsh Government and delivered by Cwmpas.

For personal data related to project outcomes, Welsh Government is the Data Controller. This means it decides how your personal data is processed and for what purposes. For these purposes, Cwmpas is a Data Processor.

For personal data related to project delivery, Cwmpas is the Data Controller. This means it decides how your personal data is processed and for what purposes.

How do we process your personal data?
Welsh Government and Cwmpas comply with their obligations under GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

Your personal data is used for the following purposes: –

  • To deliver the services you’ve requested from us
  • To monitor and report on the number of individuals and enterprises taking part in projects and the number of people from different groups being supported
  • To fulfil the reporting requirements of our project funders
  • To evaluate the impact of services on the individuals and enterprises who took part
  • For audit and verification purposes
  • To inform you about similar services, activities or events (in accordance with the Privacy and Electronic Communications Regulations)

What is the legal basis for processing your personal data?
Welsh Government processes your personal data in order to carry out a task in the public interest – this this case, to support individuals to engage with technology and develop their basic digital skills.

Cwmpas carries out processing because it is necessary for the performance of a contract we have with you to deliver a service, or to take steps to enter into a contract with you.

Processing is also necessary for the legitimate interests of both organisations, so that we can monitor and evaluate our services and inform you about similar services, activities or events.

Provision of your data is a contractual requirement – without it, we are unable to deliver the service you have requested from us.

Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with the following:

  • Third parties acting on our behalf who are helping us deliver the service
  • Third parties acting on our behalf who are helping us evaluate the service
  • Third parties who have commissioned us to deliver digital inclusion services to you
  • Third party mailing houses

Third parties are contractually required to protect your data and comply with GDPR.

Cwmpas will never pass on your information to another organisation for them to market directly to you or your organisation.

How long do we keep your personal data?
Welsh Government determines how long we must keep your data. Your data is kept for no longer than necessary in case of any complaints, legal claims or auditing queries. For Digital Communities Wales, your data is kept until December 2022.

Your rights and your personal data
You have the following rights with respect to your personal data:

  • The right to request a copy of your personal data which Welsh Government and Cwmpas holds about you;
  • The right to request that Welsh Government and Cwmpas corrects any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary for Welsh Government and Cwmpas to retain such data;
  • The right to request that Welsh Government and Cwmpas provides you with your personal data and where possible, to transmit that data directly to another data controller;
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to the processing of personal data;
  • The right to lodge a complaint with the Information Commissioners Office.

Transfer of Data Abroad

In most instances your data remains within the UK, or within the European Economic Area which is recognised in UK law as having adequate safeguards for your data protection rights.

We may transfer your personal information to countries outside the EEA or to an international organisation. Where we transfer your personal information outside the EEA, we will ensure that adequate safeguards are used to secure the data.

Where organisations or platforms that we work with operate globally or use services outside the UK we will take reasonable steps to ensure that safeguards such as a UK adequacy decision, or model contract clauses are in place to protect personal data.

Automated Decision Making
We do not carry out automated decision making with your personal data.

Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use before we start the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

Contact Details
For further information about the information which Welsh Government and Cwmpas hold and its use, or if you wish to exercise your rights under GDPR, please see contact details below:

Digital Inclusion Unit
Welsh Government
Rhydycar Business Park
Merthyr Tydfil
CF48 1UZ
Email: digitalinclusionmailbox@gov.wales

Data Protection Officer
Welsh Government
Cathays Park
Cardiff
CF10 3NQ
Email: data.protectionofficer@gov.wales

Director of Finance and Resources
Cwmpas
Spark
Maindy Road
Cardiff, CF24 4HQ
Email: info@cwmpas.coop

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.