Data Protection Policy

Introduction

Thrive Leicester is committed to compliance with all UK laws around data protection and confidentiality. It is intended that this policy is fully compliant with the Data Protection Act 2018 (the ‘2018 Act’) and the EU General Data Protection Regulation (‘GDPR’). If any conflict arises between those laws and this policy, Thrive Leicester intends to comply with the 2018 Act and the GDPR.

Thrive Leicester takes the security and privacy of your data seriously. We may need to gather and use information or ‘data’ about you as part of our work and to manage our relationship with you. We intend to comply with our legal obligations (as above) in respect of data privacy and security. We have a duty to notify you of the information contained in this policy.

This policy applies to current and former volunteers and representatives of Thrive Leicester, as well as all who attend our groups and use our services. If you fall into one of these categories then you are a ‘data subject’ for the purposes of this policy. Thrive Leicester is a ‘data controller’ for the purposes of your personal data: we determine the purpose and means of the processing of your data. We will only hold data for as long as necessary for the purposes for which we collected it. This policy explains how we will hold and process your information. It explains your rights as a data subject.

This policy also explains your obligations when obtaining, handling, processing or storing personal data in the course of volunteering for, or representing, Thrive Leicester. You should read this policy alongside your volunteer working agreement if applicable, and any other message we send you in relation to your data. This policy does not form part of your volunteer working agreement, and can be amended by Thrive Leicester at any time.

Data Protection Principles

Personal data must be processed in accordance with six ‘Data Protection Principles.’ It must: be processed fairly, lawfully and transparently; be collected and processed only for specified, explicit and legitimate purposes; be adequate, relevant and limited to what is necessary for the purposes for which it is processed; be accurate and kept up to date. Any inaccurate data must be deleted or rectified without delay; not be kept for longer than is necessary for the purposes for which it is processed; and be processed securely. We are accountable for these principles and must comply with them at all times.

How we define personal data

This policy applies to all personal data whether it is stored electronically, on paper or on other materials.

‘Personal data’ means information which relates to a living person who can be identified from that data (a ‘data subject’) on its own, or when taken together with other information which is likely to come into our possession. It includes any expression of opinion about the person and an indication of the intentions of us or others, in respect of that person. It does not include anonymised data.

This personal data might be provided to us by you, or someone else (such as a former employer, your church leader, your doctor, or another organisation), or it could be created by a Thrive volunteer or representative. For volunteers, this data could be provided or created during the volunteer recruitment process, or during the course of your volunteer work with us, or after its termination.

We may, where relevant and appropriate, collect and use the following types of personal data about you:

Volunteer recruitment information such as your application form, references, qualifications, DBS certificates, ID checks and similar;
Your contact details and date of birth;
The contact details for your emergency contacts;
Information in relation to your immigration status and right to volunteer;
Your gender, marital status and family details;
Information about your volunteer working agreement including the start date of your voluntary employment, your role and location, and conduct expectations;
Information relating to disciplinary or grievance investigations and proceedings involving you (whether or not you were the main subject of those proceedings);
Attendance and volunteer work records, and information relating to your performance and behaviour while volunteering with us;
Training records
Your images (whether captured on CCTV, by photograph or video);

And any other category of personal data which we may notify you of from time to time.

How will we process your personal data?

‘Processing’ means any operation which is performed on personal data such as: collection, recording, organisation, structuring or storage; adaption or alteration; retrieval, consultation or use; disclosure by transmission, dissemination or otherwise making available; alignment or combination; and restriction, destruction or erasure. This includes processing personal data which forms part of a filing system and any automated processing. Thrive Leicester will process your personal data (including special categories of personal data) in accordance with our obligations under the 2018 Act.

We will use your personal data for performing everything required within the volunteer working agreement between us; complying with any legal obligation; or if it is necessary for our legitimate interests, or for the legitimate interests of someone else. However, we can only do this if your interests and rights do not override ours (or theirs). You have the right to challenge our legitimate interests and request that we stop this processing.

We can process your personal data for these purposes without your knowledge or consent. We will not use your personal data for an unrelated purpose without telling you about it and the legal basis that we intend to rely on for processing it.

If you choose not to provide us with certain personal data you should be aware that we may not be able to carry out certain parts of the volunteer working agreement between us. It might also stop us from complying with certain legal obligations and duties which we have, including the duty to make reasonable adjustments in relation to disabilities.

Examples of when we might process your personal data

For volunteers and representatives of Thrive, we have to process your personal data in various situations during your recruitment, voluntary employment and even following termination of your voluntary role. For example (and see ‘Special Categories’ below for the meaning of the asterisks):

In the volunteer recruitment process, we have to process your data: to decide whether to take you on as a volunteer or representative of Thrive Leicester; to check you have the legal right to volunteer with us; to carry out the volunteer working agreement between us; to monitor diversity and equal opportunities*; and for training you and reviewing your performance*.

Once you have started as a volunteer, we have to process your data: to decide whether to offer you additional responsibilities; to decide whether and how to manage your performance, absence or conduct*; to carry out a disciplinary or grievance investigation or procedure in relation to you or someone else; to determine whether we need to make reasonable adjustments to your role because of your disability*; to monitor and protect the security, health and safety of Thrive Leicester, or you, our other volunteers, representatives, beneficiaries and others; to provide a reference upon request from another organisation; monitoring compliance by you, us and others with our policies and our obligations*;

And more generally: to pay relevant subscriptions and insurance premiums; to answer questions from insurers*; to comply with all our legal obligations*, including the prevention and detection of fraud or other criminal offences; to defend Thrive Leicester in respect of any investigation or litigation and to comply with any court or tribunal orders for disclosure*; to run our activities and plan for the future; and for any other reason which we may notify you of from time to time.

Special Categories

‘Special categories of personal data’ are types of personal data consisting of information as to your racial or ethnic origin; your political opinions; your religious or philosophical beliefs; your trade union membership; your genetic or biometric data; your health; your sex life and sexual orientation; and any criminal convictions and offences. We may hold and use any of these special categories of your personal data in accordance with the law.

We will only process special categories of your personal data in certain situations in accordance with the law. For example, we can do so if we have your explicit consent. If we asked for your consent to process a special category of personal data then we would explain the reasons for our request. You do not need to consent and can withdraw consent later if you choose by contacting Kat Gibson.

We do not need your consent to process special categories of your personal data when we are processing it for the following purposes, which we may do:

Where it is necessary for carrying out rights and obligations under UK law;
Where it is necessary to protect your vital interests or those of another person where you/they are physically or legally incapable of giving consent; where you have made the data public;
Where processing is necessary for the establishment, exercise or defence of legal claims; and
Where processing is necessary for the purposes of occupational medicine or for the assessment of your volunteer working capacity.

We might process special categories of your personal data for the purposes in the section above which have an asterisk beside them. In particular, we will use information in relation to:

Your race, ethnic origin, religion, sexual orientation or gender to monitor equal opportunities;
Your sickness absence, health and medical conditions to monitor your absence, assess your fitness for your volunteer work, to comply with our legal obligations under UK law including to make reasonable adjustments and to look after your health and safety; and
To pay any subscriptions and to comply with our legal obligations.

We do not take automated decisions about you using your personal data or use profiling in relation to you.

Sharing your personal data

Sometimes we might share your personal data with other organisations and agents to carry out our obligations under our volunteer working agreement with you or for our legitimate interests. We require those organisations to keep your personal data confidential and secure and to protect it in accordance with the law and our policies. They are only permitted to process your data for the lawful purpose for which it has been shared and in accordance with our instructions.

We do not send any of your personal data to any person or organisation outside the UK. If this changes you will be notified of this and the protections which are in place to protect the security of your data will be explained.

Volunteers and representatives: How you should process personal data

The Thrive Coordinator (Kat Gibson) is Thrive Leicester’s Data Protection Officer. The Coordinator is responsible for reviewing this policy and updating the Oversight Group regarding Thrive Leicester’s data protection responsibilities and any risks in relation to the processing of data. You should direct any questions in relation to this policy or data protection to this person, either by personal contact or by using the contact form on the Thrive website.

Everyone who volunteers for, or represents, Thrive Leicester has some responsibility for ensuring data is collected, stored and handled appropriately, in line with this policy. If you are a volunteer or representative of Thrive Leicester, you should:

Only access personal data if you need it for the volunteer work you do for, or on behalf of Thrive Leicester and only if you are authorised to do so. Regularly review and update personal data which you have to deal with for your voluntary work. This includes telling us if your own contact details change. Only use personal data for the specified lawful purpose for which it was obtained.

Store personal data securely: Do not make unnecessary copies of personal data, and keep and dispose of any copies securely. Use strong passwords, and keep your devices locked when not in use. Any paper containing personal data should be stored securely and never left lying around. Consider anonymising data or using separate keys/codes so that the data subject cannot be identified. Personal data should be disposed of securely when you have finished with it.

Do not share personal data informally, and not share it with unauthorised people, in line with Thrive Leicester’s Confidentiality Policy. Never transfer personal data to any person or organisation outside the UK except in compliance with the law and authorisation of the Data Protection Officer.

Ask for help from our Data Protection Officer if you are unsure about data protection or if you notice any areas of data protection or security we can improve upon. Any deliberate or negligent breach of this policy by you may result in disciplinary action being taken against you in accordance with our disciplinary procedure. It is a criminal offence to conceal or destroy personal data which is part of a subject access request (see below). This conduct would also amount to gross misconduct and could result in your dismissal.

How to deal with data breaches

We have robust measures in place to minimise and prevent data breaches from taking place. Should a breach of personal data occur (whether in respect of you or someone else) then we must take notes and keep evidence of that breach. If the breach is likely to result in a risk to the rights and freedoms of individuals then we must also notify the Information Commissioner’s Office within 72 hours.

If you are aware of a data breach you must contact the Thrive Coordinator (Kat Gibson) immediately and keep any evidence you have in relation to the breach.

Subject access requests

Data subjects can make a ‘subject access request’ (‘SAR’) to find out the information we hold about them. This request must be made in writing. If you receive such a request you should forward it immediately to the Data Protection Officer who will coordinate a response.

If you would like to make a SAR in relation to your own personal data you should make this in writing to the Thrive Coordinator, Kat Gibson. We must respond within one month unless the request is complex or numerous in which case the period in which we must respond can be extended by a further two months.

There is no fee for making a SAR. However, if your request is manifestly unfounded or excessive we may charge a reasonable administrative fee or refuse to respond to your request.

Your data subject rights

You have the right to information about what personal data we process, how and on what basis as set out in this policy.
You have the right to access your own personal data by way of a subject access request (see above).
You can correct any inaccuracies in your personal data. To do you should contact the Thrive Coordinator.
You have the right to request that we erase your personal data where we were not entitled under the law to process it or it is no longer necessary to process it for the purpose it was collected. To do you should contact the Thrive Coordinator.
While you are requesting that your personal data is corrected or erased or are contesting the lawfulness of our processing, you can apply for its use to be restricted while the application is made. To do you should contact the Thrive Coordinator.
You have the right to object to data processing where we are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop.
You have the right to object if we process your personal data for the purposes of direct marketing.
You have the right to receive a copy of your personal data and to transfer your personal data to another data controller. We will not charge for this and will in most cases aim to do this within one month.
With some exceptions, you have the right not to be subjected to automated decision-making.
You have the right to be notified of a data security breach concerning your personal data.
In most situations we will not rely on your consent as a lawful ground to process your data. If we do however request your consent to the processing of your personal data for a specific purpose, you have the right not to consent or to withdraw your consent later. To withdraw your consent, you should contact the Thrive Coordinator.
You have the right to complain to the Information Commissioner. You can do this be contacting the Information Commissioner’s Office directly. Full contact details including a helpline number can be found on the Information Commissioner’s Office website (www.ico.org.uk). This website has further information on your rights and our obligations.

Reporting & Compliance

If anyone becomes aware of a potential breach of this policy, whether intentional or unintentional, they must contact the Thrive Coordinator immediately. Thrive Leicester encourages reporting in good faith.

Intentional breaches of this policy may lead to disciplinary action, up to and including termination of voluntary employment.

Authorised by Thrive Coordinator, Kat Gibson

Date of last review: January 2026

Next review due: January 2027

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