This Privacy Policy applies between you, the user of this website, and The Commission on Homelessness and Rough Sleeping (including St Mungo’s as Secretariat), the owner and provider of this Website. We take the privacy of your information very seriously. This privacy policy applies to our use of any and all data collected by us or provided by you in relation to your use of the website. The Commission on Homelessness and Rough Sleeping, as defined in section 1159 of the UK Companies Act 2006 is committed to protecting and respecting your privacy.

Definitions and Interpretation

1. In this Privacy Policy, the following definitions are used:

In this Privacy Policy, unless the content requires a different interpretation:

• the singular includes the plural and vice versa;
• references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses or appendices of this privacy policy;
• a reference to a person includes firms, companies, government entities, trusts and partnerships;
• “including” is understood to mean “including without limitation”;
• reference to any statutory provision includes any modification or amendment of it;
• the headings and sub-headings do not form part of this privacy policy.

Scope of this Privacy Policy

1. This Privacy Policy applies only to the actions of the Commission and users with respect to this website. It does not extend to any websites that can be accessed from this website including, but not limited to, any links we may provide to social media websites.
2. The Commission will only use personal information if we have a proper reason to do so. This includes:

• Using data and/or information to fulfil a contract we have with you;
• When it is our legal duty to use or share information;
• When it is in our legitimate interest (see section 11)
• When you consent to it.

For purposes of the applicable Data Protection Laws, the Commission is the “data controller”. This means that the Commission determines the purposes for which, and the manner in which, your data is processed.

Information (purely anonymous data for analytics purposes) will also be collected by the Commission using Google Analytics.

How we collect data

We collect data in the following ways:

• data that is given to us by you and;
• data that is collected automatically.

Data that is given to us by you

The Commission will collect your data when you send emails or comments through the website. This includes contact details, email correspondence, and usage data.

Data that is collected automatically

To the extent that you access the website, we will collect your data automatically, for example:

• Our site uses cookies to distinguish you from other users of our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
• Cookies help us to provide you with a good experience when you browse our site and also allows us to improve our site. By continuing to browse our site, you are agreeing to our use of cookies.
• We use the following cookies: Strictly necessary cookies – for the operation of our site (i.e. cookies that allow you to log in for customer services); Analytical and performance cookies – to count the number of visitors and how they move through the site (this data will be accessed by the Commission for the purposes of monitoring and improving the website); Functionality cookies – allowing us to recognise you when you return to the site, saving your language or region preferences; Targeting cookies – used to make any advertising displayed on our website more relevant to your interests.
• You can choose to opt out of any cookies at any time using the Cookie Settings.

How we use your data

We will use your data for a number of reasons. If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot deliver products and services for you or it could mean that we cancel a product or service you have with us. A list of the ways in which we use your data are included below:

1. Keeping our records up to date
2. To study how our visitors use our site
3. To deliver our research

Who we share your personal information with

Your personal information will only be seen by the Commission and secretariat St Mungo’s, unless you have explicitly asked us to share your details with someone for the purposes of introduction.

If you share personal information in any public comments, we will not be held responsible if this data is used by other site visitors.

Keeping data secure

We will use technical and organisational measures to safeguard your data, for example;

We store your data on secure servers.

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your data, please let us know immediately by contacting info@commissiononroughsleeping.org

Data retention

Once you have completed any questionnaires, we will keep your personal information for the duration of the Commission. If you request us to cease contacting you about our organisation, we may keep your data indefinitely if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes. Even if we delete your data, it may persist on backup or archival media for legal, or regulatory purposes.

Your rights

You have the following rights in relation to your data:

Right to access – the right to request (i) copies of the information we hold about you at any time or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

Right to correct – the right to have your data rectified if it is inaccurate or incomplete.

Right to erase – the right to request that we delete or remove your data from our systems.

Right to restrict our use of your data – the right to “block” us from using your data or limit the way in which we can use it.

Right to data portability – the right to request that we move, copy or transfer your data.

Right to object – the right to object to our use of your data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set our above, or withdraw your consent to the processing of your data (where consent is our legal basis for processing your data), please contact us by writing to Personal information request, St Mungo’s, 3 Thomas More Square, London, E1W 1YW

If you are not satisfied with the way a complaint you make in relation to your data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.ork.uk

It is important that the data we hold about you is accurate and current. Please keep us informed if your data changes during the period for which we hold it.

Links to other websites

This website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the Privacy Policy or statement of other websites prior to using them.

General

1. You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy where we reasonably believe that your rights will not be affected.
2. If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.
3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
4. This agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this Privacy Policy

The Commission reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the website and you are deemed to have accepted the terms of the Privacy Policy on your first use of the website following the alterations. You can contact us at info@commissiononroughsleeping.org for further information.