Emmaus Greenwich promises to respect and keep safe any personal data you share with us.  We aim to be clear about how we will use your data and not do anything you wouldn’t reasonably expect from us.

For the purpose of the General Data Protection Regulation and the Data Protection Act 1998 the data controller is Emmaus Greenwich of 226 Elmley St, Plumstead, London, SE18 7NN, a registered charity with Charity Number 1064472 and the data protection officer is the Chief Executive Officer.

What information will we collect?

If you join an Emmaus community, we will usually collect the following information about you:

  • Name
  • Date of birth
  • Nationality
  • Next of kin details
  • National Insurance number
  • Housing situation and housing history
  • Support records
  • Risk assessments
  • Employment history, skills, work preferences, training courses attended etc

We may also collect, store and use the following “special categories” of more sensitive personal information:

  • Health (including history of drug and alcohol use and details of additional support needs)
  • Eligibility to claim benefits
  • Bank details
  • Passport or birth certificate copy to verify your ID

How is your personal information collected?

We collect information:

  • When you apply to join an Emmaus community and provide information in your application form
  • When we carry out a needs and risk assessment as part of the process of joining a community or as carried out on a regular basis thereafter
  • When we record details of support sessions and interventions carried out during your time at Emmaus

Why do we collect your information?

We need all the categories of information in the list above primarily to allow us to provide support to you during your time living at Emmaus Greenwich. The legal basis for processing your personal data is to protect your vital interests. The situations in which we will process your personal information are listed below:

  • To meet your support needs
  • To address the risk to the community, other companions, staff, volunteers, members of the public and yourself
  • To claim Housing Benefit and other services you might be eligible for
  • To help you find support from external agencies and help with moving on from Emmaus

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. Our legal basis for processing special categories of personal data is that such processing is carried out in the course of our legitimate activities as a charity with appropriate safeguards in place.

We will use your particularly sensitive personal information in the following ways:

  • To assess your needs and risks so that we can decide whether Emmaus Greenwich is the right place for you, and if it is, to develop an appropriate support plan for you
  • To share your information with doctors or other relevant agencies to help meet your support needs
  • To help emergency services as required

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legitimate activities as a charity. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your staying with us that you agree to any request for consent from us.

Information about criminal convictions

We may only use information relating to criminal convictions (e.g. sex offender registration and unspent criminal convictions) where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We envisage that we will hold information about criminal convictions and we will use information about criminal convictions and offences in the following ways:

  • To conduct risk assessments
  • To assess your eligibility about joining Emmaus Greenwich

Accessing information from other sources

We may gain access to your information from other third party organisations, when you when you give them permission to do so or if the information is available publicly. This information will only be recorded if it is beneficial in order to provide you with support during your time at Emmaus.

Data Sharing

Should you move from one Emmaus community to another, we will transfer your support record to the new community, to allow consistency of support during your time at Emmaus.

We will not share your personal details with third parties, other than if required to meet our legitimate interests and if notified to you beforehand. For example, we may contact the police to carry out a police check on you before offering you a place at the community; we may pass basic details about you to the council in respect of Housing Benefit or other housing-related issues; we may contact your GP, with your permission; we may pass basic details about you to third party professionals or agencies such as training companies in order to help secure services for you.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Chief Executive Officer.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us on 020 8316 5398 or send a description of the information you want to see and proof of your identity by post to Emmaus Greenwich of 226 Elmley St, Plumstead, London, SE18 7NN.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the 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 the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

How long we will retain your information for

We will retain your personal information for the duration of your time at Emmaus and for 6 months after you leave. At that point all information we hold about you will be securely disposed of.

In certain circumstances, we reserve the right to keep your personal information for longer than 6 months if, for example, we believe that some sort of claim may be made about you or by you concerning your time at Emmaus and the personal information may be useful in addressing such claim.

Keeping our records up to date

It is your responsibility to inform us of any changes to your personal details.

We may change this Privacy Policy from time to time.  If we make any significant changes in the way we treat your personal information we will make this clear by contacting you directly.

If you have any questions, comments or suggestions, please let us know by contacting us Emmaus Greenwich of 226 Elmley St, Plumstead, London, SE18 7NN.