Your privacy is important to us. To better protect your privacy, we provide this information explaining our information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available throughout the website and at every point where personally identifiable information may be requested.
Any questions relating to Data Privacy within Cuffe and Lacey Associates or this Policy should be sent by email to firstname.lastname@example.org
This privacy notice tells you what to expect when Cuffe and Lacey Associates collects personal information. It applies to information we collect about:
- Visitors to our website
- People who use our services, e.g. who subscribe to our newsletter or request a publication from us
- Complainants and other individuals in relation to data protection
Visitors to our Website
When someone visits www.cuffeandlaceyg.com we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. The information is held for 26 months for statistical reporting purposes only. We do not make, and do not allow Google to make any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
People who contact us via social media
We manage social media interactions inhouse. The social media platforms that we use are Facebook, Instagram, Twitter, You-Tube, Google+ and LinkedIn. Please see each of the individual social media websites for the terms of their privacy policies in how they manage information you share via their platforms.
If you send us personal information through private messaging to enquire with us about becoming a foster carer, please see enquiry details below for how we use and manage your personal data.
Cuffe and Lacey Associates occasionally store and process information in a SharePoint system that sits within Microsoft UK Data Centres, information is backed up by Microsoft. Cuffe and Lacey Associates use a third-party provider Objective Technologies to manage this site on our behalf.
We will also collect and process the following data from you:
- Information you consent to provide to Cuffe and Lacey Associates that is required to carry out our obligations arising from any contracts entered between you and us, or potential contracts that may be in liaison between you and us.
- Information that you consent to provide by filling in forms on our website, or as part of any direct marketing or sales activities. This includes and is not limited to personal information about you such as your name, telephone contact number, geographical address/location, email address and interests.
- If you contact us by telephone or in writing, we may keep a copy of your correspondence or communication.
- Details of your visits to our website and the resources that you access.
If you have provided us with the personal data of another person, there is a clear requirement imposed by Cuffe and Lacey Associates for you to confirm that he/she consents to the processing of his/her personal data and that you have informed him/her of our identity as a Data Controller and the nature of the processing taking place. Records will be retained as evidence of this consent.
We use information held about you in the following ways:
Performance of a contract – We use information held about you to carry out our obligations arising from any contracts entered between you and us; and to notify you about changes to our services.
Legal Obligation – Cuffe and Lacey Associates are required to comply with the Fostering Service Regulations 2011, the Children’s Act 1989 and Fostering Services National Minimum Standards and this means obtaining, processing and storing personally identifiable and special categories of data in relation to the fostering services provided by Cuffe and Lacey Associates in recruiting and approving foster carers to provide care to looked after children.
Legitimate Interests – We use information held about you to provide you with information, products and/or services that you request from us or which we feel may interest you if relevant to the products or services currently being supplied as part of a contract with Cuffe and Lacey Associates, or in relation to a previous contract with Cuffe and Lacey Associates whereby you are happy to continue to receive such information;
Consent (Direct Marketing) – We use information held about you to provide you with information on products and/or services that you request from us, or which we feel may interest you where you have consented to be contacted for such purposes. Where consent has been provided to Cuffe and Lacey Associates, it is a recognised right of the Data Subject that this consent can also be withdrawn. Should you wish to withdraw consent, please email email@example.com
We will not share your data with third parties for other marketing purposes unless we have your express consent to do so.
Our commitment to Data Security
To prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect.
Your rights relating to Personal Data
Under the General Data Protection Regulations (GDPR) you have a number of ‘rights’ to ensure you are treated fairly by The Capstone Group.
- The right of access – GDPR gives you the right to access information held about you. Your right of access can be exercised at any time. Cuffe and Lacey Associates operate both a Data Subjects Rights procedure and a Subject Access Rights Procedure to ensure that all rights exercised by data subjects relating to personal data are managed appropriately. You have the right to access personal information we hold on you by making a request in writing to your local office at any time
- The right to rectification – If any of your personal data changes, or if you have any questions about how we use data which relates to you, please contact your local office in writing where we will ensure that we make the necessary rectifications
- The right to erasure (The Right to be Forgotten) – You have the right to have your personal information erased and to prevent processing in some specific situations.
- The right to restrict processing – you can request that we restrict processing your personal information
- The right to data portability – you have the right to request personal information that you have provided to us for your own purposes. To request information please contact your local office in writing.
- Automated decision-making and profiling – Safeguards for individuals have been introduced by GDPR to protect against decisions being made without human intervention – Cuffe and Lacey do not use automated decision making or profiling in its work.From time to time, our website may contain links to and from our strategic partner(s), partner network(s), strategic sponsor(s), advertiser(s) and affiliate(s). If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
Retention of your information
Cuffe and Lacey Associates operate a clear Retention policy and associated Retention Schedule to ensure personal data is kept only for so long as is necessary for the purpose for which such information is used.
Disclosure of your information
We may disclose your personal information to any member of our group, which means our subsidiaries, strategic partner(s) or strategic sponsor(s) our ultimate holding company and its subsidiaries as defined in section 1159 of the UK Companies Act 2006.
As part of our GDPR compliance obligations, we are duty bound to check when personal data may be shared with third parties to ensure that they apply the same or greater controls in terms of data protection. The use of non-disclosure agreements form part of our third-party data sharing controls.
- We may disclose your personal information to third parties
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by it about our customers will be one of the transferred assets; or
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply other agreements; or
- to protect the rights, property or safety of Cuffe and Lacey Associates, our customers or others.
Making a Complaint
If you are not happy with the way that Cuffe and Lacey Associates has handled collecting and using your personal information and you want to make a complaint you can contact us by writing to our Managing Director, Michelle Cuffe, at your local office or sending an email to admin@CuffeandLacey.com.
Alternatively, or if you are not happy with our response to your complaint, you can contact the Information Commissioners Office directly to report a concern on 0303 123 1113 or via their website which is https://ico.org.uk/concerns