Data Protection Policy

Last updated: August 13, 2019

Review date: August 13, 2020

Please read this Policy Procedure (“Policy”) carefully.  The https://vyvm.co.uk website (the “Service”) is operated by Visioning You Visioning Me (“us”, “we”, or “our”). 

Our Commitment
Visioning You Visioning Me is a social enterprise dedicated to offering a service that supports participants to have an experiential experience of immersive creativity.

We are committed to processing data in accordance with our responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures 

Definition
GDPR: means the General Data Protection
Responsible Person: means the Founder of Visioning You Visioning Me
Register of Systems:  means a register of all systems or contexts in which personal data is processed by “Us”.

General provisions
a. this policy applies to all personal data processed by the us.
b. the Responsible Person will take responsibility for our ongoing compliance with this policy.
c. this policy will be reviewed at least annually.
d. we will, if not exempt register with the Information Commissioner’s Office as an organisation that processes personal data.

Lawful, fair, and transparent processing:
a. to ensure its processing of data is lawful, fair, and transparent, we will maintain a register of Systems.
b. the Register of Systems will be reviewed annually.
c.  individuals have the right to access their personal data and any such requests made to us and will be dealt with in a timely manner.

Lawful purposes:
a. all data processed by us, must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests).
b. we will note the appropriate lawful basis in the Register of Systems.
c.  where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
d.   where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in our systems

Data minimisation:
We will ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Accuracy:
a. we will take reasonable steps to ensure personal data is accurate.
b.  where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

Archiving /removal:
a. to ensure that personal data is kept for no longer than necessary, we will put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. the archiving policy will consider what data should/must be retained, for how long, and why.

Security:
a. we will ensure that personal data is stored securely using modern software that is kept-up-to-date.
b. access to personal data will be limited to personnel who need access and appropriate security will be in place to avoid unauthorised sharing of information.
c. when personal data is deleted this wil be done safely such that the data is irrecoverable.
d.  appropriate back-up and disaster recovery solutions will be in place.

Breach:
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, we will promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO

Right to complain:
If you have a comments, concerns, or complaints relating to the handling of your personal identifiable data, your comments or complaints can be received via social media channels, e-mail, via post or phone.

Postal address:
The Compliments Team,
Visioning You Visioning Me
38 Beehive Court,
Beehive Lane
Ilford Essex
IG1 3RR

Email address:
compliments@vyvm.co.uk

Phone:
07939 799 078

Disclaimer
Your use of the Service is at your sole risk. The Service is provided on an “AS IS” and “AS AVAILABLE” basis. The Service is provided without warranties of any kind, whether express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, non-infringement,   or course of performance.

Governing Law
This Policy shall be governed and construed in accordance with the laws of United Kingdom without regard to its conflict of law provisions.

Changes
We reserve the right, at our sole discretion, to modify or replace this Policy at any time. If a revision is material, we will try to provide at least 30 days notice prior to any changes taking effect. What constitutes a material change will be determined at our sole discretion.

By continuing to access or use our Service after those revisions become effective, you agree to be bound by the revised policy. 

Contact Us
If you have any questions about this Policy please contact us.