VSS Privacy Notice
How we use your information
This privacy notice tells you what to expect when the Victims and Survivors Service (VSS) collects personal information. It applies to information we collect about:
- visitors to our websites
- complainants and other individuals in relation to, for example, freedom of information queries
- people who use our services
- job applicants and our current and former employees
Visitors to our websites
When someone visits www.victimsservice.org we 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. We collect this information in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website. We will not associate any data gathered from this site with any personally identifying information from any source.
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. For example: if you send us a query using the Contact Form on the website, we will collect your email address and any information that you disclose in that email.
Cookies are small files which many web sites transfer to your hard disk. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. This information enables web sites to provide you with a more personalized service.
People who email us
The VSS IT system is part of the Northern Ireland Civil Service network. Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with the network policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
People who make a complaint to us
When we receive a complaint from a person we create a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy.
This means that information relating to a complaint will be retained for two years from closure.
It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
People who use VSS services
The VSS offers various services to the public.
We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have accessed a particular service to carry out a survey to find out if they are happy with the level of service they received. When people do engage with our services, they remain free to disengage at any time.
Job applicants, current and former VSS employees
When individuals apply to work at VSS, we will only use the information they supply to us to process their application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Criminal Records Bureau we will not do so without informing them beforehand unless the disclosure is required by law.
Please note that the personal information on the Application Form will be processed and handled in accordance with Data Protection legislation. In accordance with our Data Retention and Disposal Policy: Data contained on the application form of applicants successful in securing employment will be used for HR and Payroll administrative purposes during the period of employment. Data contained on the application form of applicants who do not secure employment will be used for HR administrative purposes and retained for up to 3 years from the date of application. Equal opportunities motoring forms will be retained for a period of 5 years.
Once a person has taken up employment with the VSS, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with VSS has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it.
Groups receiving Peace IV funding
Under the terms of our contracts both VSS and our participating groups need to share information with SEUPB so they can maintain oversight of their funding. This may include 3rd. party information, such as supplier invoices and individual contact details. For verification of PEACE IV funding by SEUPB, scanned copies of original documentation may be uploaded to SEUPB’s secure e-Monitoring System (eMS) database.
The SEUPB privacy notice is located at https://seupb.eu/sites/default/files/styles/SEUPB_Policies/SEUPBPrivacyNotice.pdf
with the relevant terms in the paragraph entitled Programme Management & Delivery.
The SEUPB eMS T&Cs are located at https://peace.seupb.eu/ems/app/main?execution=e1s1
Suppliers and Contractors
We may also share information with the NI Audit Office for the prevention and detection of fraud. This is part of the National Fraud Initiative, the general terms of which can be found at their website: https://www.niauditoffice.gov.uk/national-fraud-initative
Information shared in this way is governed by the NFI privacy notice which can be viewed here: https://www.niauditoffice.gov.uk/sites/niao/files/media-files/Updated%20NFI%20Privacy%20Notice%202018.pdf
VSS tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 2018. If we do hold information about you we will:
- give you a description of it;
- tell you why we are holding it;
- tell you who it could be disclosed to; and
- let you have a copy of the information in an intelligible form.
To make a request to the VSS for any personal information we may hold you need to put the request in writing addressing it to our Data Protection Officer, at the address provided below:
Data Protection Officer
Victims and Survivors Service
1st Floor, Seatem House
28-32 Alfred Street
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting our Data Protection Officer.
Disclosure of personal information
In most circumstances we will not disclose personal data without consent. However when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies.
There will be other occasions where we may share information with external bodies, such as our own solicitors where appropriate or with law enforcement agencies in a context where we are legally obliged to do so. We may also share information for the prevention and detection of fraud.
Links to other websites
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit. Please read the VSS Disclaimer notice for more information.
Complaints or queries
VSS tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
If at any point you believe the information we process on you is incorrect, you can ask to have this information corrected or deleted. If you wish to raise a complaint about how we have handled your data, you can contact our Data Protection Officer at the address above who will investigate the matter.
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner at the following address:
Information Commissioner’s Office
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of VSS’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 09 November 2018.