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Visia Data Protection and Privacy Policy

What is the purpose of this document?

Visia is committed to protecting the privacy and security of your personal information. Visia provides software to organisations or other purchasers who may collect and use personal information about you.

This policy sets out Visia’s expectations of how Visia treats your information and how organisations which purchase Visia’s software will be expected to manage the personal data they hold about you. Please ensure you check the privacy policy of the organisation which holds your personal data. Visia is not liable for any breach of data protection law by the organisation purchasing Visia’s software.

This privacy notice describes how the software (Data Performance Management System) we produce will enable organisations to collect and use personal information about you during and after your contact or relationship with that organisation, in accordance with the General Data Protection Regulation (GDPR).

Visia’s software is a data capture programme for Rape Crisis Centres and can be utilised by relevant authorities for intelligence gathering. Visia does not have access to personal information, however, from time to time complies anonymised and aggregated reports on activity as specified below.

Visia does not hold any personal information, but may from time to time undertake analysis on anonymised aggregated data on behalf of organisations to understand service use and to report activity data based on aggregated non personal or confidential data fields.

This notice applies to all organisations which purchase our software and for the clients of those organisations, former, temporary, and contractors involved with those organisations . This notice does not form part of your agreement with Visia. Visia may update this notice at any time.

1.1 Visia is not a "data controller" as Visia does not collect or use personal information about you;

1.2 Visia does supply software to organisations or other purchasers which may be a “data controller” and holds personal information about you which is stored within the software hosted by Microsoft. This means that the organisation is question is responsible for deciding how it holds and uses personal information about you. It is required under data protection legislation to notify you of the information contained in this privacy notice.

1.3 It is important that you read this notice, together with any other privacy notice supplied by the organisation or purchaser of our software Visia may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why it is using such information.

2. Data protection principles

2.1 Visia will comply with data protection law. Although Visia does not hold personal information about you, it expects that the organisation purchasing Visia’s software will hold personal information about you which must be:

3. The kind of information we hold about you

3.1 Visia will not collect or store any Personal data, or personal information. This means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.2 Visia will only collect, store, and use the following anonymised aggregated categories of information:

3.3 Visia may also collect, store and use anonymised aggregated data in the following "special categories":

4. How is your personal information collected?

4.1 Visia does not collect any personal information about you. However, the software it supplies to organisations enables the collection personal information about Rape Crisis Incidents through the client reporting of incidents directly to the organisation supporting the client.

4.2 The organisation which purchases Visia’s software may share the data with police, social services, agencies providing details of criminal records or other background check agencies.

5. How we will use information about you

5.1 Visia does not hold any personal information about you. However, will from to time to time produce anonymised aggregated activity reports in accordance with 3.2 above.

5.2 We expect that organisations that purchases Visia’s software to only use your personal information when the law allows them to. Most commonly, those organisations will use your personal information in the following circumstances:

6. Situations in which we will use information

6.1 Visia does not hold or use your personal information. The organisations which purchase Visia’s software, in some cases, may use your personal information to pursue legitimate interests of their own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which they will process your personal information are listed below (please ensure you check the Privacy Policy of the organisation which holds your personal data).

6.2 Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

6.3 We need all the categories of information in the list at paragraph 3.2 primarily to allow us to perform our contract with the organisation that purchases our software to enable us to comply with our legal obligation.

7. Change of purpose

7.1 Visia does not collect personal information, however, the organisation which purchases our software should only use your personal information for the purposes for which they collected it, unless it reasonably considers that it needs to use it for another reason and that reason is compatible with the original purpose. If they need to use your personal information for an unrelated purpose, they will notify you and they will explain the legal basis which allows us to do so.

7.2 Please note that they may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8. Sensitive personal information

8.1 Sensitive personal information requires higher levels of protection. Visia does not collect or hold sensitive personal information.

8.2 The organisation which purchases our software may have a need to collect and hold sensitive personal information. They need to have further justification for collecting, storing and using this type of personal information. They may process special categories of personal information in the following circumstances (please check with the organisation which holds your personal data):

8.3 Less commonly, they may process this type of information where it is needed in relation to legal claims or where it is needed 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.

9. How we use sensitive personal information

9.1 Visia will not use sensitive personal information, but may from time to time use anonymised aggregated data for activity reporting. We will use anonymised aggregated information.

10. Do we need your consent?

10.1 We do not need your consent if we use your information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, the organisation purchasing our software may approach you for your written consent to allow us to process certain sensitive personal information. 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 contract with us that you agree to any request for consent from us.

10.2 Information about criminal convictions: The organisation purchasing our software may only use information relating to criminal convictions when the law allows them to do so. This will usually be where such processing is necessary to carry out their obligations as explained above and provided they do so in line with their own data protection policy. Less commonly, they 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.

11. Data sharing

11.1 We may have to share anonymised aggregated data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of data and to treat it in accordance with the law.

If we do, you can expect a similar degree of protection in respect of your personal information.

11.2 We will share your information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

12. Which third-party service providers process my personal information?

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within local authorities, police authorities, social services, child protection and SARC. The following activities are carried out by third-party service providers: aggregated anonymised activity intelligence to track incident areas, outcomes of incidents and progress against incident case loads.

13. Data retention

13.1 Visia does not hold your personal information. However, organisations which purchase our software should only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available on the organisation which purchases our software retention policy which is available from their nominated Data Protection Officer. To determine the appropriate retention period for personal data, they should consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

13.2 In all circumstances we anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a client or contractor of the organisation which purchases our software we will retain and securely destroy any personal information in accordance with our data retention policy.

13.3 It is important that the personal information that the organisation which purchases our software holds about you is accurate and current. Please keep them informed if your personal information changes during your working relationship with us.

13.4 Your rights in connection with personal information. Under certain circumstances, by law you have the right to request from the organisation which holds your personal information:

13.5 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 Visia’s Data Protection Officer in writing and Visia’s Data Protection Officer will contact the organisation which has purchased our software and which holds your personal data.

13.6 You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, if your request for access is clearly unfounded or excessive we may refuse to comply with the request in such circumstances. Our Data Protection Officer will facilitate this request with the organisation that purchases our software and holds personal information about you;

13.7 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.

14. Right to withdraw consent

14.1 In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer or the Data Protection Officer of the organisation that has purchased our software and holds your personal information. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

15. Data protection officer

15.1 We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle information or hold we expect organisations that purchase our software and hold your personal information, please contact the DPO. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

16. Changes to this privacy notice

16.1 We reserve the right to update this privacy notice at any time, and we will post any updated version marked as such on the website below. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions or wish to draw anything to our attention about this privacy notice, please contact the Data Protection Officer or e-mail us on info@visia.co.uk


 
Visia Software Limited 2018