Data Protection It is your responsibility to ensure that that you give us an accurate and valid e-mail address and other contact details and tell us of any changes to them. We comply with all applicable Data Protection laws in the UK. Key Unlocking Futures is a subsidiary of Progress Housing Group Ltd, to view the Group privacy notice please click here to see how we comply with Data Protection Laws in the UK. For a description of how the Group uses cookies, please click here.

 

Key Privacy Notice

1. Introduction
2. Who we are
3. Your privacy rights
4. What kinds of personal identifiable information we use
5. How we gather your personal identifiable information
6. How we lawfully use your personal identifiable information
7. Automated decision making
8. Our legal basis for using your personal information
9. Sharing your personal information with or getting your personal information from others
10. Transfers outside the UK
11. How long we keep your personal information for
12. Keeping you up to date

 

Privacy Notice

Our Privacy Notice describes the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the requirements of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Introduction

1.1       We take your privacy seriously and you can find out more here about your privacy rights and how we collect, use, share and secure your personal identifiable information. This includes the personal identifiable information we already hold about you now and the further personal identifiable information we might collect about you, either from you or from a third party. How we use your personal identifiable information will depend on the products and services we provide to you.

1.2       This Privacy Notice is a public document available when Key Unlocking Futures use your personal identifiable information. It explains how we and appointed third party organisations/people use your personal identifiable information and it details your rights.  We obtain your personal identifiable information in order to conduct our normal business operations as a registered charity.

1.3       Our Data Protection Officer (DPO) provides help and guidance to make sure we apply the law to the processing and protection of your personal identifiable information. Our DPO, can be reached by email at dataprotection@progressgroup.org.uk, on our main phone number 01772 678979 or by post at Sumner House, 21 King Street, Leyland, Lancashire PR25 2LW, if you have any questions about how we use your personal identifiable information.

1.4       See section 3 Your Privacy Rights for more information about your rights and how our Data Protection Officer can help you.

1.5       This Privacy Notice provides up to date information about how we use your personal identifiable information and now updates any previous information we have published/supplied about using your personal identifiable information. If we make any significant changes affecting how we use your personal identifiable information, we will make changes to this Privacy Notice, and we will contact you to inform you of these changes.

 

2. Who we are

2.1       Where we refer to ‘we’ or ‘us’ in this Privacy Notice, we are referring to Key Unlocking Futures

2.2       Key Unlocking Futures are the 'data controller' of your personal identifiable information because we determine the use of this information. As a registered charity, we are regulated by the Charity Commission.

2.3      Key Unlocking Futures are part of a 'Group' of companies. In this Privacy Notice, when we refer to ‘Group’, we mean other members of our ‘Group’ of companies, including holding and subsidiary companies. View our group of companies and their ICO References here: https://ico.org.uk/esdwebpages/search:

 

Progress Housing Group Limited             Z7945816

Progress Housing Association Limited     Z7611446

Reside Housing Association Limited          Z8893471

Concert Living Limited                   ZA469256 

Key Unlocking Futures Limited                 ZA076933

 

3. Your privacy rights

3.1       The UK GDPR provides eight rights relating to the use and storage of your personal information. These are:

The right to be informed;

• The right of access;
• The right to rectification;
• The right to erasure;
• The right to restrict processing;
• The right to data portability;
• The right to object;
• Rights in relation to automated decision making and profiling.

For further information regarding your rights, see here: https://ico.org.uk

 

3.2       In brief, you have the right to be informed about who is obtaining and using your personal identifiable information, how this information will be retained, shared and secured and what lawful grounds will be used to obtain and use your personal identifiable information.   You have the right to object to how we use your personal identifiable information in certain circumstances. You also have the right to obtain a copy of the personal identifiable information we hold about you.

3.3       In addition, you can ask us to correct inaccuracies, delete or restrict personal identifiable information or to ask for some of your personal identifiable information to be provided to someone else. You can make a complaint if you feel we are using your personal identifiable information unlawfully and/or holding inaccurate, inadequate or irrelevant personal identifiable information which if used may have a detrimental impact on you and/or has an impact on your rights.

3.4       You can also make a complaint to the data protection supervisory authority. In the UK, this is the Information Commissioner's Office, at https://ico.org.uk.

3.5       To make enquires for further information about exercising any of your rights in this Privacy Notice, please contact our Data Protection Officer on 01772 678979 or via email at dataprotection@progressgroup.org.uk or write to Data Protection Officer, Sumner House, 21 King Street, Leyland, Lancashire PR25 2LW

 

4. What kinds of personal identifiable information we use:

4.1       We use a variety of personal identifiable information depending on the services we deliver to you. For all services, we need to use the following information about you:

4.2       Personal information

• Contact details - Name, address, email address, home and/or mobile telephone numbers
• Age - Date of birth

 

For some of Key’s services we may need to collect other information such as:

• Financial details
• National Insurance number
• Identity documents

We will only keep this information as long as necessary (while we are supporting you)

4.3       Special Information:

Key Unlocking Futures will not process any special category data. This includes information such as data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, sex life and sexual orientation.

4.4       Sometimes where we ask for your personal identifiable information to enter into a contract/agreement with you (for example to offer you support) or to meet our legal or regulatory duties, we will not be able to provide support / services without this information.

 

5. How we gather your personal identifiable information

5.1       We obtain personal identifiable information by various means, this can be face to face, by email, telephone, correspondence and/or by receiving this information from others, for example, other support agencies, health or social care agencies, benefit agencies, law enforcement. We can also receive information about you from other people you know and/or are linked to you, for example: parents or a person nominated to act on your behalf.

5.2       Some further examples of how we may gather your personal identifiable information are set out below:

• Directly from you, for example: when you telephone us, fill out a contact request or an application form on our website;
• From other organisations such as support providers, health and social care agencies and local authorities or councils that deal with you on our behalf; 

 

6. How we lawfully use your personal information

6.1      To provide you with our services we have a legal duty to confirm a person has the right to reside in the country. If we need to do this, we will need to obtain your name, contact details, date of birth, your current and previous countries of residence/citizenship, and a copy of identification documents (such as passport, home office residence papers and driving license). This information will be collected and verified but will not be stored by Key Unlocking Futures.

6.2       We might also need health and social care information (such as physical, social or mental health information or medication) to help support those who have a vulnerability and/or receive support from us.

6.3       To operate and administer our, support and services, including managing and responding to complaints, we sometimes need to gather, use and share your personal identifiable information.  The particular reasons we may need to do this are set out in more detail below:

 

1. a) We share data between our Group subsidiary companies (Progress Housing Association and Key Unlocking Futures) and our business areas trading as Progress Lifeline and Progress Living, where appropriate, to provide related and linked services.

 

1. b) We engage with IT Service providers to sometimes process data and to also support the computer systems that hold and process your information.

 

1. c) We may also share your information with Social Care agencies, DWP, Housing Associations and health professionals to support you with things that are having a negative impact on your life.

 

We use your personal and special identifiable information in this way because it is necessary to meet the conditions set out to meet our legal and regulatory obligations in relation to health and safety. 

6.4         We are required to report or share information with agencies where it is believed you or another person’s vital interests are at risk.  Examples include but are not limited to:

 

1. Where you or another person is at risk of physical, mental or sexual harm or damage.

 

1. b) Where you or another person is in need of being protected as a vulnerable person from significant harm or serious exploitation.

We use your personal and special identifiable information in this way because it is necessary to meet our legal and regulatory obligations and to protect yours and others’ vital interests. 

 Automated decision making

7.1       Key Unlocking Futures does not use any mechanisms for automated decision making. 

 

8. Our lawful basis for using your personal identifiable information

8.1       We only use your personal identifiable information where that is permitted by the laws that protect your privacy rights. This will be where:

• We need to use the information to comply with our legal obligations;
• We need to use the information to perform a contract with you; and/or
• it is fair to use the personal identifiable information either in our interests or someone else's interests, where there is no disadvantage to you – this can include where it is in our interests to contact you about products or services, market to you, or collaborate with others to improve our services;
• Where we need to seek your consent (if consent is needed).

8.2       Where we have your consent, you have the right to withdraw it. We will let you know how to do that at the time we gather your consent. See section 12 ‘Keeping You Up to Date’, clause 12.2 below, for details about how to withdraw your consent to marketing.

8.3       Special protection is given to certain kinds of personal information that is particularly sensitive. This is information about your health status, racial or ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership or criminal convictions or allegations. We will only use this kind of personal information where:

• We have a legal obligation to do so (for example to protect vulnerable people);
• It is necessary for us to do so to protect your vital interests (for example if you have a severe and immediate medical need whilst on our premises);
• It is in the substantial public interest;
• It is necessary for the prevention or detection of crime;
• It is necessary for insurance purposes; or
• You have specifically given us ‘affirmative’ consent to use the information.

 

 

9. Sharing your personal identifiable information with or getting your personal identifiable information from others

9.1       We will share personal identifiable information within the Group and with others outside Progress Housing Group where we need to do that to meet or enforce a legal obligation or where it is fair and reasonable for us to do so.

See section 4.2 ‘Personal Information’; or section 6 ‘How we use your personal identifiable information’ for more details.

 

9.2       Who we share your personal identifiable information with depends on the services we provide to you and the purposes for which we use your personal identifiable information. For most services we will share your personal identifiable information with our own service providers such as local authorities and crime prevention agencies.

See section 6 ‘How we lawfully use your personal information’ for more information on who we share your personal identifiable information with and why.

 

9.3       Most of the time the personal identifiable information we have about you is information you have given to us, or has been gathered by us in the course of providing services to you.

See section 6 ‘How we lawfully use your personal information’ for more information on who we get your personal information from and why.

 

10. Transfers outside of the UK

10.1      We may need to transfer your information outside the UK to companies, service providers, agents, subcontractors and regulatory authorities in countries where data protection laws may not provide the same level of protection as those in the European Economic Area, such as the USA. If we have to do this we ensure safeguards are put in place to protect your information and will inform you specifically if this will be the case when collecting that data or before processing the data in that country.

 

11. How long we keep your personal information for

11.1      How long we keep your personal information for depends on the services we deliver to you. We will never retain your personal identifiable information for any longer than is necessary for the purposes for which we need to use it, or while it can be used to raise a complaint or legal claim in relation to the products or services provided.

 

12. Keeping you up to date

12.1      We will communicate with you about products and services we are delivering using any contact details you have given us - for example by post, email, text message, social media, and notifications on our app or website.

For contact details, click here.

12.2     With your consent, we will send you newsletters, fundraising activities and the latest news via email. You can withdraw your marketing consent by contacting help@keycharity.org.uk or 01772 678979.