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Hub Privacy Policy

Organisation Hub System

Last Updated: January 12, 2025

Introduction

This Privacy Policy explains how personal information is collected, stored, used, and protected within the Hub, your organisation's management system. The system is designed for use in the UK and supports compliance with UK GDPR and UK data protection law. This policy applies to all data stored in the Hub and is intended for Hub administrators and anyone whose information is stored in the system.

Who We Are

Eltham Green Community Church

17 Arbroath Road, Eltham, London SE9 6RR

Contact:

Data Protection Coordinator

Email: daniel.bull@egcc.co.uk

Why We Store Your Information

We store personal information in the Hub to support the organisation's operations. Here are the specific purposes for which we collect and store data:

Contact Management and Communication

Why we store this: To maintain accurate contact information so we can communicate with contacts and members about activities, events, and important updates.

What this enables:

  • Sending newsletters and communications
  • Coordinating events and activities
  • Managing contact lists for different groups and lists

Event and Member Coordination

Why we store this: To organise events, manage member schedules, and coordinate participation in activities.

What this enables:

  • Planning and organising events and activities
  • Managing event signups and attendance
  • Creating and managing member schedules for services and events
  • Sending event invitations and reminders
  • Coordinating members

Meeting Planning

Why we store this: To plan meetings, coordinate participants, and maintain planning information.

What this enables:

  • Planning meetings and sessions
  • Coordinating speakers and participants
  • Maintaining planning notes and information
  • Managing meeting-related schedules

Form Submissions and Safeguarding

Why we store this: To process inquiries and handle safeguarding concerns in a secure and confidential manner.

What this enables:

  • Processing general inquiries and requests
  • Handling safeguarding concerns and reports (with special encryption)
  • Collecting information through dynamic forms

Newsletter and Communication Preferences

Why we store this: To respect your communication preferences and track the effectiveness of communications.

What this enables:

  • Managing newsletter subscriptions
  • Tracking communication preferences
  • Measuring engagement with communications

Admin User Accounts and Security

Why we store this: To manage Hub access securely, maintain accountability, and protect the system and data.

What this enables:

  • Secure authentication and access control
  • Audit trails for accountability and security
  • System administration and management

Audit Logging Information

Why we store this: To maintain security, accountability, and compliance with data protection requirements.

What we collect:

  • IP addresses of Hub administrators when they access the system or perform actions
  • User agent information (browser and device type) for security monitoring
  • Timestamps of all system access and data changes
  • Details of actions performed in the Hub

What this enables:

  • Security monitoring and fraud prevention
  • Accountability for data access and changes
  • Investigation of security incidents
  • Compliance with data protection regulations

Who Has Access to Your Information

Access to personal information in the Hub is strictly controlled based on role-based permissions. Here's who can access what:

Super Admin

Who: Designated lead administrator(s)

Access: Full access to all data and system functions

Why they need access: To oversee all operations, manage the Hub system, and ensure proper administration of activities.

What they can do: View, edit, and delete all records; manage admin users; access all areas including safeguarding forms; configure system settings.

Administrators with Full Access

Who: Designated leaders and senior administrators

Access: Contacts, lists, schedules, events, event planners, newsletters, and forms

Why they need access: To manage operations, coordinate activities, and communicate with the community.

What they can do: Manage contacts, create schedules, plan events, send newsletters, view form submissions, coordinate members and rotas.

Administrators with Limited Access

Who: Coordinators with limited access

Access: Specific areas based on their role (e.g., schedules only, events only, contacts only)

Why they need access: To fulfill their specific responsibilities without accessing unnecessary information.

What they can do: Access only the areas they need for their specific responsibilities (e.g., schedule coordinators can manage schedules but not access newsletters).

Safeguarding Officers

Who: Designated safeguarding officers

Access: Special access to safeguarding forms and encrypted data

Why they need access: To handle safeguarding concerns confidentially and in accordance with legal requirements.

What they can do: View and manage safeguarding form submissions (encrypted data); cannot access other sensitive information unless specifically authorised.

General Administrators

Who: General administrators

Access: Contacts, lists, schedules, events, and event planners

Why they need access: To support general administration and coordination.

What they cannot access: Newsletters, forms, safeguarding data.

Public Access (Token-Based)

Who: Members and participants

Access: Limited access via secure tokens for specific purposes

Why they need access: To sign up for schedules and events without requiring Hub accounts.

What they can do: Sign up for schedules and events using unique, time-limited tokens.

What they cannot do: View other people's information, access the Hub directly, or see any data beyond what's necessary for their signup.

How Your Information Is Used

Personal information in the Hub is used exclusively for organisation operations:

Administration

  • Maintaining accurate contact records
  • Organising and managing the contact database
  • Facilitating community connections
  • Coordinating member assignments

Event Management

  • Planning and organising events and activities
  • Managing event registrations and attendance
  • Maintaining calendar and event schedules
  • Displaying public events on the organisation website

Member Coordination

  • Creating and managing member schedules for services and events
  • Assigning members to specific roles and dates
  • Sending automated reminders to members
  • Sending invitations to members for schedule signups

Communication

  • Creating and sending newsletters and updates
  • Inviting people to events and activities
  • Reminding members of their upcoming commitments

Meeting Planning

  • Planning meetings and sessions
  • Coordinating speakers and topics
  • Maintaining notes and planning information

Form Management

  • Collecting and managing form submissions
  • Processing safeguarding concerns and reports (encrypted)
  • Managing general inquiries and requests

Reporting and Analytics

  • Tracking event attendance and participation
  • Reporting on member participation and schedules
  • Tracking newsletter engagement

Data Sharing Within the Organisation

Personal information may be shared within the organisation in the following ways:

Contact Lists

  • Contact information may be included in lists for specific groups (e.g., activity groups)
  • Lists are used for targeted communication and coordination
  • List membership is managed by authorised administrators

Schedule Information

  • Names and contact information may be visible to other members on the same schedule
  • This enables coordination and communication between members
  • Schedule information is shared only with those who need it for coordination

Data Security

We take data security seriously and have implemented multiple security measures:

Access Controls

  • Role-based permissions: Access is restricted based on user roles and permissions
  • Authentication required: All Hub access requires secure login credentials
  • Password security: Strong password requirements and secure password hashing (bcrypt)
  • Session management: Secure session management with automatic expiration
  • Account lockout: Accounts are locked after multiple failed login attempts

Encryption

  • Safeguarding data: Safeguarding form submissions are encrypted using AES-256-GCM encryption
  • Data transmission: All data transmission uses HTTPS encryption
  • Password storage: Passwords are hashed and never stored in plain text

Audit Logging

  • Access logs: All system access is logged for security and accountability
  • Change logs: All data changes are logged with timestamps and user information
  • Audit trails: Complete audit trails are maintained for sensitive operations
  • IP addresses: IP addresses of Hub administrators are recorded when they access the system or perform actions for security and accountability purposes
  • User agent information: Browser and device information is logged to help identify and prevent unauthorised access

Data Storage

  • Secure storage: Data is stored securely on Railway hosting platform
  • Backup procedures: Regular backups are maintained for data recovery
  • Access restrictions: Data files are accessible only to authorised administrators

Input Validation

  • Input sanitization: All user input is sanitized to prevent security vulnerabilities
  • CSRF protection: Forms are protected against cross-site request forgery attacks
  • HTML sanitization: HTML content is sanitized to prevent XSS attacks

Your Rights

Under UK GDPR and Data Protection Act 2018, you have the following rights regarding your personal information:

Right to Access

You can request a copy of the personal information we hold about you in the Hub by contacting the organisation using the details in the "Who We Are" section.

Right to Rectification

You can request that we correct any inaccurate or incomplete information about you.

Right to Erasure

You can request that we delete your personal information, subject to legal and safeguarding obligations that may require us to retain certain records.

Right to Restrict Processing

You can request that we limit how we use your personal information in certain circumstances.

Right to Data Portability

You can request a copy of your data in a structured, machine-readable format.

Right to Object

You can object to certain types of processing, such as inclusion in directories or certain communications.

Where we process your data based on consent, you can withdraw that consent at any time.

To exercise any of these rights, please contact the organisation using the details in the "Who We Are" section. We will respond to your request within one month.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this policy:

  • Active contacts: Data is retained while you are an active contact or regular participant
  • Former contacts: Basic contact information may be retained for historical records and reconnection purposes
  • Safeguarding records: Retained in accordance with legal requirements and safeguarding policies
  • Audit logs: Retained for security and accountability purposes (including IP addresses and user agent information)
  • Event records: Retained for historical records and planning purposes
  • Schedule records: Retained for historical records and member coordination

Safeguarding Data

Safeguarding form submissions receive special protection:

  • Encryption: All safeguarding data is encrypted using AES-256-GCM encryption
  • Access restrictions: Only designated safeguarding officers can access safeguarding data
  • Audit logging: All access to safeguarding data is logged
  • Legal compliance: Data is retained in accordance with legal requirements
  • Confidentiality: Safeguarding information is never shared except as required by law or safeguarding policies

Third-Party Services

We use the following third-party services that may process your data:

Mailgun (Email Service)

  • Purpose: Sending newsletters and transactional emails
  • Data shared: Email addresses and names only
  • Privacy Policy: https://www.mailgun.com/legal/privacy-policy/

Railway (Hosting Provider)

  • Purpose: Hosting the Hub system and data storage
  • Data stored: All Hub data files (including uploaded images)
  • Privacy Policy: https://railway.com/legal/privacy

All service providers are required to protect your data and use it only for the purposes we specify.

Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top indicates when changes were made. Significant changes will be communicated to Hub administrators and, where appropriate, to contacts.

Contact Us

If you have questions, concerns, or wish to exercise your rights regarding this Privacy Policy or your personal data, please contact your organisation using the details in the "Who We Are" section.

Complaints

If you are not satisfied with how we handle your personal information, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

Website: https://ico.org.uk

Phone: 0303 123 1113

For Hub Administrators

Your Responsibilities

As a Hub administrator, you have a responsibility to:

  • Protect data: Keep login credentials secure and never share your account
  • Use data appropriately: Only access and use data for legitimate organisation purposes
  • Respect privacy: Respect the privacy of contacts and their information
  • Report concerns: Report any security concerns or data breaches immediately
  • Follow policies: Follow organisation policies and procedures for data handling

Access Logging

All your actions in the Hub are logged for security and accountability:

  • Access logs: Records of when you access the Hub
  • Action logs: Records of data changes you make
  • Audit trails: Complete audit trails for sensitive operations

Permission Levels

Your access to Hub areas is based on your assigned permissions:

  • Check your permissions: View your permissions in your profile page
  • Request access: Contact the Super Admin to request additional permissions if needed
  • Understand restrictions: Be aware of what data you can and cannot access

Safeguarding Data

If you have access to safeguarding forms:

  • Confidentiality: Maintain strict confidentiality of safeguarding information
  • Legal compliance: Follow legal requirements for handling safeguarding data
  • Reporting: Report safeguarding concerns through proper channels
  • Access logging: Be aware that all access to safeguarding data is logged
This Privacy Policy is effective as of the date listed above and applies to all personal information stored in the Hub system.