1. Introduction
We exist to speak up for Royal Navy Royal Marines families on matters of concern to them. In appropriate circumstances we also advocate on behalf of families who have struggled to resolve an issue.
Our Privacy Policy covers families, colleagues, beneficiaries and trustees.
The NFF is a registered charity, which operates outside of the Royal Navy’s chain of command. With respects to the management of your personal information, the NFF organisation is the Data Controller.
This Privacy Policy sets out the data processing procedures for the Naval Families Federation (NFF) and describes how we securely manage and retain personal information.
2. Personal Data
Personal data is any information relating to an individual which can identify them, either directly or indirectly.
This definition provides for a wide range of personal identifiers to constitute personal data, including your name, an identification number, your location details or other online identifiers
3. How does the NFF process your personal data?
We comply with the relevant legislation, including the General Data Protection Regulations (GDPR). Information provided by anyone contacting the NFF is treated in strict confidence and with the greatest respect. It is only accessible to NFF staff members, all of whom have signed a confidentiality agreement, and is held on a secure, encrypted database or in a secure facility within the NFF offices.
4. What is the legal basis used by the NFF for processing your personal data?
- When we provide services to an individual, we use the legal basis of ‘Legitimate Interest’.
- For employees, we use the legal basis of ‘Contract’. This includes the application process.
5. Why do we collect your personal data?
The personal data we collect, and hold, is provided by the individual to whom it relates. This data may be shared with us for a variety of reasons, such as:
- To support an individual enquiry
- In response to a request for opinions, evidence or feedback (such as through online surveys)
- To subscribe to our communications package (e.g. Homeport, regular e-updates, social media sites)
- To participate in our competitions
6. What do we use your personal data for?
- To enable NFF staff to respond to personal enquiries and provide bespoke advice and information to you.
- To keep you informed of any relevant news, events or announcements that you might be interested in. We rely on you to contact us and initially request these updates, via our quarterly magazine, Homeport, and our regular e-updates.
- To manage our employees.
7. Sharing your personal data?
Your personal data will only be passed to a third party, such as Service Family Accommodation issues, with your specific permission and only for the purpose of resolving your enquiry.
Any evidence-based reports going to higher authority (for example, the Royal Navy’s chain of command or the Ministry of Defence) which draw upon information contained in the database will be generic in content, highlighting trends and themes rather than individual cases.
We will only pass your personal data to a third party if we are assured that they:
- Abide by the requirements of all relevant data protection and privacy legislation
- Treat your information as carefully as we would
- Only use the information for the purposes it was provided
8. How long do we keep your personal data?
We may retain data to inform our current and future activities and will only hold it for as long as required.
These activities could include analysing reported issue types to identify trends or highlight if a particular policy is creating an unintentional disadvantage for Naval Service families. When we no longer need this information, we will always dispose of it securely, using specialist companies as and when required.
9. Your rights
Unless subject to an exemption under legislation, you have the following rights with respect to your personal data:
- The right to be informed about the collection and use of your personal data
- The right to request a copy of the personal data which NFF holds about you. This request can be submitted either in writing, via e-mail or verbally.
- The right to request that NFF corrects any personal data if it is found to be inaccurate and incomplete. This request can be submitted either in writing, via e-mail or verbally.
- The right to request that your personal data is erased. This request can be submitted either in writing, via e-mail or verbally. This right is not absolute and only applies in certain circumstances.
- The right to withdraw your consent to the NFF processing your data at any time
- The right to request that the NFF transmits your data directly to another data controller, where possible. This is known as the right to data portability and there are certain criteria which have to be applied.
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing
- The right to object to the processing of personal data
- The right to lodge a complaint with the Information Commissioners Office.
If you wish to exercise any of these rights please contact the Data Protection Coordinator at the Naval Families Federation, Building 25, HMS EXCELLENT, Portsmouth, PO2 8ER, by email at contactus@nff.org.uk or by telephone at 023 9265 4374.
10. What do we do with your personal data?
We will use the personal data you provide to:
- Respond to your individual enquiries. This could involve a direct response to you, via email, telephone or face-to-face or to support a request for additional information and action from a third party. We will always seek your consent before releasing any personal information to a third party. If the information you share with us is considered to be special category data, which was formerly known as sensitive personal information, it will be handled in accordance with the appropriate legislation.
- Record any contact we have with you on our confidential, encrypted database
- Inform our evidence based reports. These are anonymised reports and no personal information is included as we only refer to the nature of the enquiry, the outcome or the impact that a specific policy has had upon families in general terms.
- To carry out research on the demographics of those family members who contact us. This will help us gain a better understanding of the types of issues that certain families might face e.g. dual-serving couples.
- Communicate with you. This could include sending you copies of our magazine Homeport or our monthly e-newsletter regular e-updates. This would only occur in response to a request from you
11. Exceptional Circumstances
Your information is considered confidential except in extreme circumstances such as:
- Serious risk of harm to you or to others around you.
- When your behaviour presents a serious risk to the legal rights of others.
- When staff have been placed in a position that compromises their professional integrity.
- To prevent a serious criminal act; especially where others may be endangered, for example an act of terrorism.
- To protect the operational efficiency of the Service. For example; an individual calling to say that his/her Naval Service partner has just gone to work under the influence of drugs that could compromise the security and safety of serving personnel and/or their equipment.
If NFF staff consider that, in these rare cases, confidentiality is not possible, they will try to encourage individuals to disclose the information voluntarily to the appropriate authorities. In such cases the individual will be made aware that the information provided cannot be kept within the confines of the NFF and that it will have to be shared with the authorities concerned.
12. Storing your information
All personal data we hold in electronic format on our database is securely stored by our service provider ICARIS Ltd, who fully comply with the GDPR regulations and all other relevant legislation. ICARIS Ltd ensures that the latest standards for security and data protection are met and exceeded for the ICARIS platform, including the protection of personal and confidential data.
These standards include operating an information security management system (ISMS) in accordance with the ISO/IEC 27001:2013 standard.
We treat your personal data as if it was our own and have put all reasonable measures in place to ensure that it is held and transmitted securely. We have a range of processes in place to protect against the lost, misuse or alteration of any personal data we hold and we use secure server software (SSL) to encrypt personal information.
13. Use of Cookies
To ensure we are publishing content customers need and want, the Naval Families Federation collects aggregated site-visitation statistics using cookies. When someone visits the site, a cookie is placed on the customer’s machine (if the customer accepts cookies) or is read if the customer has visited the site previously. If you choose to not have your
browser accept cookies from the Naval Families Federation’s website, you will need to re-enter your personal information each time that you attempt to access premium information.
14. Changes to our Privacy Policy
Any future changes to our Privacy Policy will be made available on our website at www.nff.org.uk.
15. Contact Details
To exercise all relevant rights, queries or complaints please contact:
The Data Protection Coordinator, Naval Families Federation, Building 25, HMS EXCELLENT, Portsmouth, PO2 8ER, by email at contactus@nff.org.uk or by telephone at 023 9265 4374.
If you believe that your complaint has not been resolved to your satisfaction, you can also contact the Information Commissioners Office on 0303 123 1113, by email at https://ico.org.uk/global/contact-us/ or write to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
