Brahma Kumaris - GDPR Privacy Notice

Scope

The scope of the Privacy Notice concerns all data subjects whose personal data is processed, in line with the requirements of the GDPR.

Responsibilities

2.1

The Brahma Kumaris World Spiritual University (BKWSU UK) as Data Controller is responsible for ensuring that this Privacy Notice is made available to data subjects prior to the BKWSU (UK) collecting and processing their personal data.

2.2

All volunteers of the BKWSU (UK) who interact with data subjects are responsible for ensuring that this Notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

Privacy Notice

3.1

Who are we?

The BKWSU (UK) teaches Raja Yoga as a way of experiencing peace of mind and a positive approach to life.

The University provides opportunities for people from all religious and cultural backgrounds to explore their own spirituality and learn skills of reflection and meditation derived from Raja Yoga, which will help develop inner calm, clear thinking and personal well-being.

The BKWSU (UK) is registered as Data Controller with the Information Commissioner’s Office under registration reference: Z6079264

The BKWSU (UK) GDPR Team can be contacted directly as follows:

GDPR Team
Global Cooperation House
65-69 Pound Lane, London NW10 2HH
Tel 0208 8727 3350

Cette adresse e-mail est protégée contre les robots spammeurs. Vous devez activer le JavaScript pour la visualiser.

The personal data we would like to collect and process:

personal information	obtained directly from the data subject / or from affiliate organisations
special category data	obtained directly from the data subject / or from affiliate organisations

The personal data we collect will be used for one or more of the following purposes:

to organise events such as: seminars / workshops / courses / retreats / talks
to keep data subjects up to date with information about events (this can be via newsletters / E-flyers)
to comply with legal obligations of the Data Controller such as: health and safety regulations / financial regulations / immigration laws / child protection laws / requirements regarding wills and charitable legacies / for insurance purposes
to enable travel coordination
purposes regarding Information Technology Management
for marketing purposes
to manage Volunteers

Our legal basis for processing personal data, is at least one of the following:

processing is necessary to comply with legal obligations of the Data Controller
data subject gives consent for one or more specific purposes
processing is necessary to protect the vital interests of the data subject
special protection is in place for personal data related to children and vulnerable adults

The special categories of personal data are:

health (to accommodate for guests / participants with special needs, diet requirements or other health information processed in the vital interest of the data subject)
lifestyle practices (to visit spiritual headquarters in India)
DBS (Disclosure and Barring Service) checks

3.2

Consent

By consenting to this Privacy Notice you are giving us permission to process your personal data and special category data specifically for the purposes as identified above.

Consent is required for the BKWSU(UK) to process both types of personal data, but it must be explicitly given. Where we are asking you for special category data, we will always tell you why and how the information will be used.

You may withdraw consent at any time by notifying the GDPR Team via email (Cette adresse e-mail est protégée contre les robots spammeurs. Vous devez activer le JavaScript pour la visualiser.) in line with the withdrawal of consent procedures.

3.3

Disclosure

The BKWSU(UK) will only pass on your personal data to third parties or transfer personal data to affiliate organisations in third countries and/or EU countries with your consent or to comply with legal requirements under GDPR.

The following third parties and non-EU countries (third countries) will receive your personal data as part of the processing activities:

Third parties in the UK	Safeguards in place to protect your personal data
Disclosure and Barring Service (DBS)	Encryption of personal data in transit by using suitable encryption solutions (e.g recent versions of TLS online or encrypted devices) Authentication, authorization and audit of data access or delivery.
HM Revenue & Customs
First Aid Training Providers
Travel Agencies
Insurance Companies
Professional Bodies (Auditors, Solicitors, Banks etc.)

Third countries (non-EU) and EU countries	Safeguards in place to protect your personal data
As the Brahma Kumaris is part of a worldwide network in more than 100 countries, some of the data might be shared within the Brahma Kumaris network.	Encryption of personal data in transit by using suitable encryption solutions (e.g recent versions of TLS online or encrypted devices). Authentication, authorization and audit of data access or delivery. Memorandum of Understanding with independent Brahma Kumaris establishments in non-EU countries

3.4

Retention period

The BKWSU (UK) will process personal data for as long as strictly needed as per the GDPR requirements and will store the personal data in line with the BKWSU Retention of Records Policy.

Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply, you have the right to restrict the processing.
Right of portability – you have the right to request the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right to object to automated processing or profiling.
Right to judicial review: in the event that the BKWSU (UK) refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

3.5

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by the BKWSU (UK) or third parties as described in 3.4 above, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and the BKWSU (UK) GDPR Team.

The details for each of these contacts are:

	Supervisory authority contact details	Data Controller (the BKWSU UK)
Contact Name:	Information Commissioner's Office	GDPR Team
Address line 1:	Wycliffe House	Global Cooperation House
Address line 2:	Water Lane	65-69 Pound Lane
Address line 3:	Wilmslow	London NW10 2HH
Address line 4:	Cheshire SK9 5AF
Email:	Cette adresse e-mail est protégée contre les robots spammeurs. Vous devez activer le JavaScript pour la visualiser.	Cette adresse e-mail est protégée contre les robots spammeurs. Vous devez activer le JavaScript pour la visualiser.
Telephone:	ICO Helpline 0303 123 1113	Tel 020 8727 3350

Online privacy statement

4.1

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

4.2

How we use your information

This privacy notice tells you how we, the BKWSU (UK) will collect and use your personal data to invite you to events, retreats or public programmes, to comply with legal requirements of the Data Controller, such as insurance purposes, health and safety regulations, financial regulations, immigration laws, child protection laws etc.

4.3

Why does the BKWSU (UK) need to collect and store personal data?

In order for us to provide you with information about public events, retreats, or to host you as a guest on our premises, or in line with legal requirements we need to collect personal data. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
In terms of being contacted for marketing purposes the BKWSU (UK) will contact you for additional consent.

4.4

Will the BKWSU (UK) share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to the BKWSU (UK) in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to the purpose the data has been collected. When they no longer need your data to fulfil this service, they will dispose of the details in line with the GDPR. If we wish to pass your special category data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

4.5

How will the BKWSU (UK) use the personal data it collects about me?

The BKWSU (UK) will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulations. We will endeavour to keep your information accurate and up to date, and not keep it for longer than strictly needed.

The BKWSU (UK) is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

4.6

Under what circumstances will the BKWSU (UK) contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

4.7

Can I find out the personal data that the BKWSU (UK) holds about me?

The BKWSU (UK), at your request, can confirm which information we hold about you and how it is processed. If the BKWSU (UK) does hold personal data about you, you can submit a request for access to personal data in line with the General Data Protection Regulations.

4.8

What forms of ID will I need to provide in order to access this?

When information on your personal data is requested, the BKWSU (UK) requires one of the following or a combination of the following IDs: any ID which has a valid and recent photograph / address details /passport, driving licence / birth certificate / recent utility bills.