JAM Card Privacy Notice
JAM Card User Privacy Notice
When you apply for a JAM Card or register for the JAM Card app, we need to collect some personal details about you so we can send the card to you or give you access to the app. We will take all possible steps to protect personal information. We are determined to do nothing that would infringe your rights or undermine your trust. This Privacy Notice describes the information we collect about you, how it is used and shared, and your rights regarding it. We would also like to give you some updates or news about JAM Card but you can say no to this if you don’t want to receive it.
We think it is important to keep your information safe so other people cannot use the information you give us if you don't want them to.
This notice tells you more about:
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Why we collect information from you
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What details we might need
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How we use your details
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How we keep your details safe
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Your data rights
Who are we?
JAM Card is operated by NOW Group a social enterprise registered as a company and a charity in UK and ROI that provides support for people with learning difficulties, autism and other conditions.
Our Head office and address for the Data Protection Officer is:
Ann Osborne
NOW Group
15-17 Grosvenor Road
Belfast BT12 4GN
Email: dpo@nowgroup.org
We are registered with the Information Commissioner’s Office (ICO) as a Data Controller for the personal data that we hold and process on your behalf. Our ICO registration number is ZA302134. If you need to contact us about your data or this privacy notice you can reach us at the above address.
How do we collect your personal information?
We collect your information when:
You register a JAM Card app
You order a JAM Card from us by phone or through our website.
What personal details do we collect?
We collect and process both personal data and special categories of personal data. This includes:
For the JAM Card
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Your name
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Your email address
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Your postal address
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Your postcode
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Your mobile number if you opt for updates
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Gender
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Your age band
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Your card-message type, i.e. ‘I have autism’
For the JAM Card app
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Your name
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Your email address
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Your postcode
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Your mobile number if you opt for updates
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Gender
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Your age band
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Your card-message type, i.e. ‘I have autism’
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Your location while you use the JAM Card App (longitude and latitude coordinates) when the location feature is enabled.
Why do we collect this information?
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We collect this information so we can post the card to you or send the app to your device.
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So we can set up a JAM Card App account for you.
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So we can give you news and updates, if you would like to receive them.
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So that we can gather information about how many people use the JAM Card, the locations they live in, and the types of disabilities or conditions they have, to help us raise awareness about the need for services to be more accessible.
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To gather your ratings on the places you visit or the services you use.
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To help us improve the training we deliver to JAM Card Friendly organisations by giving us more information about the profile of people using JAM Cards, e.g. age groups, conditions and where they live.
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We may need this information to apply for funding to provide JAM Cards and recruit more JAM Card Friendly organisations.
Special Category Information
The information we collect on the card message type you select is considered Special Category Information under data protection law. We safely store this information alongside the other data that we collect from you.
What lawful basis do we use for holding the information?
We will only process your personal information if we have a lawful basis to do so. This includes:
Consent. Where this is required, we will ensure that we have your specific consent for processing your data. You can withdraw your consent by contacting us.
Legitimate Interests. Examples of legitimate interests include:
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Where we process your data to provide you with the JAM Card or app;
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Provision of training and awareness services and advice;
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Processing necessary for management and administration of the charity, network and information security, including preventing unauthorised access;
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For completion of all regulatory requirements; and
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Processing for direct marketing purposes.
Special Category processing. We process special category data when we:
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Have your explicit consent to do so; or
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We are able to process data about your disability or condition as we are a not-for-profit body which provides support to individuals with a particular disability or medical condition.
How do we keep this information safe?
We respect your privacy and will keep your information safe and secure.
How long do we keep your personal data?
We will retain your data for as long as you use the plastic JAM Card or app. However if you no longer wish to use the app or the card your data can be deleted as below.
JAM Card App
If you no longer wish to use the JAM Card app you have the option of deleting the app data that we have gathered from you at the ‘Profile’ page of the JAM Card App. This includes the information that we collected when you registered as a JAM Card user and any subsequent data that we received from your app use.
JAM Card
If you no longer wish to use your plastic JAM card please contact us and we can remove your data. To do this you can contact our office (details above) and ask to speak to the Data Protection Officer or you can email dpo@nowgroup.org
Information we collect from other sources:
Standard internet log information, such as your IP address and visitor behaviour patterns. We use Google Analytics to analyse website traffic. You can get more information on Google's security and privacy principles here.
JAM Card App geolocation tracking
The app is designed to provide you with information on businesses and organisations that are nearest to you, this includes JAM Card Friendly ‘places’. The App uses precise geolocation services and accuracy will depend on your device and the GPS coverage of your location.
Location data is only recorded when the app is in use, this is optional and only occurs when you enable this feature in the app. If you prefer not to use this feature you can disable this in your device settings.
Do we share your personal information?
We share your personal information with our third-party JAM App developer for the purposes of maintaining the app and website. If you request a ‘Dementia’ JAM Card we share your contact details with our partner Dementia NI to enable them to post a card out to your address. Agreements are in place to ensure data security and privacy.
We may share your anonymised data for research and funding purposes to third parties.
If you are a JAM Card App user living outside the UK, we may transfer your data to the UK. We have ensured we have additional data protection safeguards in place to securely transfer your personal data to the UK.
Have you heard about GDPR?
GDPR is a law about keeping personal information safe. Under this law you can do the following
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You can ask us to let you see the information that we hold about you so you can check it is correct.
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You can ask us to change information that is not correct.
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In certain circumstances you can ask us to delete your information if you do not want us to hold it.
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You can tell us that you do not want to receive any more information from us.
Contact the Information Commissioners Office
The Information Commissioners Office is responsible for making sure that GDPR Data Protection laws are carried out. You can contact them by following this link: https://ico.org.uk/concerns/.
Privacy Notice for E Learning Platform
Data Protection
The operation of the JAM Card E learning platform requires the sharing of employee data between the customer and NOW Group. As a data processor NOW Group undertakes to hold personal data relating to employees in accordance with the Data Protection Act.
Data shared between customer and NOW Group
As the customer and data controller the customer will share the following with NOW Group
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First name and surname of employee (learner)
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Email address of employee. This will be a business email address when available. Personal email addresses will only be used where a business email address is not available.
Purpose for sharing data
In line with our data protection principles, we have designed the system to operate with the minimum personal data. The data is used for the following purposes
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To provide a learner profile for logging on to the system
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To provide a record of learners who have completed the training
Data Retention
We will retain the personal data as above for as long as your company remains a customer of the learning platform to provide you with a record of employees who have completed the training. However, as the data controller, you may determine your own retention period for this data and we can act in accordance with your own instructions to delete records in accordance with your internal data retention policies
Sharing of data
We do not use sub-processors and the data will not be shared beyond NOW Group with the exception of the learning platform contractor for purposes of operating the system.
Appropriate security measures
We will ensure appropriate technical and organizational measures to provide a level of security appropriate to ensure protection of data including how data is accessed and stored. We shall notify you without undue delay upon becoming aware of a potential Personal Data Breach affecting relevant Personal Data, and will provide you with sufficient information to allow you to meet any obligations to report or inform Data Subjects.
Data subjects’ rights
We will provide all necessary assistance to the customer in respect of supporting individuals to exercise their data protection rights including for example the right to erasure. In the event of a subject access request coming directly to NOW Group this will be passed to the customer at earliest possible opportunity.
End-of-contract provisions
All personal data will be returned to the customer and removed from the platform at end of contract.
