Reg, Charity 1112779; Company Ltd by Guarantee 5097785
In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our service users, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
A) DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
a) processing is fair, lawful and transparent
b) data is collected for specific, explicit, and legitimate purposes
c) data collected is adequate, relevant and limited to what is necessary for the purposes of
d) data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or
erased without delay
e) data is not kept for longer than is necessary for its given purpose
f) data is processed in a manner that ensures appropriate security of personal data including
protection against unauthorised or unlawful processing, accidental loss, destruction or damage
by using appropriate technical or organisation measures
g) we comply with the relevant GDPR procedures for international transferring of personal data
B) TYPES OF DATA HELD
We keep several categories of personal data on our service users in order to carry out effective and efficient processes. We keep this data in a file relating to each service user and we also hold the data within our computer systems.
Specifically, we hold the following types of data:
a) personal details such as name, address, phone numbers
b) your gender, marital status, information of any disability you have or other medical information
c) your GP details
d) information on your gender, sexual orientation, race and religion for equality monitoring
e) information gathered via yourself or third parties relating to your reasons for accessing our
f) criminal convictions
g) CCTV footage
C) COLLECTING YOUR DATA
You provide several pieces of data to us directly during the referral process and subsequently upon the start of your counselling
In some cases, we will collect data about you from third parties, such as social services.
Personal data is kept in files and within the Company’s IT systems.
D) LAWFUL BASIS FOR PROCESSING
The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the service contract we have with you.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
E) SPECIAL CATEGORIES OF DATA
Special categories of data are data relating to your:
b) sex life
c) sexual orientation
e) ethnic origin
We carry out processing activities using special category data:
a) for the purposes of equal opportunities monitoring
b) to determine reasonable adjustments
Most commonly, we will process special categories of data when the following applies:
a) you have given explicit consent to the processing
b) we must process the data in order to carry out our legal obligations
c) we must process data for reasons of substantial public interest
d) you have already made the data public.
F) FAILURE TO PROVIDE DATA
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of service with you. This could include being unable to offer you support.
G) CRIMINAL CONVICTION DATA
We will only collect criminal conviction data where it is appropriate given the nature of your offence and the safety of other service users. We rely on the lawful basis of legitimate interest to process this data.
H) WHO WE SHARE YOUR DATA WITH
Data is only shared with third parties for the following reasons:
•If a child under the age of 18 is being abused
•If an abuser from the past currently has access to the children
•If you are at significant risk to yourself or others
•If you inform us of any act of terrorism
•If you break the law and others are at risk of harm
We rely on the lawful basis of legal obligation to share this data.
We do not share your data with bodies outside of the European Economic Area.
I) PROTECTING YOUR DATA
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
J) RETENTION PERIODS
We only keep your data for as long as we need it for, which will be at least 6 years
K) AUTOMATED DECISION MAKING
Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
L) SERVICE USER RIGHTS
You have the following rights in relation to the personal data we hold on you:
a) the right to be informed about the data we hold on you and what we do with it;
b) the right of access to the data we hold on you;
c) the right for any inaccuracies in the data we hold on you, however they come to light, to be
corrected. This is also known as ‘rectification’;
d) the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
e) the right to restrict the processing of the data;
f) the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
g) the right to object to the inclusion of any information;
h) the right to regulate any automated decision-making and profiling of personal data.
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.
N) MAKING A COMPLAINT
If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
O) DATA PROTECTION COMPLIANCE
Our appointed compliance officer in respect of our data protection activities is:
Ron Dukelow, Manager
01274 733080 or firstname.lastname@example.org