You can be confident that:
· We only use personal information in the ways we need to and that is expected of us.
· We will keep you up to date with our work including any relevant services, raising awareness, promoting understanding as well as our fundraising activities.
· But, we only use your personal information to do this if you have previously told us that’s OK.
· We will make it easy for you to tell us how you want us to communicate with you, including how to opt out from future communications – and we promise your request will respected straight away.
· We will never release your information to organisations outside Brent, Wandsworth & Westminster Mind (BWW Mind) for their marketing purposes.
· We will be especially careful and sensitive when engaging with vulnerable people or those we have reason to believe might be vulnerable.
· We take all reasonable care to safeguard your personal information through security policies and secure business processes.
· We will always provide easy ways for you to contact us and will be happy to answer any queries you have as quickly as possible but no longer than five working days.
2. Who we are
Here at BWW Mind, we are committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner.
We are a “data controller” for the purposes of the Data Protection Act 1998 and the EU General Data Protection Regulations (effective 25 May 2018). This means that we are responsible for, and control the processing of your personal information.
For further information about our privacy practices, please contact our Data Protection Officer by:
· Writing to BWW Mind, 6 Osbert St, London, SW1P 2QU
· Calling us on 020 7259 8100
· Emailing us at: firstname.lastname@example.org
3. How we collect information about you
Everything we do, we do to ensure that we can help people experiencing a mental health problem get both support and respect. We want to make sure you receive the support and communication that are most relevant to you, be it through visiting our website contacting us directly, through a referral, e-mail, post or phone call.
We collect information from you in the following ways:
· When you interact with us directly: This could be if you ask us about our services, activities, register with us for training or an event, make a donation to us, ask a question about mental health, purchase something, apply for a job or volunteering opportunity or otherwise provide us with your personal information. This includes when you phone us, visit our website or get in touch through the post, or in person.
· When you interact with us through partners or suppliers working on our behalf.
· When you interact with us through third parties: This could be if you provide a donation through a third party or one of the other third parties that we work with and provide your consent for your personal information to be shared with us.
· When you visit our website: We may gather general information which might include which pages you visit most often and which services, events or information is of most interest to you. We may also track which pages you visit when you click on links in emails from us. We also use “cookies” to help our site run effectively. There are more details below – see ‘Cookies’.
Wherever possible all information mentioned above is anonymized (meaning no one can identify you based on collected information) unless you are specifically asked or specifically told that the personal information will be taken.
We may use this information to personalise the way our website is presented when you visit to make improvements and to ensure we provide the best service and experience for you.
From other information that is available to the public: In order to tailor our communications with you to your background and interests we may collect information about you from publicly available sources or through third party subscription services or service providers (we have provided further details about this below – see ‘Profiling: Making our work unique to you’).
4. Information we collect and why we use it
Personal information we collect includes details such as your name, date of birth, email address, postal address, telephone number and credit/debit card details (if you are making a purchase or donation), as well as information you provide in any communications between us. You will have given us this information whilst making a donation, registering for an event, placing an order on our website or any of the other ways to interact with us.
We will mainly use this information:
· To provide the important services, advice and support you’ve asked for.
· To process your donations or other payments, to claim Gift Aid on your donations and verify any financial transactions.
· To provide you with the goods that you have requested.
· To comply with the Charities (Protection and Social Investment) Act 2016 and follow the recommendations of the official regulator of charities, the Charity Commission, which require us to identify and verify the identity of supporters who make major gifts so we can assess any risks associated with accepting their donations.
· To keep a record of your relationship with us.
· Where you volunteer with us, to administer the volunteering arrangement.
· Provide or administer activities relating to all our services: updating you with important administrative messages, to help us identify you when you contact us, and help us to properly maintain our records.
· Improve your experience with us. We may use your information to enhance the service that our staff provide, to fulfil your donations and gift aid declarations, to improve our information and communications, or to personalise the website to better suit your needs.
· Provide you with information about our plans. This may be letting you know about new or enhanced services that we hope will be useful and interesting to you, and may include fundraising updates; of course, we will only do this either with your consent, where we need to fulfil a contract or service with you, or where we believe you will expect to be updated and contacted by us. You can of course ask us at any time to change how we contact you, simply contact ‘email@example.com’.
· Analyse the personal information we collect about you so that we can better understand our supporters, their preferences and needs and important trends. This may mean looking at all the interactions you have with us so we can aim to offer you the right information or offers at the right time; including financial interactions so we can ensure we ask you for an appropriate level of support. It may also mean using external sources of information about you, the area where you live, or people like you, so we can better inform how we talk to you about our work. We believe this enables us to offer you more appropriate offers and communications, but you can opt out of this activity at any time. To do this please email ‘firstname.lastname@example.org’ with the subject line ‘Please stop analysis of my data’.
· We may need to disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to enforce other agreements which are relevant to our business and legal.
If you do not provide this information, we may not be able to provide you with the services, advice and support you have requested, sign you up for a particular event, provide goods requested or process your donation.
We may also use your personal information:
· To contact you about our work and how you can support BWW Mind (see section 7 on ‘Marketing’ below for further information).
· To invite you to participate in surveys or research.
Sensitive Personal Information
You can of course decide if you want to remain anonymous, if you are happy to share your personal details with staff members or if you would like us to share your story with the media or other parties as part of our work telling people’s personal stories about mental health (for example, on a blog).
A special note about the Sensitive Personal Information we hold
Data Protection Law recognises that some categories of personal information are more sensitive. Sensitive Personal Information can include information about a person’s health, race, ethnic origin, political opinions, sex life, sexual orientation or religious beliefs.
We will only use this information:
· For the purposes of dealing with your enquiry, training, and quality monitoring or evaluating the services we provide.
· We will not pass on your details to anyone else without your express permission except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or posing a threat to others or children contacting us and sharing serious issues such as physical abuse or exploitation.
· Where you have given us your express consent or otherwise clearly indicated to us that you are happy for us to share your story, then we may publish it on our blog or in other media.
5. Profiling: making our work more unique to you
We want to improve how we talk to you and the information we provide through our website, services, products and information. To do this we may use profiling and screening methods so that we can better understand our supporters, your preferences and needs to provide a better experience for you.
We may carry out targeted fundraising activities using profiling techniques based on the information that we hold about you. We may also work with third party organisations who provide additional insight, this may include providing wealth screening information or general information about you that is publicly available.
This information can be appended to the information that you have provided which allows us to use our resources more effectively by better understanding the background of our supporters and making appropriate requests based on what may interest them and their capacity to give.
You can of course opt out of this activity at any time. To do this, email email@example.com with the subject line ‘Please stop analysis of my data’ or by contacting our Data Protection Officer at: BWW Mind, 6 Osbert St, London, SW1P 2QU or by calling us on 020 7259 8100.
6. Legal basis for using your information
In some cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a contract with you.
However, there are other lawful reasons that allow us to process your personal information and one of those is called ‘legitimate interests’. This means that the reason that we are processing information is because there is a legitimate interest for BWW Mind to process your information. This is in order for us to provide you with the services, support and advice you have requested and to help us to achieve our vision of ensuring that everyone experiencing a mental health problem gets both care and respect.
Whenever we process your Personal Information under the ‘legitimate interest’ lawful basis, we make sure that we take into account your rights and interests and will not process your personal information if we feel that there is an imbalance.
We will only contact you about our work and how you can support Mind by phone, email or text message, if you have agreed for us to contact you in this manner.
However, if you have provided us with your postal address we may send you information about how you can support BWW Mind by mail. Unless you have told us that you would prefer not to hear from us in that way.
You can update your choices or stop us sending you these communications at any time by contacting firstname.lastname@example.org or clicking the unsubscribe link at the bottom of the relevant communication.
8. Sharing your Information
The personal information we collect about you will mainly be used by our staff (and volunteers) at Mind so that they can support you.
We will never sell or share your personal information with organisations so that they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity.
BWW Mind may however share your information with our trusted partners and suppliers who work with us on or on our behalf to deliver our services, but processing of this information is always carried out under our instruction. We make sure that they store the data securely, delete it when they no longer need it and never use it for any other purposes. Some examples of where we may share your information are:
· With partners who help us provide you with the services and support you have requested.
· With relevant bodies interested in your wellbeing (i.e. GP’s, NHS, Social Services, Community Mental Health Teams).
· With our partners who help us to process donations and claim Gift Aid.
· With our partners who help us to manage our social media accounts.
Where relevant we enter into contracts with these service providers that require them to comply with Data Protection Laws and ensure that they have appropriate controls in place to secure your information.
On occasions we will share your personal information with other local Minds to ensure that they are able to provide their services effectively, when there is a reason to do so we will only share your personal information with other local Minds with your consent.
We may disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to enforce our conditions of sale and other agreements.
9. Keeping your information safe
We take looking after your information very seriously. We’ve implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.
Unfortunately the transmission of information using the internet is not completely secure. Although we do our best to protect your personal information sent to us this way, we cannot guarantee the security of data transmitted to our site.
Our websites may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites. Please be aware that advertisers or Web sites that have links on our site may collect personally identifiable information about you. This privacy statement does not cover the information practices of those websites or advertisers.
Any debit or credit card details which we receive on our website are passed securely to our payment processing partner, according to the Payment Card Industry Security Standards.
10. How long we hold your information for
We only keep it as long as is reasonable and necessary for the relevant activity, which may be to fulfil statutory or legal obligations.
11. Your rights
You have various rights in respect of the personal information we hold about you – these are set out in more detail below. If you wish to exercise any of these rights or make a complaint, you can do so by contacting our Data Protection Officer at BWW Mind; 6 Osbert St, London, SW1P 2QU, by email at email@example.com or by calling 020 7259 8100.
You can also make a complaint to the data protection supervisory authority, the Information Commissioner’s Office, https://ico.org.uk/:
· Access to your personal information: You have the right to request access to a copy of the personal information that we hold about you, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge (multiple requests may incur a charge). Please make all requests for access in writing, and provide us with evidence of your identity.
· Right to object: You can object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. Please contact us as noted above, providing details of your objection.
· Consent: If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time.
· Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
· Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
· Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
· Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
· No automated-decision making: Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law. You also have certain rights to challenge decisions made about you. We do not currently carry out any automated decision-making.
Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.
‘Cookie’ is a name for a small file, usually of letters and numbers, which is downloaded onto your device, like your computer, mobile phone or tablet when you visit a website.
They let websites recognise your device, so that the sites can work more effectively, and also gather information about how you use the site. A cookie, by itself, can’t be used to identify you.
The cookies we use
We use the categorisation set out by the International Chamber of Commerce in their UK Cookie Guide.
We use all four categories of cookies:
· Strictly necessary cookies are essential for you to move around our website and to use its features, like our shopping basket and your account.
· Performance cookies collect anonymous information about how you use our site, like which pages are visited most.
· Functionality cookies collect anonymous information that remember choices you make to improve your experience, like your text size or location. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
· Targeting or advertising cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. As such if you visit the Mind website you may then be more likely to see adverts about Mind’s work on other websites as your browsing suggests that this is an area of interest.
No cookies, please
You can opt out of all our cookies (except the strictly necessary ones). Find out how to control and delete cookies in your browser.
But, if you choose to refuse all cookies, our website may not function for you as we would like it to.
Your communications with our teams (including by telephone or email) may be monitored and/or recorded for training, quality control and compliance purposes to ensure that we continuously improve our customer service standards.
To find out more about this policy and how we look after your personal information, contact our Data Protection Officer at: BWW Mind, Hopkinson House, 6 Osbert St. London SW1P 2QU. By email: firstname.lastname@example.org or by phone on 020 7259 8100.