PRIVACY POLICY

The Swaffham & District Mental Health Association (SDMHA) is committed to protecting any personal information that you share with us or information that is provided to us by other organisations.  The purpose of this policy is to give you a clear explanation of what personal information we collect and how we collect, use,and protect your personal information.

What is personal information?

Personal information is any information about you from which you can be identified such as your name, address, date of birth, credit card details, IP address, photo or video image but it may also be anything that identifies you for example, your NHS number or biometric data. For service users, some of this data will be sensitive and relate to their health and wellbeing, ethnicity and religious views.

By providing us with personal sensitive data you give us your explicit consent to process this sensitive personal data for the purposes set out in this Privacy Policy.

SDMHA will only use your information in ways that you would reasonably expect. Sometimes we may undertake research, with your permission, to better understand people’s expectations about how their data will be used.

SDMHA will always consider the impact of processing your data before any action is taken to ensure that it has no unjustified adverse effects.

Information we may hold about you

Your information will only be collected, stored or processed where a specific purpose has been identified.

This will fall into the following categories:

Information required to provide you with SDMHA services. Service User Information and data held may include personal information such as name, address, contact details, date of birth, gender, ethnicity and religious beliefs, next of kin, information about your health and wellbeing collected by SDMHA and information received by us from other agencies and health and social care professionals involved in your care, emails, images, audio and video recordings,correspondence, care assessments, plans and records of care and services received, appointments, bookings, incidents, surveys, commendations, complaints and concerns.

Personal Information to support a contractual arrangement – for example, contracts of employment or other formal agreement.

Information required for SDMHA to comply with legal obligations – for example, disclosure and baring service, vat records, payroll records.

Information required in the legitimate interest of the charity or its subsidiaries – for example, as a supporter of the charity it will be in the legitimate interest of both SDMHA and you as a supporter to keep you informed about the work of SDMHA.

Information which you have provided us with your consent to process – for example, you may have given us your consent to send you marketing information.

Information which you may have provided us with as a matter of your own vital interest. ie to maintain your own personal safety such as next of kin of information about your health

If you have provided us with details of relatives or next of kin, it is your responsibility to ensure that you have made them aware of this and that they accept the terms of this privacy policy.

Information collected by our website – including the internet protocol (IP) address used to connect your computer and other information about your browser type, version, times, operating system and platform and Uniform Resource Locators (URLs or web addresses) clickstream to, through and from our site and browsing activity onour site.

How information is collected

Information you provide directly to us

Information is given to us directly when, forexample, you become a service user, register for a fundraising event, volunteer to support the charity, become an employee, or make a donation.

We will ask you to provide personal information. You may provide this on a form, during a discussion, over a web form or by other means. 

The details we ask you for will be directly related to the purpose for which they are required, for example:

• A charitable donation may be given anonymously, but we would prefer to have your contact details so that we can confirm receipt and keep you informed; you will be able to choose whether or not you supply this information. Depending on your payment method we may need to record your payment details.
• As a donor, we will often ask you for more information than the bare minimum to process your donation, this may be so that we can identify you as an event entrant or it may be part of building a long-term relationship with you. Our fundraisers will be genuinely interested in how you have raised funds and why you have chosen to support SDMHA and may record this information so they have a record when they next contact you.
• If you are a member of staff or a volunteer more information will be required, depending on the work you do we may need to ask you for sufficient information to carry out some background checks and there is certain information that we are required to have on record.
• If you are a service user then your records may include sensitive personal data, including medical information

Information collected electronically

You may provide information to us directly through our website. When you interact with an SDMHA website it is helpful to be able to identify you to improve your experience.  Like most websites SDMHA uses ‘cookies’ to enable the website to recognise you when you return. A cookie is a small text file that transfers to your computer (or phone or tablet) and can help with things such as auto-filling your name and address in text fields.

By using an SDMHA website you are confirming you agree to our privacy and cookies policies.

There is more information about how cookies work as an appendix to this document.

If you enter details onto one of our online forms and you don’t send or submit the form, we may contact you to see if we can help with any problems you may be experiencing with the form or with our website.

CCTV

Some of our premises are monitored by CCTV or door access systems. For the purposes of security, images and videos may be retained for a limited period of time.

Information provided by third parties

Sometimes information will be provided indirectly through a third party, for example: through a donation website (e.g. Just Giving), from an organisation where you have given permission to share your data, or service user information may have been shared with SDMHA through the NHS spine or by other agencies, health and social care professionals.

Third parties must only supply SDMHA with your information if they have the correct lawful authority to do so. When you share your information with anyone you should check their privacy policy so you understand how they will process and share your data. You should also regularly check your security settings for online services with whom you share your data.

Information collected from public sources

SDMHA may collect information from public sources such as Companies House, social media profiles, newspapers and other published material. SDMHA may also carry out research into population demographics, geographic data or other areas which may impact on our future service delivery or identify potential areas of focus to raise funds.

How we use your data

The following gives examples of how data is used are:

• For the purpose of treatment and care
• To make sure we maintain our responsibilities for quality and accountability
• To inform the development of care services
• To raise awareness of needs of families & SDMHA services.
• For funding purposes
• To provide you with information, products or services that you request.
• To keep you informed about the work of the charity.
• To ask for your support to help SDMHA continue our work. This may be through volunteering, fundraising, becoming a gift-aider or other means of providing support to the charity.
• To provide you with other services.
• To maintain a relationship with you as a supplier of services.
• To ensure we contact supporters with the most appropriate communication we may profile your data by combining the information we hold with other sources of information or carry out other analysis techniques. This will enable SDMHA to contact you in the most relevant way and provide an improved experience. It will also enable SDMHA to have a greater insight     and understanding of its supporters and use the information to develop the charity’s donor base. If you do not want your data to be used in this way then you can opt out at any time by contacting the Swaffham & District Mental Health Association Manager. We may record telephone conversations for the purposes of staff training or other development.

Marketing

If you have consented to our processing your personal data for marketing purposes,in accordance with this Privacy Policy, we may send you information (via email, post, phone or text) about our activities and services we consider of interest to you.

You have the right to ask us not to process your information in this way at any time. If you no longer wish to receive emailed or web based marketing information you can unsubscribe at unsubscribe@merleboddy.org.uk. For non-web based marketing please contact the Swaffham & District Mental Health Association Manager.

How we will contact you

If you have told us how you prefer to be contacted then we will use your preferred method to contact you. This may be by post, email, telephone, text or another method you have requested.  

We will comply with the requirements of the data protection laws and the Fundraising Regulator guidance to ensure we do not contact you without your consent for the purposes of marketing calls by telephone, email or text message.

We understand people may give us their contact details for a variety of purposes, but will only use them for marketing purposes if this was made clear at the time they were given and we received your consent.

Sharing information

Service user information may be shared with other parties for the following reasons:

• For the purpose of treatment and care
• To make sure we maintain our responsibilities for quality and accountability
• To inform the development of care services.
• To raise awareness of needs of families & SDMHA services.
• For funding purposes including to provide evidence that contracted services have been delivered.
• To fulfil a legal duty
• To provide information to regulatory bodies.
• To carry out research

We will always seek consent before identifiable service user information is shared for the purposes listed above.

National Data Opt-Out Programme

From May 25th, 2018, any person aged 13 years or over, with an NHS number, can opt-out of having their confidential identifiable patient information being used for reasons other than their individual care and treatment. If you wish to opt out or wish to find out more information about this, please go https://digital.nhs.uk/services/national-data-opt-out-programme or contact the Swaffham & District Mental Health Association Manager.

Third party agencies

SDMHA does not sell personal details to third parties for the purposes of marketing.

SDMHA uses third party agencies who act under contract to carry out tasks on behalf of the charity.  This may include data cleaning, direct mail fulfilment services, database technical support from IT providers, data hosting, external secure archiving, and confidential record destruction. These providers, in addition to contractual commitments to SDMHA, have the same obligations as SDMHA under data protection legislation.

SDMHA may also engage third party medical or therapeutic professionals or other contractors or agency staff to work on site providing or supporting SDMHA services. These third parties may be given access to personal information on the same basis as SDMHA staff and will be contractually bound to the same standards of data protection and confidentiality.

Employee data may be shared with third parties for the purpose of occupational health assessments; consent will always be obtained for this. Payroll data will be shared with our payroll processing bureau and with His Majesty’s Revenue and Customs.

Where possible, SDMHA will always choose to anonymise data before sharing with third parties.

SDMHA may be required by law to share data to comply with legislation, for example, to safeguard a child or adult at risk of harm, as a result of a court order, a request from the police who are investigating a crime or an investigation from other authorities, for example, a tax enquiry.

Safeguards to protect your privacy

SDMHA takes data protection and information governance very seriously.

All SDMHA staff receive formal training annually and are supported with resources, materials and advice to ensure that the organisation complies with the requirements of the various data management and protection legislation and best practice guidance. This includes the General Data Protection Regulations (EU)2016, the NHS Digital Data Protection & Security toolkit and National Data Guardian’s 10 Data Security Standards 2017.

An information governance management group oversees the arrangements for ensuring compliance with required law and standards. Your personal data will be kept confidential and secure and will, unless you agree otherwise, only be used for the purpose(s) for which it was collected and in accordance with this Privacy Policy, applicable Data Protection Laws and other regulatory requirements (e.g.The Fundraising Regulator).  

All access to data is managed through role-based security to ensure access to systems and data is restricted only to those who have appropriate authority.

All SDMHA mobile devices and servers are encrypted and data is held in a secure data centre. On our website, if the web page starts with HTTPS or if you see a padlock symbol, your data should be encrypted when it is sent from your computer to its destination. If you do not see this symbol then it is not encrypted and you should not send confidential, financial or sensitive data.

Software versions are updated to ensure they are supported and SDMHA deploys up-to-date virus protection systems.

All data processes and systems at SDMHA are risk assessed to ensure compliance with legal requirements and best practice. The process includes the identification of the legal basis by which information is processed. Depending on what this is, further steps are carried out to protect your interests; this may mean contacting you to obtain your specific consent or carrying out a balancing test to ensure our treatment is fair.

SDMHA has a retention policy for all data stored or processed on SDMHA systems. The retention policy is decided and then reviewed as part of the annual data risk assessment process. Information is only kept as long as it is required, or as long as there is a legal requirement to keep it. Information no longer required is disposed of in a secure manner.

In order to maximise the security around processing of financial transactions the SDMHA website uses industry recognised secure payment processing companies to process payments. This means that whilst on an SDMHA website you may be seamlessly passed over to a third-party payment portal to complete your transaction (e.g. PayPal or SagePay) – this may include the transfer of personal details you have already provided. We will always make it clear where this happens.

Where our website links you to sites hosted by other organisations, we will make this clear so you know you are leaving the SDMHA website. No personal data will be transferred over these links.

The majority of SDMHA data is processed in the UK or the European Economic Area(EEA) on SDMHA systems. Occasionally there may be a requirement to process non-care data outside of this zone. Where data is sent outside of the EEA we will ensure appropriate obligations are in place to give your data the same level of protection as it would have in the EEA. This may be through data sharing agreements, national agreements or confidentiality contracts. By providing your personal data to SDMHA you agree to this transfer, storage and processing.

Debit and Credit Card Information

If you use your credit or debit card to donate or pay for a transaction we will ensure that this is done securely and in accordance with the Payment Card Industry Data Security Standard. SDMHA does not keep your payment details – all card details and validation codes are securely destroyed once the pay mentor donation has been processed.

Vulnerable Supporters Policy

SDMHA is committed to protecting vulnerable supporters. Please refer to our Vulnerable Supporters Policy (link to policy) on our website for more information.

Inappropriate Website Content

If you post or send any content that we believe to be inappropriate, offensive or in breach of any laws, such as defamatory content, we may use your personal information to inform relevant third parties such as your internet provider or law enforcement agencies.

Your rights

Your rights are important to us, we recognise that you have the following rights:

• The right to be informed about your personal information we store and/or process
• The right of access to the information we hold about you and make a subject access request.
• The rights of erasure or restricted processing
• The right of portability – you may be able to ask us to give information we hold about you to another organisation.
• The right to object to the way in which we store or process your information
• The right to object to any automated decision-making process that we may use

If you would like to exercise any of these rights, please contact the Swaffham & District Mental Health Association Manager.

Other information

For the purposes of Data Protection Laws, the Data Controller is:

Swaffham & District Mental Health Association, The Merle Boddy Centre, Station Yard, Swaffham, Norfolk. PE37 7JE (Tel: 01760 724527)

Registered Charity No. 1050124.

Company Limited by Guarantee No. 2956667 (registered in England and Wales).

Where this document refers to we or us or SDMHA we mean Swaffham & District Mental Health Association

If you are not satisfied with the way SDMHA handles your request you can contact the Information Commissioner’s Office on 0303 123 1113 or visit their website at http://www.ico.org.uk

Appendix 1– Cookies

SDMHA websites use cookies to help you in your interactions with the site. Most cookies are session cookies, lasting only for the duration of your visit and are deleted when you close your browser. No personally-identifiable data is collected.

Examples of the sort of information that iscollected via session cookies are provided below. This list is not exhaustive:

• The last search term that you used within the site
• Your preference in terms of accessible viewing options
• A unique ID to track your session from page-to-page, which is vitally important should you sign into the site
• Which page you are looking at within a multi-paged index of content, or search  results

Certain cookies are persistent, meaning that they last beyond your session, enabling an enhanced user-experience when you return to the site. Again, a non-exhaustive list of examples of the use of persistent cookies includes:

• • The option to “Remember my username” when signing-in to the site
• • The fact that you have voted in a poll, so that you are prevented from voting multiple times.

This site uses Google Analytics (www.google.com/intl/en_uk/analytics) to allow us to track how popular our site is and to record visitor trends over time. Google Analytics uses a cookie to help track which pages are accessed. The cookie contains no personally-identifiable information, but it does use your computer’s IP address to determine where in the world you are accessing the site from, and to track your page visits within the site.

From time to time, we may embed external content from third-party websites (e.g.Facebook, YouTube) within our website. These websites may utilise cookies and the Privacy Policy that will apply to such third-party content will be that published on the website of that third-party content provider.

Information about our use of cookies

Our site uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.

All sites which operate across certain parts of the European Union are required to obtain consent using or storing cookies (or similar technologies) on your computers or mobile device. This cookie policy provides you with clear and comprehensive information about the cookies we use and the purposes for using those cookies.

What is a cookie?

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our site.

Key concepts

*First and third-party cookies: whether a cookie is 'first' or 'third' party refers to the domain placing the cookie. First-party cookies are those set by a website that is being visited by the user at the time.

*Third-party cookies: are cookies that are set by a domain other than that of the site being visited by the user. If a user visits a website and another entity sets a cookie through that site this would be a third-party cookie.

*Persistent cookies: these cookies remain on a user's device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.

*Session cookies: these cookies allow website operators to link the actions of auser during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

How to delete and block our cookies

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our site.

Can I withdraw my consent?

If you wish to withdraw your consent at any time, you will need to delete your cookies using your internet browser settings.

For further information about deleting or blocking cookies, please visit: http://www.aboutcookies.org/Default.aspx?page=2.

What cookies do we use and why?

To find out about specific cookies we use on this site, please see below for details.

The cookies used on our site are categorised as follows:

*Strictly necessary

*Performance

Strictly necessary

'Strictly necessary' cookies let you move around the site and use essential features like accessing your profile and posting feedback. Without these cookies, these services cannot be provided. Please note that these cookies do not gather any information about you that could be used for marketing or remembering where you've been on the internet.

We use these strictly necessary cookies to:

*identify you as being logged in to our site; and

*enable you to submit information via online forms such as registration and feedback forms.

Accepting these cookies is a condition of using the site, so if you prevent these cookies we can't guarantee your use of our site or how the security on our site will perform during your visit.

Performance

'Performance' cookies collect information about how you use our site e.g. which pages you visit, and if you experience any errors. These cookies do not collect any information that could identify you and is only used to help us improve how oursite works, understand what interests our users and measure how effective our content is.

We use Web Analytics performance cookies to provide anonymous statistics on how our site is used.

Some of our performance cookies are managed for us by third parties. However, we don't allow the third party to use the cookies for any purpose other than those listed above.

By using our site, you accept the use of 'Performance' cookies. Accepting these cookies is a condition of using the site, so if you prevent them we cannot guarantee how our site will perform for you.

More information about cookies

*Information about cookies: useful information about cookies can be foundat: http://www.allaboutcookies.org

*International Chamber of Commerce United Kingdom: information on the ICC (UK)UK cookie guide can be found on the ICC Web site section: http://www.international-chamber.co.uk/our-expertise/digitaleconomy