Privacy Policy

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Who we are:

In this Privacy Policy, “we”, or “our” means: Keeping A Head 

How we collect your personal information:

Depending on your interactions with us we collect information from a variety of sources such as:

· When you use our services

· When you visit our websites

· When you provide information to us directly

· When you provide it to us indirectly via a third party - such as via professional referrals or professional fundraising agencies, where you’ve given them permission to share the information, they hold about you with us

· Other sources (such as social media or information available in the public domain)

· When you choose to complete any surveys, we send you

· When you ask one of our partners to email you information about a product or service

· When you contact us by any means with queries, complaints etc.

Legal Bases for processing your data:

Data protection laws mean that each use we make of personal information must have a “legal basis”. The relevant legal bases are set out in the General Data Protection Regulation (EU Regulation 2016/679) and in current UK data protection legislation.

Specific consent
Consent is where we ask you if we can use your information in a certain way, and you agree to this (for example when you engage with our services).  Where we use your information for a purpose based on consent, you have the right to withdraw consent for any future use of your information for this purpose at any time.

Legal obligation
We have a basis to use your personal information where we need to do so to comply with one of our legal or regulatory obligations. For example, a court order may require us to process personal data for a particular purpose and this also qualifies as a legal obligation.

Performance of a contract / take steps at your request to prepare for entry into a contract
We have a basis to use your personal information where we are entering into a contract with you or performing our obligations under that contract. Examples of this would be if you are applying to work/volunteer with us or being funded to undertake research.

Vital interests
We have a basis to use your personal information where it is necessary for us to protect life or health. For instance, if there were to be an emergency impacting one of our service users / clients which required us to contact people unexpectedly or share their information with emergency services.

Legitimate interests
We have a basis to use your personal information if it is reasonably necessary for us (or others) to do so and in our/their “legitimate interests” (provided that what the information is used for is fair and does not unduly impact your rights).

An example not mentioned under the other bases above where we are relying on legitimate interests is analysis and profiling of our supporters using personal information we already hold.

Special Category Data / Criminal Convictions or Offences
In some circumstances we will need to process information around Special Category Data. These could include race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation.

In relation to criminal convictions or offences we have a lawful basis as well as be processing the data in an official capacity; or we will meet a specific condition contained in the Data Protection Act 2018.

Giving your consent

To record, use or your personal information we must ask for your consent. However, we have a duty to share information with or without your permission under certain circumstances.  Wherever possible, we will discuss this with you first. We have a duty to share information: 

· If the safety/security of other service users, staff or the community is compromised by not revealing information.

· If Keeping A Head believes you may be at risk of self-harm or risk of harm to any person.

· If Keeping A Head has concerns for the welfare of any child(ren).

You have the right to withdraw your consent at any point during the chat or afterwards. You can do so by either talking to the advisor or, if it is after the conversation, by emailing louize@keepingahead.co.uk

What information we collect

If you use the online service there’s information that is visible to us, including your IP address, where on our website you’ve come from and your approximate location (such as your town). With your consent, we may also invite you to share additional information for evaluation purposes and/or in order to provide effective advice to you: 

· The name you would like us to call you

· Age

· Gender

· Your own contact details (email or phone)

· Issues related to your own or loved one’s use of drugs and alcohol and related impacts on lifestyle and behaviour

· Whether you are a current or former Keeping A Head client

· Presenting issue

· Contact details

· Additional comments on you experience of using their service

How we share this information

We do not sell, trade or rent any personal information provided by you in any transcript, survey or recording for direct marketing or any other purpose, except as stated in this privacy policy or with your consent.

How and why we collect it:

Information we may collect about you includes:

Website visitors
When someone visits www.keepingahead.co.uk we collect data about their behaviour. This is to enable us to find out things such as the number of visitors to our site and what areas are of interest to people. When collecting this information, we do not gather any ways to identify anyone. We do not attempt to find out the identities of those visiting. We will not associate any data gathered from this site with any personally identifying information from any source.

If we want to collect personally identifiable information through our website, we will make sure that you are fully aware of this when we ask for your information, and we will explain what we intend to do with it.

Cookies
Cookies are small data files which are placed on your computer when you visit certain websites. We use cookies to help improve our website by measuring things like number of visitors we have and if they have visited before. The cookies do not give us access to any personal data.

When you first visit our site, we tell you that it used cookies and give you the opportunity to give your consent. If you do not want to give your consent to this, you can stop browsing our website, or update settings in your browser to block cookies from being collected. If you change your mind, you can still block them at a later time.

Search engines
Search queries and results are logged anonymously to help us improve our website and search functionality. No user-specific data is collected by either Keeping A Head or a third party.

Individuals who email us
Any email sent to us, including any attachments, might be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.

Individuals who send complaints / Data Protection enquires / Freedom of information enquires
When we receive a complaint, we create a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved. We will only use the personal information to investigate the complaint. Under normal circumstances we have to disclose the complainant’s identity to whoever the complaint is about. If a complainant does not want information identifying him or her to be disclosed, we will try to respect that. Although, it may not be possible to handle a complaint on an anonymous basis.

Service Users / Clients
It is necessary for us to process the information of people who have requested our services in order to provide it. We will ask for consent to process this information and only use the information for which the person has agreed too. This information is covered by data protection principles (including GDPR) and compliance to Information Commissioner’s Office (ICO) standards.

Service Providers reporting a breach

We are required to consider reporting serious security breaches to the Information Commissioner’s Office (ICO). We use the ICO process in order to do this. In relation to all breaches, we use the information to inform the actions we need to undertake.

How we protect your data:

We know how much data security matters to all of us and with this in mind we treat your data with the utmost care and take all appropriate steps to protect it. We ensure that there are appropriate technical and organisational controls (including physical, electronic and managerial measures) in place to protect your personal details.

How long we keep your data for:

Keeping A Head has specific criteria to determine how long we will retain your information for, which are determined by legal and operational considerations. Whenever we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and planning.

Sharing your Information with other organisations: 

We have a duty to share information with or without your permission under certain circumstances. Wherever possible, we will discuss this with you first. We have a duty to share information:

· If the safety/security of other service users, staff or the community is compromised by not revealing information

· If the Keeping A Head team believes you may be at risk of self-harm or risk of harm to any person

· If the Keeping A Head team has concerns for the welfare of any child or children

We ask for your consent to share information with other services or professionals who are important to your care or who hold important information about you.

We will never sell or rent your information to third parties for marketing purposes. However, we may disclose your information to third parties in connection with the other purposes:

· business partners, suppliers and sub-contractors who may process information on our behalf.

· analytics and search engine providers.

· IT service providers.

Your Rights over your personal data:

You have the right to request:

· Access to the personal data we hold about you, free of charge in most cases.

· The correction of your personal data when incorrect, out of date or incomplete.

· The deletion of the data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.

· A computer file in a common format containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.

· Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made.

· That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.

· That we stop using your personal data for direct marketing (either through specific channels, or all channels).

· That we stop any consent-based processing of your personal data after you withdraw that consent.

· Review of any decision made based solely on automatic processing of your data (so where no human has yet reviewed the outcome and criteria for the decision).

You can contact us to request to exercise these rights at any time by contacting us via: Keeping A Head

 

If we choose not to action your request, we will explain the reasons for our refusal.

Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest
In cases where we are processing your personal data based on our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.

If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office (ICO).

Complaints:

If you are unhappy with any aspect of how we are using your personal information we’d like to hear about it. 

We appreciate the opportunity this feedback gives us to learn and improve. Please email us at info@keepingahead.co.uk