POLICY STATEMENT

At the Children’s Bereavement Centre, we are committed to protecting your privacy. When you interact with us by phone, mail, in person or online, we sometimes receive personal information about you. 

This page, together with our website terms and conditions, tells you about how we collect, use, and store your personal information. Please read this policy carefully to understand how we collect, use, and store your personal data. If you have any queries about our privacy policy, please contact the Chief Executive at [email protected] or call us on 01636 551739. 

1.          Introduction

We will process any data in accordance with the Data Protection Act 1998 and the General Data Protection Regulations 2018. The purpose of this privacy policy is to inform people who use the Children’s Bereavement Centre about what information we collect when they visit the service, how we use the information, whether the information is disclosed and the ways in which we protect users' privacy. 

2.          Policy and Procedure Drafting and Approval

This policy is drafted by the CEO and approved by the Trustees. Approved policies and procedures are centrally indexed. One full copy of the policy handbook is held electronically on file on the shared drive to avoid out of date copies being used.  Staff will be made aware of the relevant revisions or new editions via email. 

3.          Associated Policies, Procedures and Guidance 

•           Data Protection Policy 

This privacy policy also considers several legal instruments, including:

•           the Data Protection Act 1998

•           the General Data Protection Regulations 2018

•           the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011

•           Directive 2009/136/EC of 25 November 2009 (“The European Union Cookie Directive”) 

4.          Aims and Objectives

We want people to feel secure when using the website and our care services. We are committed to respecting privacy. The following sets out an overview of how we do that. 

5.          Scope of the policy

The scope of this policy includes all data held by the Children’s Bereavement Centre including HR, Care, Finance and Fundraising information, privacy and data protection. In broad terms the Children’s Bereavement Centre will:

•           keep all information it has about you private and confidential

•           use the information solely for the purpose for which it was provided

•           not use or disclose the information unless authorised by you specifically or as per the section headed Your Consent below (unless ordered by a Court or Regulator)

•           not retain the information for longer than necessary. 

6.          Accountabilities and Responsibilities

The Chief Executive is ultimately accountable for the implementation and operation of this policy in conjunction with the relevant member of the leadership team. 

7.          What This Policy Considers (Method) 

7.1        Why we collect personal information 

We need information about you to provide an effective bereavement support or counselling service, to comply with fundraising, marketing and employment laws and other statutory requirements, collate statistical data to report to funders and effectively manage the charity.  We process the data we collect under the following basis; 

·        Consent – you have given us permission to contact you and you have the option to withdraw at any time. This can be given during any contact with the charity including when you refer into the service, take part in an event or activity, volunteer, or work for the CBC, make an enquiry and/or if you fundraise for us.

·        Contractual obligations - data processing is necessary to deliver any aspect of our service, and this includes referring into the service, taking part in an event or activity, fundraising for us and if you volunteer or work for the charity.

·        Legal obligation - is the processing of an individual’s personal data to comply with laws or statutory obligations and does not include contractual obligations. This includes

o   Case history if you are receiving counselling services, including contact and family contact details

o   Contact and emergency contact details and/or medical history if you are volunteering or participating in an event where Health & Safety demands

·        Vital interests - Vital interest is the processing of an individual’s personal information in case of an emergency medical situation, or to protect their life. This applies to both the essential protection of the data subject and other people. We would process data under this basis if while under counselling it was felt that you were in danger of harming yourself or others. 

7.2        How we collect information about you 

We may collect and store information about you whenever you interact with us. For example, when you donate, register for an event, or submit an enquiry, or if register for our services, or apply for a job or volunteering opportunity, or otherwise give us any other personal information. 

We may also receive information about you from third parties for a specific purpose– but only if you’ve given them permission to share your information. 

7.3        What information we collect 

We collect information about you when you refer into the service, take part in an event or activity, volunteer, or work for the CBC, make an enquiry and/or if you fundraise for us. We also collect information when you voluntarily complete customer surveys, provide feedback, and participate in evaluations, most of which are anonymous unless otherwise stated.  We may also get your information from publicly available sources, like LinkedIn or your organisation’s website. 

When you interact with us, we may ask you to give us your name, address, email address, telephone number if this is needed, or your, bank account details, if for example you are setting up a regular payment by direct debit. Your date of birth and relevant medical information will only be collected if appropriate, for example to register for a challenge event. We may collect some, or all, of this information when you visit our website, depending on how you use it. We also monitor how people use our website, so we can improve it. However, you can use our website without giving us any personal information and we won't know who you are. If you visit our site anonymously, we may however still record information about: 

•           the areas of the website you visit

•           the amount of time you spend on the site

•           whether you are new to the site, or have visited it before

•           how you came to our website – for example, through an email link or a search engine

•           the type of computer, browser, network location and internet connection you use which is done by using cookies on our website 

7.4        How we use your information 

The Children’s Bereavement Centre will collect data from you to process your donation, personalise your supporter experience or provide you with the goods or services you have requested, and comply with our administrative duties, financial regulations and the law. 

Personal details collected this way will only be used to provide you with information you would reasonably expect or have agreed to. This may include using your data, in combination with public data sources, to analyse, research and profile the data we hold, so that our communications with you and others are appropriate and cost effective. 

We promise to make all reasonable efforts to keep your details secure and will only share them with suppliers or professional agents working on our behalf, for example professional fundraising organisations or mailing houses who are sending out our marketing materials on our behalf. We will ensure we received from these agents a contract of confidentiality to ensure they acknowledge their responsibility in processing any data we share. 

The exception to this is if we believe a child or vulnerable adult might harm themselves or where actual harm could come to a person or place, if required by law or to enforce our legal rights to defund us against a legal claim.  In these circumstances we have a legal obligation to report/supply relevant information to the appropriate authorities. 

Except as required by law we will never share your details with other organisations to use for their own purposes. 

7.5        Your consent 

By giving us your personal information, including sensitive personal data like information about your health, you consent to us collecting and using that information in the ways that we describe in this privacy policy and/or that you have specifically consented to. 

You also consent to us transferring your information to countries or jurisdictions which may not provide the same level of data protection as the UK, if necessary, for any of the above purposes. If we do transfer your information in this way, we will comply with our legal obligations as a data controller under the Data Protection Act 1998 and, if we need to, put in place a contract with the companies we use to process information to ensure your details are properly protected. 

7.6        Marketing Consent

We will only send you marketing information by e-mail, SMS, or phone if you have given us specific consent. If you withdraw your consent and then subsequently opt in, then your most recent preference may take precedence.  

If you have responded to a letter of appeal, you may also receive fundraising mail, which you can opt out of at any time. 

You can opt out of us using your personal details for marketing at any time either by calling us on 01636 551739, or by e-mail to [email protected]. 

7.7        How we protect your personal information 

We take the protection of your data very seriously.  We restrict access to personal information collected about you to those that need information to provide our services or while conducting our business operations or activities.  

We maintain appropriate physical, electronic, and procedural safeguards to protect your personal information. Information is held on secure password protected databases and/or computers that have limited access and high security protection.  All information will be disposed of securely. 

Although we use appropriate security measures once we have received your personal information, the transmission of information over the internet is never completely secure. We do our best to protect personal information, but we cannot guarantee the security of information transmitted to our website, so any transmission is at the user’s own risk. 

Donations are currently processed mainly via Just Giving and other similar programs. 

7.8        Your credit card information

If you use your credit/debit card to donate to us, buy something or make a booking online, we pass your credit/debit card details securely to our payment processing system. 

7.9        Job applicants, and current and former employees 

If you apply for a job or volunteering opportunity, we will also collect information, so we can assess your suitability for the role. We will only use the information you give us to process your application and to monitor recruitment statistics. If we want to disclose information to someone outside the Children’s Bereavement centre - for example, if we need a reference, or need to get a 'disclosure' from the Criminal Records Bureau - we will make sure we tell you beforehand unless we are required to disclose this information by law. 

If you are unsuccessful in your job or a volunteer application, we will hold your personal information for 6 months after we’ve finished recruiting the post you applied for as per HR guidance. After this date we will destroy or delete your information. We keep depersonalised statistical information about applicants to develop our recruitment processes, but this does not contain any information that could be used to identify individual job applicants. 

If you begin employment with us, we will put together a file about your employment. We keep the information in this file secure and will only use it for matters that apply directly to your employment. 

Once you stop working for us, we will keep this file according to our record retention guidelines. You can contact us to find out more about this. 

7.10     Storage of Information 

The length of time we hold your personal information for varies depending on the type of information and its use.  We will only keep your personal information for as long as it is necessary to provide the services that you have requested, or for such other essential purposes such as complying with our legal obligations, resolving disputes, investigating disciplinary matters, and enforcing our agreements.  We may also retain the data in accordance with statutory requirements.

The actual retention periods for the different types of personal information we hold can be found in our Data Protection Policy.  If you have any questions about this, please contact us using the details below. 

7.11     How to find out what personal information we hold about you 

You can request details of the personal information we hold about you under the Data Protection Act 1998. We may ask you for an administrative fee of £10.00.

If you would like a copy of the information we hold on you, in the first instance please write to:

The Chief Executive

Children’s Bereavement Centre

3 Kings Road

Newark

NG24 1EW

Email [email protected]

Call 01636 551739 

7.12     How to change the personal information we hold about you 

If you want to update the information we hold for you, or you think any information we have about you is incorrect or incomplete, please get in touch with the Chief Executive as soon as possible as detailed above.

Our privacy policy may change from time to time, so please check this page occasionally to see if we have included any updates or changes, and that you are happy with them. 

7.13     Complaints and Queries 

We do our best to meet the highest standards when collecting and using personal information.  For this reason, we will take any complaints we receive about this very seriously.  We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading, or inappropriate.  We also welcome any suggestions for improving our procedures.  Please contact the Chief Executive via the contact information above.

8. Policy Review 

This policy will be reviewed every 3 years or sooner in the light of changes in the law or following investigations of incidents that indicate a change is required.