Privacy Policy

How we respect your privacy when dealing with the personal information we collect

This Privacy Policy applies to information we (The Freedom Project/West Cumbria Domestic Violence Support) collect about individuals who interact with our organisation. It explains what personal information we collect and how we use it.

If you have any comments or questions about this notice, feel free to contact us at: hope@freedom-project-west-cumbria.org.uk

 

1. Personal data that we process

The following table explains the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed.

Name, email, messageLegitimate interests – it is necessary for us to read and store your message so that we can respond in the way that you would expect.

Purpose	Data (key elements)	Basis
Enquiring about our organisation and its work	Name, email, message	Legitimate interests – it is necessary for us to read and store your message so that we can respond in the way that you would expect.
Subscribing to email updates about our work	Name, email	Consent – you have given your active consent.
Making a donation	Name, email, address, payment information	Legitimate interests – this information is necessary for us to fulfill your intention of donating money and your expectation of receiving a confirmation message.
Website functionality	Website activity collected through cookies	Legitimate Interests – it is necessary for us to store a small amount of information, usually through cookies, to provide you with the services, products or information you asked for.

2. How we use your data

We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out in the table above.

For example, we may use your personal information to:

• reply to enquiries you send to us;
• handle donations or other transactions that you initiate;
• where you have specifically agreed to this, send you marketing communications by email relating to our work which we think may be of interest to you.

3. When we share your data

We will never sell or swap your details. We may share your information with third parties in the process of managing your engagement with us, such as payment processors for donations.

We will only pass your data to third parties in the following circumstances:

you have provided your explicit consent for us to pass data to a named third party;
we are using a third party purely for the purposes of processing data on our behalf and we have in place a data processing agreement with that third party that fulfils our legal obligations in relation to the use of third party data processors;

or

we are required by law to share your data (where the user is disclosing information about an act of terrorism, where a court orders us to disclose information, where there is reasonable cause to suspect that an adult’s life may be in immediate danger, where there is reasonable cause to suspect that a child or young person may be experiencing or at risk of experiencing significant harm).

In addition, we will only pass data to third parties outside of the EU where appropriate safeguards are in place as defined by Article 46 of the General Data Protection Regulation.

 

4. How long we keep your data

We take the principles of data minimisation and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required.

Where data is collected on the basis of consent, we will seek renewal of consent at least every three years.

 

5. Rights you have over your data

You have a range of rights over your data, which include the following:

• Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example by putting ‘unsubscribe’ links at the bottom of all our marketing emails).
• You have the right to ask for rectification and/or deletion of your information.
• You have the right of access to your information.
• You have the right to lodge a complaint with the Information Commissioner if you feel your rights have been infringed.

A full summary of your legal rights over your data can be found on the Information Commissioner’s website here: https://ico.org.uk/

If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us.

Please note that relying on some of these rights, such as the right to deleting your data, will make it impossible for us to continue to deliver some services to you. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible.

 

6. Cookies & usage tracking

A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website.

When you visit our website we collect information to help us to understand how people use our site, and to make improvements to your website experience. This information consists of your IP address, your browser (e.g.Chrome or Internet Explorer), when you visited and which pages you visited or any downloads made during your visit. We cannot use this information to find out further personal information about you, and will not share any individual information unless required to do so by law.

We also use some cookies that do not collect personal information but help us collect anonymous information about how people use our website. We use Google Analytics for this purpose.  Google Analytics generates statistical and other information about website usage by means of cookies, which are stored on users’ computers. The information collected by Google Analytics about usage of our website is not personally identifiable. The data is collected anonymously, stored by Google and used by us to create reports about website usage. Google’s privacy policy is available at http://www.google.com/privacypolicy.html.

 

7. Data Protection for active Freedom Project/WCDVS clients

Once you are part of our counselling service, it is important that you feel the information you share is treated confidentially and respectfully. It is also important that you understand the duties we have to safeguard you, and any information we hold about you, and how we do that.

This section of the Privacy Policy explains how we use any personal information we collect about you and your children once you become active clients.

Data Protection

The information about confidentiality in no way contravenes your rights under the General Data Protection Regulation (GDPR) May 2018 to access personal data that West Cumbria Domestic Violence (WCDVS) holds on you.

WCDVS keeps confidential records and statistics about its clients. All records are kept securely and are only seen by authorised WCDVS personnel. These records are subject to the General Data Protection Regulation May 2018. Some of the information we may collect is classified as sensitive personal data and we can only use such data where we have your explicit consent. This data may include: racial or ethnic origin, political opinions, religious beliefs, physical or mental health, sexual life, criminal proceedings and offences. Your personal and sensitive personal data will only be used in order to provide the service to you and for managing and quality assuring the service.

Records are kept for a period of 7 years and are then destroyed.

WCDVS recognises that on rare occasions our clients may wish to exercise their rights under the General Data Protection Regulation May 2018 and make a subject access request in respect of their personal information held by WCDVS.

Often during counselling, information is provided by more than one individual. In these cases WCDVS will only release information if consent has been given by all of the individuals involved. If at any time you wish to exercise your right under the Act you should put your request in writing to the Project Manager and provide evidence of your identity such as a copy of your passport or driver’s licence and proof of your address. When the Project Manger receives your written request and evidence of identity they will respond to your request within 40 calendar days. WCDVS response to a valid subject access request will normally be in the form of an appointment listing and describing the personal data we hold on them.

Confidentiality

WCDVS counselling is a private and confidential form of help. We hold information about each of our clients and the counselling they receive in confidence. This means that we will not normally give your name or any information about you to anyone outside the organisation. However, there are exceptional cases where WCDVS might ethically or legally have to give information to relevant authorities, for example if we had reason to believe that someone, especially a child, is at serious risk of harm or to prevent a miscarriage of justice. We will discuss any proposed disclosure with you unless we believe that to do so could increase the level of risk to you or to someone else.

If you come with a partner or your family, the counsellor will suggest seeing each of you individually. It is important for you to know that what is said in those individual sessions will be confidential and not shared with your partner or family.

Domestic and Sexual Violence

Violence and abuse is an issue for many people who come to WCDVS for help with their relationship. We know from our experience that in this situation, working with couples or family members together may not be safe. If this is so, the counsellor will help each person to get individual specialist support from WCDVS or another agency.

Authorised Electronic Recording

Occasionally a counsellor, for example one who is undertaking a training course, will be required to tape record a counselling session. Some counsellors regularly use audio or video recording in their work and in these circumstances you will be asked to give your written consent for this to happen. The consent will specify all the ways in which the recording will be used (for example training, supervision or research) and will specify how and when the recording will be destroyed.

Reports and Client Records

Occasionally WCDVS is asked by our clients or by external agencies such as Social Services or the NHS to write reports on the progress made in counselling. We are not normally in a position to do this because of our duty of confidentiality to our clients and because WCDVS counsellors are not trained in the specialist areas of diagnosis or social work assessment. However, we can and on receipt of written consent from the client(s) who attended counselling, provide brief information about the dates and number of sessions attended.

In addition we are also asked by clients, their solicitors, the police and the courts for access to the client records. These are not suitable as evidence in legal proceedings and WCDVS reserves the right to resist legal requests to produce the records in court. We do this in order to protect WCDVS duty of confidentiality to all its clients and to preserve WCDVS reputation as the provider of confidential counselling.

Codes of Ethics and Practice

All WCDVS counsellors and supervisors are required to comply with the code of ethics and practice that is appropriate to the work they undertake.

1-1 Counselling is covered by the British Association for Counselling & Psychotherapy’s Ethical Framework for Good Practice.

In addition, WCDVS personnel must comply with WCDVS code of ethics. Please ask your counsellor if you would like to know more about this.

 

8. Modifications

We may modify this Privacy Policy from time to time and will publish the most current version on our website. If a modification meaningfully reduces your rights, we’ll notify people whose personal data we hold and is affected.