This policy summarises how seAp collects and uses personal information about the people who visit our websites or give us their data over the telephone, face to face in person, and in writing, as well as how we store data, how we use it, and how those who give us their details can request that their data is used by seAp.
seAp Advocacy takes the privacy of our clients, supporters and volunteers very seriously, and is committed to protecting your privacy. seAp’s privacy statement is outlined in section 2.0 of this policy.
References to the seAp website should be taken to include accessing any of the following websites: seAp, Advocacy Training, Essex Advocacy, Kent Advocacy, Advocacy in Cornwall, Isles of Scilly Advocacy, seAp guides, ESA assessment, and PIP assessment, or such others as may be developed from time to time with the seAp brand.
seAp is registered with the Information Commissioner’s Office, registration no. Z9231372 and, where it operates as Healthwatch West Berkshire, registration no. ZA144263.
If you have any queries about this policy, please contact the Data Support Officer - contact details given at the end of this document. The terms of this policy may change, so please check it from time to time.
2.0 seAp Privacy Statement
The General Data Protection Regulation (GDPR) [Regulation (EU) 2016/679], provides the legal framework that defines how personal information can be used. seAp is fully committed to complying with current data protection legislation and has a legal duty to protect any information we collect from you.
- Your personal information is only used for the purpose for which we collect it
- Only information that we actually need is collected
- Your personal information is only seen by those who need it to do their jobs
- We will not pass your personal information on to any other organisation without your consent unless we are required to do so by law (see “How do we use this Information?” below)
- Personal information is retained only for as long as it is required for the purpose collected
- We will, where necessary, keep your information up to date
- Your information will be protected from unauthorised or accidental disclosure
- We will provide you with a copy of your personal information on request (please see below for information on access rights and requests)
- Inaccurate or misleading data will be corrected as soon as possible
- These principles apply whether we hold your information on paper or in electronic form.
3.0 How do we collect information?
We obtain personal information from you when you enquire about our activities, make a referral for yourself or another person, send or receive an e-mail, donate to us, ask a question or otherwise provide us with personal information. We may also receive information about you from third parties; for example, from a social worker who wants to make a referral on your behalf or a relative who asks for information to be provided.
Where you ask us to provide a specific service, you may be asked to give consent to your data being collected. This may be verbally, online or by signed consent form, and this particularly relates to sensitive information you may not want shared. However, even if you have not formally given consent, we may still collect personal information as outlined in the next section.
4.0 What information do we collect?
The personal information we collect might include name, e-mail address, postal address, telephone number and the nature of your enquiry.
We may also collect sensitive personal information such as date of birth, ethnicity and other information required to allow us to review whether our services reach all sections of the community (which may be due to a contractual obligation under any funding we receive for providing the service), and information about your advocacy need which may include details of a personal nature if this is required for the purpose you have contacted seAp.
We also gather general information about the use of our website, such as which pages users visit most often, and which are of most interest. We may also track which pages users visit when they click on links sent in seAp e-mails.
We may use this information to personalise the way our website is presented when users visit it, to make improvements to our website and to ensure we provide the best service for users. We will only use aggregated or anonymous information which does not identify individual visitors to our website. Please see the section below on Cookies.
5.0 How do we use this information?
5.1 For clients of our advocacy services
For people who have contacted us for advocacy support directly, or been referred to us by another person, we will only use the information provided to facilitate our work with you and to record information required by the organisation that funds us for the work (such as a local authority), as well as for internal administrative purposes such as monitoring the quality of our service. We may however contact you to ask for your assessment of how we helped you and your satisfaction with the service provided, or other market research. We will not publish any information that could identify you personally without your consent.
If you are kind enough to give a donation or indicate your support for us such as by giving a compliment, then we may contact you to thank you, or to obtain your permission to publicise details of your particular case or feedback; but not any details that identify you without your consent.
We will not contact you otherwise unless with your express permission.
Depending on which local authority area you live in, we may work in partnership with other advocacy providers as detailed on the relevant local authority web page of our website. This means we may subcontract work on your case to another advocacy organisation, in which case they will be bound by the same requirements as we are under this statement. Alternatively, seAp may ourselves be subcontracted by other advocacy providers. Your advocate will be able to clarify any specific queries you may have.
We will not share your information with other parties other than for the purposes of providing the service you have contacted us about, although we may be required to share information with the council or other organisation that is funding us to provide the service.
If we do share your information, we will ensure you have provided consent to enable us to do this, for example when a service transfers to another provider, or if you have agreed specific information can be used for a particular purpose.
We may however be required to breach this policy if we believe you might suffer serious harm if we did not - see our Confidentiality Policy.
5.2 For users of our training services, referrers, enquirers and donors
For users of our training services:
We will collect your personal information, details of the courses you have booked or attended and any feedback you have provided. We will retain this information to comply with City & Guilds registration requirements and for marketing purposes.
For referrers and people who approach us for information or who donate to us:
If you refer a client to us, contact us for general information about seAp or about our advocacy and training services, or make a donation, we may contact you further to promote events, products and services.
If you do receive a marketing or promotional communication from us and no longer require this, there will be an ‘unsubscribe’ e-mail address or contact details for you to inform us, or you can contact the Data Support Officer - contact details at end of this document.
5.3 For volunteers and supporters
We will use your personal information for:
- Dealing with your enquiries and request
- Providing information about the charity’s work
- Fundraising where you have indicated you support our work
- Contacting you to promote our events, products and services. If we do not have your contact details such as your telephone number, e-mail address, or postal address, we may source this information via third party companies
- Providing and personalising our services to beneficiaries
- Conducting market research
- Profiling and segmentation so that we can offer supporters information relevant to them
- For administrative purposes such as to record information on your volunteering activity
As part of this, we may analyse the personal information we collect to create a profile of your interests and preferences so that we can contact you in the most appropriate way and with the most relevant information.
We may need to share your information with our service providers, associated organisations and agents for the purposes described above.
5.4 For employees
See separate HR guidelines.
6.0 Your choices on receiving information
You have a choice about whether you want to receive information about our work and fundraising activities. We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted. You can change your marketing preferences (such as e-mail or post at any time), by contacting the relevant contact on the communication or requesting this from the Data Support Officer - contact details at end of this document.
7.0 Access Rights and Requests
You have the right to see what personal data we hold about you. Subject access requests must be submitted in writing. Please use our Subject Access Request Form to ensure you supply all the information we need to process your request. You can also use this form if you are requesting information on behalf of somebody else.
You may also request a right to be forgotten by requesting your identifying information is deleted. This will include your specific contact information such as house number and phone numbers, and any correspondence. However, we will retain other information that cannot specifically be used to identify you and are required to do this for contractual and compliance reasons.
To obtain a copy of the personal information we hold about you, or request your information is deleted please write to us or submit your form to the Data Support Officer - contact details at the end of this document.
8.0 Transfer of Information
We confirm that any information we hold about you is stored and transmitted within the United Kingdom and the European Economic Area and will not be transferred outside these areas.
9.0 Right to prevent processing of your personal data
You have a right to object to seAp processing your personal information. Such a request should be made in writing and we will take steps to delete your identifying information.
This can be sent to the Data Support Officer as per the details provided at the end of this document.
10.0 Under 16s
seAp is concerned to protect the privacy of children and young people aged under 16. Where appropriate, we will seek consent from a parent or guardian before collecting personal information about a child aged under 16. However, where we are supporting a young person directly, any information will only be shared with their consent.
11.0 How do we protect personal information?
We take appropriate measures to ensure that the personal information disclosed to us is kept secure, accurate, and up to date. We will ensure that your personal information is kept only for so long as is necessary for the purposes for which it was collected and is securely destroyed in accordance with our data retention and disposal policy - see our Data Protection Policy.
Personal information is stored online using secure Microsoft hosted servers in the UK. Our online referral process is protected by digital encryption. We also use a secure server when you make a donation or payment via our website which is provided by JustGiving.
12.0 Will we disclose the information we collect to outside parties?
We do not share or sell donor details with other charities or other third parties.
We will only disclose data when obliged to disclose personal data by law, or the disclosure is ‘necessary’ for purposes of national security, taxation and criminal investigation, or we have your consent, and to the following:
- Suppliers we engage to process data on our behalf. In such cases, information is only shared for the purpose of providing services on our behalf relating to communications, or agreements between yourself and seAp. Such processing is conducted under relevant contracts that detail the data processing requirements.
We will not sell any information about your web browsing activity.
13.0 Deleting personal data
Our standard retention period for client information is eighteen months after case closure unless we are required to keep data longer due to contractual requirements.
If, when a case is due for deletion, you have another open case with us, we will not delete your older case until all contact with us has ceased after eighteen months.
By client information we mean any information that could identify you as an individual or could be used to inform any decision about you.
When we no longer need to keep your personal information, we will delete your contact details, any associated documents, and any other information that could identify you personally.
We may keep other information about your case where this cannot identify you personally but is required for contractual or operational reasons.
By deletion we mean put “beyond use” as defined by the Data Protection Information Commissioner’s Office guidelines.
For retention periods for other types of data, please refer to seAp’s Data Protection Policy.
14.0 Use of Mobile Phone Data
seAp values your support. We would like to keep you up to date with information and fundraising appeals on our charitable work via your mobile phone and also by writing to you. If you have texted us, we will retain a copy of your mobile phone number, together with any other personal details you have given us, such as your name and address.
If you would prefer us not to contact you by mobile phone, or if you would prefer us not to contact you by mail, you may contact the Data Support Officer as detailed at the end of this statement.
15.0 Cookie Usage
Our cookies aren’t used to identify you personally. They collect anonymous information on the pages visited and we do not use advertising cookies. Most browsers will allow you to turn off cookies. Please note however that turning off cookies will restrict your use of our website. To learn more about cookies and how to manage them, visit AboutCookies.org
16.0 Trademarks and copyright
seAp’s websites contain material which is protected by copyright and/or other intellectual property rights. All copyright and intellectual property rights including the names, images and logos are owned by seAp unless otherwise stated. All rights are reserved.
You are responsible for complying with all applicable copyright laws. We permit you to make copies of information on seAp’s website as necessary incidental acts during your viewing. You may take a print, for your personal use, of as much of the site as is reasonable for private purposes. All other uses are prohibited. Nothing in these terms shall be construed as conferring any right to use any trademark, logo, patent right or copyright of seAp.
17.0 Your consent
By providing us with your personal information, including sensitive information such as medical details, you consent to the collection and use of this information in accordance with the purposes described in this policy.
seAp may be funded to provide local advocacy services which have specific contractual requirements on how data is used. Reference to these may be made on the individual local authority web pages on the seAp website and when you complete any referral form.
If you complete a referral form, or contact us about a third party, we expect you to have the consent of the person concerned and, unless they lack capacity, we will need their consent to proceed with any casework.
Our websites may include links to websites run by other organisations. seAp is not responsible for the privacy practices of these other websites so you should read their privacy policies carefully.
If your personal details change, please help us to keep your information up to date by notifying your advocate or other relevant staff member.
20.0 Data Protection Regulator
Further information and advice about data protection is available from:
The Office of the Information Commissioner
Cheshire SK9 5AF
Tel: 0303 123 1113
21.0 Further information or specific requests
For further information or specific requests relating to this statement please contact:
Data Support Officer
PO Box 375
Tel: 0330 440 9000
We will require specific proof of identity if making a subject access request. Please request a copy of the Subject Access Request Form, or download this by clicking below.