Our data protection officer and how to contact us
Postal address: Tadworth Court, Tadworth, Surrey, KT20 5RU
Telephone number: 01737 36 5000
Complaints about how we handle your information
You have the right to make a complaint at any time to the Information Commissioner's Office (the "ICO"), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance. If you wish to contact us to make a complaint about how we handle your personal data, you can do so through our Data Protection Officer (whose contact details are above).
This policy was last updated on the date shown at the top of the document.
We will only use your personal data for the purposes for which we collected it, or for reasons which we believe are compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the DPO using the contact details provided.
We reserve the right to make changes to this policy from time to time. However, if we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we will not process your personal data without your knowledge or consent unless this is required or permitted by law. In such cases, we will do so only in compliance with the law. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The data we collect about you
Personal data, or personal information, means any information which can be used to identify an individual. It includes pseudonyms such as unique identifiers (e.g. customer, supporter, patient, employee number), but excludes data from which a person cannot be identified from (anonymised data).
The information that we collect will depend on your relationship with us.
To find out more about the type of data we collect about you, how and why we collect it, our legal bases for processing your data and who we share it with, please click the relevant headings below to view the specific privacy notices:
Our beneficiaries are the children and young people and their families to whom we provide health, care and education services. This privacy notice covers how we process data of our beneficiaries and of their guardians/ families. It is aimed at the parents and other legal guardians of the children and young people in our care, as it covers their data as well as the data of the child (who may find it difficult to understand this policy and privacy notice either by virtue of their young age or lack of mental capacity).
Supporters and ambassadors who make a donation to the charity, take part in fundraising events and activities, or support our campaigns.
Professionals and Corporate Partners
This privacy notice is aimed at external health, social care and educational professionals with an interest in the services we provide including; our events and research into brain injury and neurodisability. It also applies to external colleagues employed by our suppliers and corporate partners.
Candidates & Prospective Volunteers
Prospective employees and volunteers (when you apply for vacancies or register for opportunities through our website).
Although we provide clinical and education services for children and young people, our website and online services are not intended for children directly and we do not knowingly collect children’s data without parental consent. For more details about the type of data we process about children and how we collect it, see our Beneficiaries privacy notice.
From time to time we may use data processors who process your personal data outside of the European Economic Area (EEA). In these cases, we will always ensure a similar degree of protection is afforded to your data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact the DPO if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
How long will you keep my personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the relevant purposes set out in this privacy notice and in order to satisfy our legal, statutory, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
How we protect your data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Click to find out more:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you or your child and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Object to automated decision making or profiling. This enables you to ask us not to subject your personal data to automated decision-making or profiling with legal or similarly significant effects.
If you wish to exercise any of your rights above, please contact the DPO
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We shall respond to all legitimate requests within one month unless your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated and may take longer to respond.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We hope that you will be happy for us to send you news about the work of the charity and our fundraising campaigns but you are free to change your mind at any time.
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You may receive marketing communications from us if you have given us your contact details when ordering a product, buying a ticket to an event or signing up for a service from us and have not opted out. In other cases, we will ask you for your consent to receive marketing from us when the law requires it.
The Children’s Trust will never share your data with third parties for their direct marketing purposes without your consent.
You can withdraw your consent (if given) or ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting our Supporter Care team at firstname.lastname@example.org or telephone us on 01737 364 349.