EMERGE ADVOCACY – PRIVACY NOTICE
1 THIS IS AN IMPORTANT NOTICE ABOUT HOW EMERGE ADVOCACY KEEPS YOUR DATA SAFE
Emerge Advocacy (“Emerge”, “we”, “us” or “our”) has to keep your personal data safe. This Privacy Notice explains how we collect and process (use) your personal data.
We are a charity and our registered charity number is 1171851. Our registered address is at 257 Grange Road, Guildford, GU2 9QX.
Where we collect your personal data directly, we are called the ‘data controller’, which means we decide how and why we process your personal data. Because of the type of support we provide, it is likely we will collect and process what is called ‘special category data’ which is things like data relating to your health.
Personal data is any information that identifies “you”. For example, your name and contact details. It also covers information you may not think is personal data, such as electronic location data, and other online identifiers.
This page, along with our website terms of use and cookie policy, tells you how we use and protect your personal data.
If you are an employee, volunteer, contractor or otherwise engaged in work for us or applying to work for us, a separate privacy notice applies to you instead.
We may occasionally change parts of this Privacy Notice, so please check back regularly if you’d like to stay up to date.
This version of this Privacy Notice was published on 13th of February 2024 and has not been updated since.
2 CONTACTING US
If you have any questions or need to contact us in connection with our use or processing of your personal data, or gain access to it, then our contact details are info@emergeadvocacy.com or you can write to us at 257 Grange Road, Guildford, Surrey, GU2 9QX.
3 WHAT PERSONAL INFORMATION DO WE COLLECT AND HOLD?
We may collect, store, share and transfer the following type of personal information data about you:
• Individual information. This includes information relating to your identity e.g. your name, date of birth, contact details etc.
• Information Technology (IT) information. This includes information relating to your use of our website e.g. your login details or IP address etc;
• Financial information. This includes information about your bank account, any payment card details and information which we collect for the purposes of the prevention of fraud and processing of donations you may have given to us;
• Audio and Visual information. This includes photographs, video footage and audio recordings taken at any of our locations or used as part of our services with you or for promotional purposes;
We may sometimes obtain and use certain aggregated (bundled together) data such as statistical or demographic data for any purpose. This aggregated or bundled data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your IT information to calculate the percentage of users accessing a specific feature on our website. This is not personal data but if we were to re-combine or re-connect any aggregated data with your personal data so that it can directly or indirectly identify you, we would treat this combined data as personal data which will be used in accordance with this Privacy Notice.
We may also collect, store and use the following “special categories” of your sensitive information data which needs more protection. We will not use any of this information without a justified reason. Paragraph 6 below sets out how we may process your special category personal information:
• information about your race or ethnicity
• political opinions, religious or philosophical beliefs
• information about your health.
We do not collect any information about criminal convictions and offences.
4 THE SOURCES FROM WHICH WE OBTAIN YOUR PERSONAL DATA
We obtain your personal data from the following sources:
• Directly from you, either in person (at a hospital or otherwise), through our website or by telephone or through hand held devices. This could include personal data which you provide when you:
(a) subscribe to our mailing list
(b) request information regarding our services to be sent to you;
(c) complete a survey from us or give us feedback; and
• through automated technologies, such as IT recording systems, cookies, server logs and other similar technologies. We also collect browsing data when you visit our website, which may identify your device or web browser. This data is collected by cookies, which are small files stored on your computers’ or mobile devices’ web browser. To understand how we use your device information, please see our Cookie Policy https://emergeadvocacy.com/cookies-policy/ for further details.
• From someone else, such as:
(a) search information providers (such as Google);
(b) providers of payment services for example where you donate to us through a third party website such as Just Giving or Amazon Smile;
(c) providers of social media platforms (such as Facebook, Twitter and Instagram) for example where you share our content through social media, for example by liking us on Facebook, following or tweeting about us on Twitter;
• From publicly available sources, such as the Charity Commission.
5 HOW WE USE YOUR PERSONAL DATA
We collect personal data about you in order to:
a) provide our services to you including providing services for safeguarding children and vulnerable adults. This may include the collection of ethnicity and health date. We use this personal data to assess your needs and to work with other health providers.;
b) manage our relationship with you and enable us to support you u in our work with you including:
• sending you important notices such as communications about changes to our terms and conditions and policies (including this Privacy Notice);
• providing you with important real-time information (e.g. a change of time or location due to unforeseen circumstances);
• sending you information you have requested;
• dealing with your enquiries; and
• asking you to leave a review or feedback on us;
c) administer our business and carry out our business activities including fund raising;
d) make suggestions and recommendations to you about services that may be of interest to you, deliver relevant website content and advertisements to you and to measure or understand the effectiveness of our advertising;
e) communicate with you about, and administer your participation in, special events, programs etc.
f) for internal purposes to use data analytics, to identify usage trends, determine and measure the effectiveness of promotional campaigns and advertising and to improve our website, products/services, marketing, customer relationships and experiences;
g) protect our business including to deal with any misuse of our website and to comply with our security policies at our locations;
h) to comply with our own legal obligations e.g. to comply with health and safety requirements, or to assist in a police investigation;
i) in an official role which we have been asked to carry out by an official authority (e.g. the government) or where we are carrying out other work in the public interest (e.g. which has been designated as such by the Government, or which would be considered to be in the public interest);
j) to detect and prevent fraud and other illegal activities (and to assist regulators, trade bodies and law enforcement agencies); and
k) to record and respond to any comments or complaints from supporters or service users and to investigate and make necessary changes. This helps us to learn and to improve what we do.
6 OUR LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA
Where we may rely on consent
For certain purposes it may be appropriate for us to obtain your prior consent. The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way.
Where we rely on your consent, you may at any time withdraw the specific consent you give to our processing your personal data. Please contact us using the contact details set out in paragraph 1 to do so. But even if you withdraw consent for us to use your personal data for a particular purpose we may continue to rely on other lawful bases to process your personal data for other purposes.
Examples of when we may rely on your consent to process your personal data include:
• where, in the provision of our services to you, we need to use your sensitive / special category personal data such as health information; or
• where we would like to use photos or images taken of you in promotional materials.
Other legal basis we may rely on
Where we are relying on a basis other than your consent, the lawful basis for processing personal data will be one of the following:
a) the processing is necessary in order for us to comply with our legal obligations;
b) the processing is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract;
c) processing is necessary for the establishment, exercise or defence of legal claims; or
d) the processing is necessary for the pursuit of our legitimate business interests. In particular, our legitimate interests include;
• the provision of services;
• analyse our impact and to report to relevant legal authorities
• to develop and the update of our products and services;
• the development of our business strategy;
• protecting our business and property.
e) the processing is necessary in order to protect the vital interests of an individual e.g. where there is a medical emergency at one of our premises;
f) the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
Extra conditions for special category/sensitive personal data
Where we are processing your special category/sensitive personal data one of the following conditions will also apply:
a) you have given your explicit consent to the processing. This is consent that you have freely given, confirmed what we can do and is clear and specific;
b) the processing relates to personal data which has been manifestly made public by you. This includes information that you have disclosed about yourself in the public domain which is easily accessible e.g. social media posts;
c) the processing is necessary for the establishment, exercise or defence of legal claims;
d) the processing is necessary for archiving purposes in the public interest; scientific or historical research purposes or statistical purposes;
e) the processing is necessary to protect an individual’s vital interests where the individual cannot give consent;
f) the processing is necessary for reasons of substantial public interest;
g) processing is necessary in relation to your or our rights in the field of employment and social security and social protection law;
h) processing by a not-for-profit body (e.g.a charity) in certain circumstances;
i) processing is necessary for the purposes of preventative or occupational medicine; and
j) processing is necessary for reasons of public interest in the area of public health.
7 WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH
We will not rent or sell your personal information to any other organisation for use by them in any way including their marketing.
We may share your personal information with other organisations (or persons) in the following ways and for the following reasons:
• to our group companies or those organisations or persons who are our data processers meaning that they process (use) personal data on our behalf to help us to carry out our usual business practices. We will only share your personal information with our data processors so that we can use your personal information for the purposes set out in this Privacy Notice;
• to legal and other regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;
• to our external professional advisers such as accountants, bankers, insurers, auditors and lawyers;
• to law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;
• to other third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
• to third parties operating plugins or content (such as Facebook, Twitter, Instagram) on our website which you choose to interact with;
• to the NHS Mental Health Digital Data Set to help assess the impact of our service.
Sometimes we cannot keep information confidential as we need to ensure all young people and vulnerable adults are safe. This means that if you tell us anything about yourself or another person being hurt or at risk of being hurt, we might need to tell someone who can help. Sometimes the court might order us to share information and you might ask us to share information on your behalf.
8 PERSONAL INFORMATION YOU GIVE US ABOUT OTHER PEOPLE
If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us and that, without our taking any further steps, we may collect, use and disclose that personal information as described in this Privacy Notice.
You must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual’s right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.
9 ACCURACY OF YOUR PERSONAL DATA
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes by contacting us. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
10 WHERE DO WE STORE YOUR PERSONAL DATA
We will do everything we can to make sure that your personal information, whether in paper or electronic form, is treated securely and in accordance with this Privacy Notice. It is possible that personal data we collect from you may be transferred, stored and/or processed outside the United Kingdom including outside the European Economic Area (“EEA”). For example, where our IT system uses a server in another part of the world.
Where we transfer your personal data to and store it at a destination outside the UK or the EEA we will go through a full due diligence process (checks) to help ensure the data has the same levels of security. We will also make sure the transfer of data outside the UK or EEA is done in a way that ensures there are appropriate safeguards in place to protect it in accordance with relevant data protection laws.
11 HOW LONG WE WILL STORE YOUR PERSONAL DATA FOR
Your information is securely stored and kept for the time period which is appropriate in accordance with our data retention policy. If you have used any of our services supporting young people we will make notes of the work we do. We will typically keep these notes until you reach the age of 26 years but this may be longer depending on your circumstances. For more information, or to request a copy of our data retention policy, please contact us using the contact details under paragraph 2 above.
We keep the length of time that we hold your personal data for under regular review.
12 YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
Under data protection laws you may have a number of rights in connection with the processing of your personal data, including:
• Right of access: you can ask us for copies of your personal data that we process or control;
• Right of rectification: you can ask us to change information which may be wrong, or to complete information you think may be incomplete;
• Right to restriction of processing: you can ask us to restrict the processing of your personal data or to erase it in certain circumstances;
• Right to object: You can object to our processing of your personal data in certain circumstances;
• Right to data portability: You can ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances; and
You also have the right to lodge complaints regarding the processing of your personal data with the Information Commissioner’s Office or other relevant supervisory body. Please see https://ico.org.uk/concerns/ for how to do this.
If you would like to exercise any of the rights set out above, please contact us using the contact details set out in paragraph 2.
You are not required to pay any charge for exercising your rights. If you make a request, we usually have one month to respond to you.
13 RIGHT TO COMPLAIN
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details set out in paragraph 2.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
14 LINKS TO OTHER WEBSITES
This policy only applies to us. If you click a link and go to another website from our website, you should remember to read and understand their privacy policy as well.
We do not control and are not responsible for any use of your personal information that is made by unconnected third party websites.