Privacy Notice & Cookies Policy

The Rekindle website is controlled and managed by Rekindle. The charity is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you before, during and after your relationship with us as, in accordance with the UK General Data Protection Regulation (GDPR).

​

​Rekindle is a registered charity, charity number 1067356, registered office at 2-3 Ladywell Centre, New Church Street, Newtown, SY16 1AF.

As part of ensuring the effective running of our service and its associated operations it is essential that we hold and use data and information about clients, clients’ emergency contacts, staff and trustees. It is important to us that we do this professionally and in line with our statutory, moral and contractual obligations, and this notice is part of how we explain how we do this. Legally the charity is a Data Controller under the Data Protection Act 2018 / the UK General Data Protection Regulation. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. The responsible officer at Rekindle is Lizzie Cockle who is Data Protection Officer (DPO). This notice applies to current and former clients of Rekindle. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

DATA PROTECTION PRINCIPLES

We will comply with data protection law. This says that the personal information we hold about you must be:

(a) Used lawfully, fairly and in a transparent way.
(b) Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
(c) Relevant to the purposes we have told you about and limited only to those purposes.
(d) Accurate and kept up to date.
(e) Kept only as long as necessary for the purposes we have told you about.
(f) Kept securely.

 

THE TYPE OF INFORMATION WE HOLD ABOUT YOU

​

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are special categories of more sensitive personal data which require a higher level of protection, such as information about your health.  We set out below when we will process your personal and special personal data and when we will ask for your consent.

 

We will collect, store, and use the following categories of personal information about you:

 

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;

• Date of birth;

• Gender;

• Emergency contact information [and please note, where you provide this information to us, it is your responsibility to ensure that those named are aware of and accept the terms of this Privacy Policy];

• Information obtained through electronic means such as referral records;

• Records of your reading / consenting to policies, procedures and other directives relating to your time as a client of Rekindle;

• Information about any surveys or marketing initiatives you may have participated in, or if you have signed up to our newsletter;

• Details of your attendance at our site recorded by our systems;

• Technical information collected during your online interaction with us, such as IP address

 

We may also collect, store and use sensitive personal data including the following:

Information about your health, including any medical condition or related records which are made known to us at the time of your referral or subsequently, and which may have an impact on or be relevant to the support we provide you.

​

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We collect personal information about you primarily from your referral and from the client information form and demographic information form normally completed at your initial appointment. We may also gather further information in the course of your relationship with us, for example if you tell us about a change in your health while you are receiving support.

 

HOW WE WILL USE INFORMATION ABOUT YOU

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information as permitted under article 6 of the UK General Data Protection Regulation, for example in the following circumstances:

(a) Where we need to deliver our service to you; 
(b) Where we need to comply with a legal obligation.

We may also use your personal information in the following situations:

(c) Where we need to protect your interests (or someone else’s interests);
(d) Where it is needed in the public interest or for official purposes; for example for the NHS Test and Trace service during the COVID-19 pandemic
(e) Where you have given your consent, for example if you choose to sign up for any additional services we may offer

 

Legal basis for using your information
In some cases, we will only use your personal information where we have your consent.

However, there are other lawful reasons that allow us to process your personal information and one of those is called ‘legitimate interests’. This means that the reason that we are processing information is because there is a legitimate interest for Rekindle to process your information to help us to continue to deliver services and support the mental wellbeing of our clients.

Whenever we process your Personal Information under the ‘legitimate interest’ lawful basis we make sure that we take into account your rights and interests and will not process your personal information if we feel that there is an imbalance.

Some examples of where we have a legitimate interest to process your personal information are: where you have accessed a service funded by a particular funder and we have to report that funding to justify the project.  This data will always be anonymised in funding reports; to apply for funding, to show that a particular service is needed; to improve our services; for our legal purposes (for example, dealing with complaints and claims), or for complying with guidance from the Charity Commission.

In very specific circumstances we will rely on ‘vital interests’ as a legal basis to process your information.  We will only use this legal basis when the situation is about protecting someone’s life (for example if we consider you to be a significant risk to yourself or other people, or if you have told us about a situation that involves abuse of some kind.  In these circumstances Rekindle has a duty of care to protect and we must report what we know to the appropriate agency/authority.  In this situation we will always tell you that we will be passing this information on (as long as the disclosure of this information to you does not increase the risk), but we do not need to seek your permission to do so.

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you, to enable us to comply with legal obligations and/or where it is needed in the public interest or for official purposes. The situations in which we will process your personal information are listed below.

 

• To provide you with the important advice and support you’ve asked us for;

• To provide or administer activities relating to all our services: updating you with important administrative messages, to help us identify you when you contact us, and help us to properly maintain our records and provide the quality services that you have requested;

• To improve your experience with us. We may use your information to enhance the service that our staff provide;

• To provide you with information about our plans. This may be letting you know about new or enhanced services that we hope will be useful and interesting to you, and may include fundraising updates; of course, we will only do this with your consent and you can change your mind and remove or add your consent at any time by contacting us;

• To analyse the personal information we collect about you so that we can better understand our clients, their preferences and needs and important trends;

• To fulfil funder obligations and provide up to date statistics for future funding applications (this data will all be anonymised);

• We may need to disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority);

 

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to assess your support needs or perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of other clients and staff on the premises or we may be unable to discharge our obligations which may be in the public interest or for official purposes.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information 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 may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

HOW WE USE SENSITIVE PERSONAL DATA INFORMATION

If you use our services you may choose to provide details of a sensitive nature.  We only use it for the purposes of dealing with your enquiry, providing quality services, and quality monitoring of, or evaluating, the services we provide. We will not pass on your details to anyone else without your express permission except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or posing a threat to others, children contacting us and sharing serious issues.

 

If you provide us with any Sensitive Personal Data by telephone, email or by other means, we will treat that information with extra care and always in accordance with this Privacy Notice.

Your personal information and details are stored on a secure database for no longer than is necessary for the purposes of its use. We carry out periodic deletion of data whose retention period has expired and/or when the need to continue holding such data is no longer necessary.

Do we need your consent?
We do not need your consent if we use your sensitive personal data in accordance with our written policy where processing is necessary:

• for reasons of substantial public interest, on the basis of UK law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and we provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

 
DATA SHARING

We may have to share your data with third parties, including third-party service providers and other organisations.

In particular, we may share your data with organisations and individuals including, but not limited to, the following:

• the provider of the referral system
• insurance providers, for example if we need to file a report of an incident
• your GP (or other specialist) only if this is necessary as a result of a medical condition made known to us which may impact your use of our services

We require third parties to respect the security of your data and to treat it in accordance with the law. Some of the organisations referred to above are joint data controllers with us. This means we are all responsible to you for how we process your data.

 

Why might we share your personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer our relationship with you or to protect your health and safety, where it is needed in the public interest or for official purposes, or where we have your consent. 

 

Which third-party service providers process your personal information?

“Third parties” includes third-party service providers (including contractors and designated agents).

The following third-party service providers process your personal information for the following reasons:

• Lamplight, the Customer Relations Managements system we use for referrals

• Wix.com, the website/app providers who provide and maintain contact form we use to interact with you; and please note that the Wix.com membership platform may include links through to social media providers or single sign-ons, and in this case if you click through to other sites then that site’s Privacy Policy will apply

 

How secure is your information with third-party service providers?

Our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. You should note their own Privacy Policies which may also apply when you use the services provided by the third parties.

 

What about other third parties?

We may share your information with other third parties if we are required lawfully to do so, or if we have your consent, for example if you consent to receive marketing communications from our partners. In these circumstances your data will only be transferred securely and in accordance with the consent you have given, and as noted in this Privacy Notice you have the right to change your mind at any time where your consent is the only basis on which we are relying for processing your data in this way.

Transferring information outside the UK

Data stored electronically may be saved on a cloud-based system which may be hosted in overseas, including outside of the UK. If this happens we will take steps to ensure the data is managed and protected as if it were covered by the same protections which apply in the UK.

Personal data may be transferred to other countries, including countries outside the UK, for specific essential purposes – for example if a specific part of your use of our services requires this. Appropriate steps will be taken to keep the data secure.

 

DATA SECURITY

We have put in place measures to protect the security of your information. Details of these measures are available in our Data Protection Policy.

Third parties who are processing personal data on our behalf will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Officer, Lizzie Cockle.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

 

DATA RETENTION

How long will we use your information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, insurance or reporting requirements. Details of retention periods for different aspects of your personal information are available in our Data Protection Policy  which is available from the Data Protection Officer, Lizzie Cockle. 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 information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a client of Rekindle we will retain and securely destroy your personal information in accordance with our Data Protection Policy.

 

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your support with us. In particular please ensure your contact and emergency contact information is up to date.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer, Lizzie Cockle, in writing.

The legal timescale for the charity to respond to a Subject Access Request is one calendar month. For further information about how we handle Subject Access Requests, please see our Data Protection Policy.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Officer, Lizzie Cockle. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

DATA PROTECTION OFFICER

Rekindle’s Data Controller is the Service Delivery Manager.

The Data Controller is the key decision maker in respect of why and how personal data is used and handled. The Data Controller will ensure that, both in the planning and implementation phases of processing activities, data protection principles and appropriate safeguards are addressed and implemented and that records of processing activity are kept. The Data Controller will also ensure that Privacy Impact Assessments are carried out, when necessary.

 

The Data Controller will oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Controller, Lizzie Cockle at hello@rekindle.org.uk.
 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. You can contact the Information Commissioners Office on 0303 123 1113 or via email   https://ico.org.uk/make-a-complaint/or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact Lizzie Cockle Data Controller.

​

​

Next Review: August 2024