Privacy policy

How we respect privacy when we deal with personal information collected by our organisation

If you have any questions or would like toexercise any of your rights, please get in touch via the following information: 

Email us: [email protected]

Data Protection Officer: Hope & May:[email protected]

If you are unhappy with the way we process your data, you can also make a complaint to the Information Commissioner’sOffice (ICO) which regulates the use of information in the UK. They can be contacted by:

Telephone 0303 123 1113

Write to the ICO: InformationCommissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Or by going online to www.ico.org.uk/concerns

1.  Who are we?

My Black Dog is a charity that offerspeer-to-peer support for people who are struggling with their mental health.For the purposes of UK Data Protection Law, My Black Dog is registered with theICO under the registration number ZB596066.

In this Notice, ‘My Black Dog’, 'we', 'us','our' means:

My Black Dog - Registered Charity Number 1182690 with aregistered address at 88/90 Baker Street, London, W1U 6TQ

2.  Personal data collected, how and why we collectit, and on what lawful basis

Appendix 1 – Human Resources (employees,trustees, job applicants and volunteers)

Appendix 2 – Service Users

Appendix 3 – Donors, websites visitors andcookies

 

3.  Fundraising and Marketing Communications

Your contact details may be used to provideyou with information about our services or our fundraising opportunities via e-messages.We will only send you fundraising and marketing communications by email, textor other electronic message if you have explicitly provided your consent. Youmay opt-out of our fundraising and marketing communications at any time byclicking the unsubscribe link at the end of our marketing emails.Alternatively, you can get by using any of the contact details listed at thetop of this notice.

 

4.  Your Rights

Under the data protection laws, you havecertain rights over the personal information that we hold about you. If youwould like to exercise your rights, please get in contact with any of thedetails listed above. Here is a summary of the rights we think apply:

 

a)    Right to be Informed

You have the right to be informed as to how weuse your data and under what lawful basis we carry out any processing. ThisPrivacy Notice sets this information out however if you would like furtherinformation, please get in touch.

 

b)    Right of Erasure – also known as the right to be forgotten

You may ask us to delete some or all of yourinformation we hold about you. Sometimes where we have a legal obligation wecannot erase your personal data.

 

c)    Right to Object

You have the right to object to processingwhere we are using your personal information such as where it is based onlegitimate interests or for direct marketing.

 

d)    Inaccurate personal information corrected

Inaccurate or incomplete information we holdabout you can be corrected. The accuracy of your information is important to usand we are working on ways to make this easier for you to review and correctthe information that we hold about you. We will also carry out an annualaccuracy check. If any of your information is out of date or if you are unsureof this, please get in touch through any of the contact details listed in thisnotice.

 

e)    Right of restriction

You have a right to restrict the processing ofsome or all of your personal information if there is a disagreement about itsaccuracy, or we are not lawfully allowed to use it.

 

f)     Right to Access your information

You have a right to request access to a copyof your personal information that we hold about you, along with the informationon what personal information we use, why we use it, who we share it with, howlong we keep it for and whenever it has been used for automated decisionmaking. You can make a request for access free of charge and proof of identityis required.

 

g)    Right to withdraw consent

Where you have provided consent to our use ofyour data, you also have the right to withdraw that consent at any time. Thismeans that we will stop processing your data.

 

5.  Transferring your information outside of theUnited Kingdom

Wherepersonal data is stored outside of the UK and the EEA, safeguards to protectpersonal data may include but are not limited to the UK Addendum used inconjunction with the EU Standard Contractual Clauses (SCCs), or UKInternational Data Transfer Agreement (IDTAs). Such safeguards will be subjectto Transfer Risk Assessments (TRAs).

6.  Making a complaint

If you thinkyour data rights have been breached or you are not happy with how we handleyour data, you are able to raise a complaint with us by contacting [email protected] can also contact the ICO at Information Commissioner's Office, WycliffeHouse, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113(local rate) or 01625 545 745.

7.  Changes to our Privacy Notice

We may modify this Privacy Policyfrom time to time and will publish the most current version on our website. Ifa modification meaningfully reduces your rights, we'll notify people whosepersonal data we hold and is affected.

This Privacy Policy applies to information we, My Black Dog, collect aboutindividuals who interact with our organisation. It explains what personalinformation we collect and how we use it. If you have any comments or questionsabout this notice, feel free to contact us at [email protected]

 

APPENDIX 1 – Human Resources

Freelancers, job applicants and current and former employees, and volunteers

How and when do we collect information about you?

You provide several pieces of data to usdirectly during the recruitment period and subsequently upon the start of youremployment/engagement.

 

We will sometimes collect dataabout you from third parties, such as employment agencies or former employers, whattypes of information is collected about you and who provides it?

Wekeep several categories of personal data on our employees/freelancers/job applicants andvolunteers to carry out effective and efficient processes. We keep this data ina personnel file relating to each individual and we also hold the data withinour computer systems, for example, our holiday booking system.

 

Specifically,depending on your type of engagement with My Black Dog, we may process thefollowing types of data:

a)    personal details such as name,address, phone numbers

b)    name and contact details of yournext of kin

c)    your photograph, your gender,marital status

d)    footage of the organisation eventswhere you may appear

e)    informationsubmitted voluntarily of any disability or other medical information you havedisclosed

f)     right to work documentation

g)    information gathered via therecruitment process such as that included in a CV, cover letter or applicationform, references from former employers, details on your education andemployment history etc

h)    National Insurance number, bankaccount details and tax codes

i)     information relating to youremployment with us (e.g job title, job description, salary, terms and conditionof the contract, annual leave records, appraisal and performance indication,formal and informal proceedings involving you such as letters of concern anddisciplinary, disciplinary and grievance proceedings.

j)     internal and external trainingmodules undertaken

k)    information on time off from workincluding sickness absence, family related leave etc

l)     IT equipment use includingtelephones and internet access

m)  your biography and picture for thewebsite (if applicable).

 

We may also process special category of datawhich include health information, sexual orientation, race, ethnic origin,political opinion, religion, trade union membership, genetic and biometricdata. We may also process criminal records information if the role involves DBScheck.

How is the information used?

We are required to use your personal data forvarious legal and practical purposes for the administration of your contract ofemployment or your volunteer agreement, without which we would be unable toemploy you. Holding your personal data enables us to meet variousadministrative tasks, legal obligation or contractual/agreement obligation.

Lawful basis for processing

Wemainly use ‘contractual obligation’ as a lawful basis for processing yourpersonal data for employees, job applicants and Volunteer. We mainly use ‘legitimateinterest’ for volunteers. We may also have legal obligation to process andshare your data, for example we need to share salary information to HRMC or usesome of your data to enrol a new employee on a pension scheme. When processingspecial category of data, we may use your consent.

We may rely on our legitimate interest forprocessing activity such as keeping supervision and appraisal records; usingyour image, bio and videos/pictures of the organisations’ events where you mayappear on our website or marketing/fundraising materials to promote thecharity. When relying on legitimate interest, we may undertake a balancing testto ensure your rights are upheld.

When processing criminal records (for example,to perform DBS check), andallegation records of employees and volunteers, the organisation relieson the lawful basis of legitimate interest, and Condition 10 from Schedule 1, DPA(Data Protection Act) 2018, ("preventing or detecting unlawful acts").

How long do we keep your data?

I. Volunteers

If you aresuccessful, the information you provide during the application process will beretained by us as part of your volunteer file for the duration of yourvolunteer role plus one year following the end of your volunteering.

If you areunsuccessful at any stage of the process, the information you have provideduntil that point will be retained for XXX. Equal opportunities information is retained for up to XXX whether youare successful or not.

II. Employees and freelancers:

We only keepyour data for as long as we need it for, which will be at least for theduration of your employment/engagement with us though in some cases we willkeep your data for a period of 6 years after your employment/engagement hasended. If you’ve applied for a vacancy but your application hasn’t beensuccessful, we will keep your data only for 12 months

Some dataretention periods are set by the law. Retention periods can vary depending onwhy we need your data. Please get in touch by contacting us [email protected]  or [email protected] if you want to know more about retention period.

Data isdestroyed or deleted in a secure manner as soon as the retention date haspassed.

 

Confidentiality - who do we share your data with?

Employees within our company who haveresponsibility for recruitment, administration of payment and contractualbenefits and the carrying out performance related procedures will have accessto your data which is relevant to their function. All employees have beentrained in ensuring data is processing in line with UK GDPR and the DataProtection Act (2018).

Data in relation to your salary is shared withHRMC as part of our legal obligation. Data may be shared with third parties forthe following reasons:      for the administration ofpayroll, pension, HR functions (for example the online holiday booking system),administering other employee benefits (healthcare). When sharing with thirdparties, we have data sharing, processor agreements or contracts in place toensure data is not compromised. Third parties must implement appropriatetechnical and organisational measures to ensure the security of your data.

We may have a section on our website or socialmedia where we upload the name, photo and a short bio of our employees. It isin our legitimate interest to have such information available on the website,but you have the right to object.

Please see section Your rights as DataSubject.  

 

APPENDIX 2 –Guests (service users)

Personal data that we process

When you contact us in an offline mode, wecollect with your name, your email address and the information that youprovided in your request.

 

The conversations you have with our volunteersare only stored as pseudonymised data. This means that we only storeconversation under a Visitor number. We don’t actively collect any informationfrom yourself or from any third party. Your conversations with us may activatedifferent visitor numbers depending on how you log into the chat portal. We only access the storedconversations for safeguarding purposes. For example, we regularly runsafeguarding checks to make sure that you are appropriately supported whenaccessing our service. For more information on confidentiality, please sectionbelow.

How is your information used?

We may use your personal information to

●     Provide an appropriate service which best meets yourneeds;

●     Monitor and manage risk;

●     Safeguarding;

●     Collate anonymised statistical information for fundersand partners

Lawful basis for processing

We mainly rely on the legitimate interest forprocessing your personal data.

When we process special category of data andcriminal records, the lawful basis is supported by additional conditions.

How long do we keep your data for?

We retain the personal data of all our guestsand the conversations had with our volunteers for a period of 5 years.  After this time, personal data will be deleted.

Confidentiality, data sharing and safeguarding  

We do not share data with other parties unlesswe need to, in orderto comply with our dutyof care and safeguarding. We may need to pass some information raisingsafeguarding concern with the authorities. In such circumstances, we rely onour legitimate interest. For example, if during your conversations with ourvolunteers, we identify a serious safeguarding concern, we may track previousconversations in order to provide information to safeguarding bodies only if wecan ensure the accuracy of the data that we disclose.

 

 

APPENDIX 3 –Fundraising, Website and Cookies

Personal data we process

The personal information that we obtain aboutyou is collected via online forms, emails, donations.

 

We may, like many companies, automaticallycollect some of your information when you visit our website via website cookies- more information on cookies can be found under the ‘use of cookies' sectionbelow.

 

We may also collect information that areprovide directly by yourself, for example via the online contact form or emailvia Salesforce (name, email address, phone number) or when completing adonation via Just Giving (email address, Gift aid information).

How is your information used?

We may use your personal information to

●      deal withyour enquiry

●      administerdonations

 

Lawful basis for processing

When processing data about donors we rely on alegitimate interest. We are legally required to hold some types of informationto fulfil our statutory obligations (for example the collection of Gift Aid).

 

When processing information about a generalenquirer, we are most likely to rely on our legitimate interest.

How long do we keep your data for?

We keep your data as long as necessary. Thismeans that if you make an enquiry and we have assisted with the enquiry, wewill only keep your data for a noticeably brief period after your enquiry hasbeen made.

 

If you have donated, we may keep your data for5 years.

 

Data is destroyed or deleted in a securemanner as soon as the retention date has passed.

Confidentiality and Financial transaction – who dowe share the data with?

We rely on Just Giving and Salesforcein order to process the donations. Your card information is not held by us, itis collected by our third-party payment processors (donorbox, stripe, sumup),who specialise in the secure online capture and processing of credit/debit cardtransactions. We will share transaction datawith our payment services providers only to the extent necessary for thepurposes of processing your payments, refunding such payments and dealing withcomplaints and queries relating to such payments and refunds.

We also may disclose your information ifrequired by law, requested by law enforcement authorities, such as HMRC whenyou claim Gift Aid. 

 

We do not share or sell your data with otherthird parties for any marketing purposes.

Use of Cookies

A cookie is asmall file of letters and numbers that is downloaded onto your computer whenyou visit a website. Cookies are used by many websites and can do severalthings, eg remembering your preferences, recording what you have put in yourshopping basket, and counting the number of people looking at a website. Weonly use cookies that do not collect personal information but that do help uscollect anonymous information about how people use our website. We use GoogleAnalytics for this purpose. Google Analytics generates statistical and otherinformation about website usage by means of cookies, which are stored on users'computers. The information collected by Google Analytics about the usage of ourwebsite 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.

Links to other websites

Our websites may contain links to other sites. While wetry to link only to sites that share our high standardsand respect for privacy, we are not responsible for the content, or the privacypractices employed by other sites. Please be aware that advertisers or websitesthat have links on our site may collect personally identifiable informationabout you. This Privacy Notice does not cover the information practices ofthose websites or advertisers.