There is no right or wrong way to grieve, it is a very personal process and is individual to each of us, whether we are young or old, and whether you have lost a relative, friend or colleague we all cope differently. Compass is a new service in Merton guiding you through all areas of bereavement.
The death of someone close can be life changing and at a time when you may feel at a loss, there are many legal requirements which need to be fulfilled - we can guide through the process: from registering a death, to arranging a funeral and what an executor needs to do. For whatever your needs may be Compass is just a phone call or email away. We know how difficult bereavement can be – let us guide you.
WIMBLEDON GUILD OF SOCIAL WELFARE
How we use your information
1. What is the purpose of this document?
We are committed to protecting the privacy and security of your personal information, in accordance with the EU General Data Protection Regulation (GDPR) and UK’s Data Protection Act 2018.
This Privacy Notice describes how Wimbledon Guild of Social Welfare (referred to as "Wimbledon Guild" or "we" or "us") collect and use personal information about our customers, clients, volunteers, training delegates, private room hire counsellors/psychotherapists, supporters and website visitors (“you”).
It does not describe the personal information that we collect and use about other audience groups, including staff, prospective employees, trustees, members, third party consultants, and residential tenants, which can be obtained from our nominated Data Protection Officer (see section 11).
Additional information about how we use your data for particular activities may also be provided at the time you become involved in such activities
This Privacy Notice is also available in a format that has been tailored for anyone requiring a simpler format, including for clients who are children, for each of our main areas of activity. These shorter versions will be offered when you first apply, register or are assessed for a service or activity with us.
We may update this Privacy Notice at any time, and will always make the latest version available, via our staff and on our website. This Notice was last updated on 25 May 2018
2. What is covered in this Privacy Notice?
|Section heading||Description of contents||Page|
|3.Who we are and data protection principles||The legal requirements placed upon us in the way we collect, use, record and disclose personal information we hold about you.||2|
|4.The kind of information we hold about you and how we use it||
Describes the different types of personal information we may hold about you, including "special categories" of more sensitive personal data which require a higher level of protection, and the reasons. To try and make this easier to navigate, we have divided this into sections according to the type of relationship you have with us, i.e.:
|Section heading||Description of contents||Page|
|5.Direct marketing communications||Describes the types of direct marketing communications that we send and how you can change the way you hear about us.||7|
|6. Other uses of your personal information||Explains the situations, in addition to those outlined in section 4-5, that we may use your personal information e.g. for safeguarding, data analysis and images.||7|
|8.Data sharing with third party (disclosures)||Describes the ways in which we may disclose certain personal information we hold about you and the reasons. To try and make this easier to navigate, we have divided this into the main disclosures that we make on behalf of clients/customers; volunteers; and all individuals.||8|
|9. Data retention||Describes how we have determined the appropriate length of time to retain different types of personal information and explains how you can get a copy of our Archiving and Retention Policy which lists out the retention periods for different kinds of personal information.||10|
|10. Data security||A summary of security measures we have put in place to protect your personal information.||10|
|11.International data transfers||Explains our responsibilities should we ever transfer your personal data to countries outside the UK that are not subject to the same laws.||10|
|12. Your rights in connection with personal information||Describes the rights that you have to access, correct, delete, object, restrict and transfer your personal information, contest any decisions based solely on automated decision-making, withdraw consent and complain to the regulator.||11|
|13.How to contact us about this Privacy Notice||Provides full contact details for our nominated Data Protection Officer.||12|
3. Who we are and data protection principles
Wimbledon Guild is a controller under data protection law, meaning that we decide how your personal information is used and the reasons. Data protection law requires us to ensure that the personal information we hold about you is:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Adequate and relevant to the purposes we have told you about and limited to what is needed for those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
We have appointed a Data Protection Officer, who is responsible for overseeing use of personal data by Wimbledon Guild. You may contact the Data Protection Officer with any queries or concerns about our use of your personal data – refer to section 13 for contact details.
4. The kind of information we hold about you and how we use it
Personal data, or personal information, means any information about an individual who can be identified by us. It does not include data where we do not know the identity of the person to whom it relates or where we have removed information which allows identification (anonymous data).
There are "special categories" of more sensitive personal data which require a higher level of protection.
4.1 Clients and customers
“Clients” and “customers” mean the recipients of our services, including those who receive our counselling, befriending, outreach, bereavement and other welfare services, and those who attend our classes, trips, talks and emotional support groups.
In order to receive these services, determine the type of service you may require, and/or whether you are eligible or able to receive relevant services, we need to collect and use information about you.
This information will be collected from you or from another party (such as a family member or referring organisation), or otherwise created by us when you first apply, are referred, register for a service or are assessed for a service and subsequently whilst providing that service.
We may collect, store, and use the following categories of personal information about you:
If you provide us with information about another individual (such as your next of kin or emergency contact), you should ensure that this person is comfortable with us holding their data, and direct them to this Notice for more information as needed. See also section 4.4 below.
We may also collect, store and use the following "special categories" of more sensitive personal information about you, where relevant to the services we provide. This includes:
4.5 Counselling training delegate
As a delegate attending Continuous Professional Development events and training you will be asked to provide us with your contact details so that we can process your booking via Eventbrite.
The lawful basis for collecting, storing and using your data is that it is necessary for the contract for the provision of training.
4.6 Private room hire counsellors / psychotherapists and other private individuals who book Guild House and Drake House rooms
If you are a self-employed counsellor or psychotherapist or other individual who privately hires rooms from us, we may collect, store and use the following categories of personal information about you:
5. Direct marketing communications
Subject to obtaining your consent, we may from time to time send you direct marketing communications including:
Information about our services.
Information about our fundraising activities and events.
Information to our volunteers about training opportunities and other ways to get more involved with us.
Everyone has the right to object to receiving these, so we include options to enable you to change the way you hear from us, or to stop receiving all or similar marketing communications from us in future in the footer of all our marketing newsletters (digital and print).
You can also do this at any time by contacting us as follows:
6. Other uses of your personal information
We may process your personal information for the purposes of safeguarding children or individuals at risk, to protect them/you from neglect or physical, mental or emotional harm; or protect their/your physical, mental or emotional well-being. Please refer to section 8.3 about disclosures.
We conduct data analysis activities on anonymised data for governance, marketing and fundraising purposes.
We may include images relating to our services within our marketing materials and annual impact report, which could include images of your involvement in such services. We will discuss this with you first to ask for your consent.
(a) Essential cookies – these are required for the operation of our website, for example to enable you to log in to secure areas of the website or make use of a shopping cart and e-payment services.
(b) Analytic/performance cookies – these allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies – these are used to recognise you when you return to our website so that we can personalise our content for you and remember your preferences, e.g. whether you are signed up to email alerts.
(d) Targeting cookies – these record your visit to our website, pages you have visited and links you have followed. We may use this information to make our website and the advertising displayed to you more relevant to your interests.
The table below provides more information about the cookies we use and why:
8. Data sharing with third parties (disclosures)
We may have to share certain personal information about you with third parties for reasons outlined below. We require third parties to respect the security of your data as well.
8.1 Clients and customers
Healthcare providers. Subject to obtaining your consent, we may need to disclose certain personal details (including health details) to your healthcare providers, such as your GP. This would arise, for example, if you ask us to make a telephone call on your behalf to report concerns, arrange an appointment or to obtain a referral to another health specialist because you have communication difficulties, memory loss or lack confidence.
Individuals in companies supplying items purchased as part of our grants programme. Subject to obtaining your consent, we may disclose contact details so that the item(s) can be delivered directly to you. If you ask us to, we may also disclose personal details (including health details) if we think they would help the delivery, for example there are steps leading to your accommodation, you have a hearing impairment and may not hear a doorbell, you may take time to answer the door.
Other professionals working for external agencies. Subject to obtaining your consent, we may need to disclose certain personal details (including health details) with external agencies who need to be involved in the activity or service you have asked us to support you with.
The lawful basis for disclosing your data in these instances is through consent, which we will either obtain at the point of collecting personal data from you or when you ask us to organise this activity or service for you.
Our volunteers, other staff members and trustees. We may need to disclose certain personal details with Wimbledon Guild staff and volunteers directly involved in providing a particular Wimbledon Guild activity or service you have asked us to support you with, or with staff, volunteers or trustees as part of our safeguarding or complaints processes.
Self-employed psychotherapists/counsellors. If you become a counselling client then we may disclose personal details you have shared with us at assessment with your psychotherapist/counsellor, who may not employed by us but acts on our behalf.
Self-employed class instructors. We may need to disclose certain details about health conditions to your class instructor, who are not employed by us but act on our behalf, as your health may affect your participation in the class.
Emergency contact. We may need to disclose relevant personal details to the individual you have given us permission to speak to in relation to a particular matter or in an emergency (such as family and friend member, or another service provider).
|Type of cookie||Function and further information|
|Google analytics||This is common performance cookie that many websites use. It allows us to collect anonymous information about how you and other users use our website and helps us to improve the website.|
The lawful basis for disclosing your data in these instances is through legitimate interests, for the reasons described above for each of the third parties.
Subject to obtaining your consent, we may share your personal information, where appropriate, for example:
|Third party/ies||Purpose||Lawful basis|
|Our technology service providers||The organisations hosting our website; Charitylog, CORE and Access databases; event bookings; survey responses; direct marketing emails; Amazon web services; and Office 365 data act as processors on our behalf, meaning that we remain primarily responsible for how they use your data.||Legitimate interests|
|Other third parties where required or permitted by law.||In these cases we may disclose your personal information without your knowledge or consent, but where practical we will inform you about the disclosure of your personal data at the time.||Legal obligation/ Vital interests/ legitimate interests|
|Statutory or regulatory bodies and law enforcement authorities||These include the Police and Social Services, where relevant. We may disclose your personal information to protect someone at risk/you from neglect or physical, mental or emotional harm; or protect their/your physical, mental or emotional well-being (safeguarding children or adults at risk). In these cases we may disclose your personal information without your knowledge or consent, but where practical we will inform you about the disclosure of your personal data at the time.||Vital interests/ legitimate interests|
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements, which may extend beyond the end of our relationship with you.
We keep different types of information for different lengths of time, which are explained in our Retention and Archiving Policy which is available from email@example.com. 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.
At the end of the retention period any paper-based information will be securely shredded, electronic information is anonymised and any audio or video recordings created solely for training purposes in counselling will be securely deleted or destroyed.
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.
10. Data security
We take the privacy and security of personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. In addition, we limit access to your personal information to just the people who have a business need to know.
Staff are required to acknowledge and sign that they have read, understood and will comply with data protection requirements as part of their contract of employment upon joining Wimbledon Guild.
Data protection is covered at induction and in supervisions with volunteers who have contact with clients. Volunteers sign a Volunteer Agreement to acknowledge that they have received, read and understood our policies and procedures, including those relating to confidentiality.
We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or loss and have several layers of security measures. Our data security procedures include strict user access controls to all systems, strong password protection and technical security measures such as boundary firewalls, malware protection, and auditable internet use.
11. International data transfers
Our activities are based within the United Kingdom. We do not generally transfer your personal data to countries outside the United Kingdom. Should we ever need to do so, we will check that safeguards are in place to protect your data to a similar standard as under UK law.
12. Your rights in connection with personal information You have the right to:
13. How to contact us about this Privacy Notice
If you have any questions about this Privacy Notice or how we handle your personal information, or wish to exercise any of your rights relating to your personal data, please contact our nominated Data Protection Officer:
Head of Finance and Resources 020 8946 0735 firstname.lastname@example.org Wimbledon Guild
Guild House, 30/32 Worple Road, Wimbledon, London SW19 4EF.
|Date of Notice||25 May 2018|
|Date due for review||May 2019|
|Person responsible||Data Protection Officer|