Privacy and Cookies Policy
We want everyone who uses our services, or who supports our work by volunteering or through donations to feel confident that any personal information they share with us will be looked after properly.
This Privacy Policy sets out how we collect, use and protect your personal information (this means any information that identifies or could identify you).
This Privacy Policy may change in accordance with newly introduced legislation, so please remember to check back from time to time. This version has been updated to take into consideration the new EU General Data Protection Regulation 2016/679.
1. Who we are
2. How we collect information about you
3. Information we collect and why we use it
4. Legal basis for using your information
5. Marketing
6. Sharing your Information
7. Keeping your information safe
8. How long we hold your information for
9. Your rights
10. Cookies
1. Who we are
The Baobab Centre is committed to protecting your personal information and making every effort to ensure that your personal information is protected and used in a fair, open and transparent manner.
The Baobab Centre is a "data controller" for the purposes of the Data Protection Act 1998 and (from 25 May 2018) the EU General Data Protection Regulation 2016/679 ("Data Protection Law"). This means that we are responsible for, and control the processing of, your personal information.
For further information about our data protection practices, please contact our Data Protection Officer by:
• Writing to the Baobab Centre for Young Survivors in Exile, 6-9 Manor Gardens, London N7 6LA
• Calling us on 0207 263 1301
• Emailing to info@baobabsurvivors.org
2. How we collect information about you
Everything we do is focused on our charitable aims of providing psychotherapeutic and practical support to children, adolescents and young adults who are refugees or seeking asylum in the UK.
We want to make sure you receive communications that are most relevant to you, be it through visiting our website or receiving emails, post or phone calls. We want to make sure you receive the best attention when you make a referral, start attending the Baobab Centre for treatment and support, register for an event or make a donation.
We collect information from those who come into contact with our organisation in the following ways:
When you interact with us directly: This could be if you are referred to our service, you make a referral to our service, ask us about our services, register with us for training or an event, make a donation to us, apply for a job or volunteering opportunity or otherwise provide us with your personal information. This includes when you phone us, visit our website, or get in touch through the post, or in person.
When you interact with us through partners: This could be if your social worker, local mental health team, lawyer or GP has made a referral to us in discussion with you.
When you interact with us through third parties: This could be if you provide a donation through a third party such as My Donate or other third parties that we work with and provide your consent for your personal information to be shared with us.
When you visit our website: We gather general information which might include which pages are visited most often and which services, events or information is of most interest to those visiting the website. We also use "cookies" to help our site run effectively. There are more details below – see 'Cookies'. We use this information to make improvements and ensure we provide the best service and experience for you when visiting the site.
3. Information we collect and why we use it
Personal Information
Supporters, Volunteers and Participants in Events
Personal information we collect includes details such as your name, email address, postal address, telephone number and credit/debit card details if you are making a donation, or your bank details and National Insurance Number if you are working with us, and your date of birth if you are volunteering with us. It also includes the communications you exchange with us when you call, email or write to us. You will have given us this information whilst making a donation, registering for an event, placing an order on our website, making an application to become a volunteer, or in any number of other ways used to interact with us.
We will mainly use this information:
· To process your donations or other payments, to claim Gift Aid on your donations and verify any financial transactions.
· To provide the services or goods that you have requested.
· To update you with important administrative messages about your donation, an event or services or goods you have requested.
· To comply with the Charities (Protection and Social Investment) Act 2016 and follow the recommendations of the official regulator of charities, the Charity Commission, which require us to identify and verify the identity of supporters who make major gifts so we can assess any risks associated with accepting their donations.
· To communicate with you and manage our relationship with you.
· Where you volunteer with us, to administer the volunteering arrangement and comply with our safeguarding duties.
· Where you work with us to process payments, make PAYE and pension payments on your behalf and comply with our safeguarding duties and our duties as an employer.
· Where you have requested training or registered for an event to ensure that we provide training or other events that meet your needs.
· Your posts and messages on social media when you interact on social media platforms with us such as twitter, Facebook.
If you do not provide this information, we will not be able to process your donation, sign you up for a particular event or provide goods and services you have requested.
We may also use your personal information:
· To invite you to participate in surveys or research as part of our monitoring and evaluation to improve our service.
A special note about the Sensitive Personal Information we hold
Data Protection Law recognises that some categories of personal information are more sensitive. Sensitive Personal Information can include information about a person’s health, race, ethnic origin, political opinions, sex life, sexual orientation or religious beliefs.
If you have provided us with Sensitive Personal Information, we treat that information with utmost care and confidentiality and always in accordance with this Privacy Policy.
If you provide us with sensitive personal information, we will only use this information:
· For the specific purposes of dealing with your enquiry, treatment, training, and quality monitoring or evaluating the services we provide.
· We will not pass on your details to anyone else without your express permission except in very exceptional circumstances, for example if we feel that you are in danger or someone else is in danger or when required by law. Examples of this might include anyone reporting serious self-harm or posing a threat to others or children, or serious issues such as physical abuse or exploitation.
· Where you have given us your express consent or otherwise clearly indicated to us that you are happy for us to share your information in order to support you in accessing or engaging with services or to provide you with practical support, then we may share the information as discussed with you.
· Only if you have given your express consent for us to share your story, then we may publish it on our blog or in other media.
Children
· We are committed to protecting the privacy of young people and we will only ever collect and hold information on a child under 13 with explicit parental consent or the explicit consent of those with parental responsibility. We will make clear the reasons for collecting the information and how the information will be used.
4. Legal basis for using your information
In some cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a contract with you.
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 the Baobab Centre to process your information to help us to achieve our aim of ensuring that everyone experiencing a Mental Health problem gets both treatment and support.
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.
Examples of where we have a legitimate interest to process your Personal information are where we contact you for our legal purposes (for example, dealing with complaints and claims), or for complying with guidance from the Charity Commission.
5. Marketing
We will only contact you about our work and how you can support the Baobab Centre by phone, text or email if you have agreed for us to contact you in this manner. You can update your choices or stop us sending you these communications at any time by contacting info@baobabsurvivors.org.
We may send out general mailshots to all addresses in a local area about our work and how individuals can support Baobab which does not involve the processing of personal data. In doing so we ensure that we comply with the relevant guidelines and codes on marketing and advertising.
6. Sharing your Information
The personal information we collect about you will be used by our staff (and volunteers) at Baobab so that we can engage with you as required.
We will never sell or share your personal information with organisations so that they can contact you for any marketing activities. Nor do we sell any information about your web activity.
Baobab may however share your information with our trusted partners and suppliers who work with us on or on our behalf to deliver our services, but processing of this information is always carried out under our instruction. We make sure that they store the data securely, delete it when they no longer need it and never use it for any other purposes. Some examples of where we may share your information are with our fulfilment partners who help to create and send information to you to reduce our costs, with our partners who help us to process donations and claim Gift Aid and our partners who help us to manage our social media accounts.
We enter into contracts with these service providers that require them to comply with Data Protection Laws and ensure that they have appropriate controls in place to secure your information.
Legal disclosure
We may 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); or, in order to enforce our conditions of sale and other agreements.
7. Keeping your information safe
We take looking after your information very seriously. We've implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.
The Baobab website may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites. This privacy statement does not cover the information practices of those websites or advertisers.
8. How long we hold your information for
We keep your information only for as long as is reasonable and necessary for the relevant activity. The time we also hold onto records takes account of our legal and accounting obligations. We are required to keep details of financial transactions, including donations, for seven years to meet HMRC requirements.
9. Your rights
You have various rights in respect of the personal information we hold about you – these are set out in more detail below. Consent: If you have given us your consent to use personal information, you can withdraw your consent at any time.
If you wish to exercise any of these rights or make a complaint, you can do so by contacting our Operations Manager at Baobab Centre, 6-9 Manor Gardens, London N6 7LA, info@baobabsurvivors.org and by phone on 020 7263 1301. You can also make a complaint to the data protection supervisory authority, the Information Commissioner's Office, https://ico.org.uk/:
· The right to be informed – primarily through this policy – about the collection and use of your personal data - including the purposes for processing personal data, retention periods for that personal data, and who it will be shared with.
· Access to your personal information: You have the right to request access to a copy of the personal information that we hold about you. You can make a request for access free of charge. Please make all requests for access in writing, and provide us with evidence of your identity and we must respond within one month of receipt of the request.
· Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
· Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
· Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
· Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
· Right to object: You can object to our 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. Please contact us as noted above, providing details of your objection.
· Rights related to automated-decision making: the Baobab Centre does not use automated decision-making. However, you may wish to know that you have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given your consent. In such circumstances, it is necessary for a contract to be drawn up between you and the organisation carrying out the decision making, or is otherwise permitted by law. You also have certain rights to challenge decisions made about you. We do not currently carry out any automated decision-making.
10. Cookies
'When you visit our website: our website uses "cookies", as most websites do, to help our site run effectively. There are more details below – see 'Cookies'. We use this information to ensure we provide the best service and experience for you when visiting the website.
'Cookie' is a name for a small file, usually of letters and numbers, which is downloaded onto your device, like your computer, mobile phone or tablet when you visit a website. Cookies let websites recognise your device, so that the sites can work more effectively.
How do we use cookies?
We use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you come to our website and also allows us to improve the user experience.
Our cookies help us:
· Make our website work as you'd expect
· Remember your settings during and between visits
· Improve the speed/security of the site
· Allow you to share pages with social networks like Facebook
· Continuously improve our website for you
We do not use cookies to:
· Collect any personally identifiable information (without your express permission)
· Collect any sensitive information (without your express permission)
· Pass data to advertising networks
· Pass personally identifiable data to third parties
· Pay sales commissions
You can learn more about all the cookies we use below
Granting us permission to use cookies
If the settings on your software that you are using to view our website (your browser) are adjusted to accept cookies we take this, and your continued use of our website, to mean that you are fine with this. Should you wish to remove or not use cookies from our site you can learn how to do this below (turning cookies off).
Website Function Cookies
Third party functions
Our site, like most websites, includes functionality provided by third parties. A common example is an embedded Vimeo video. Our site includes the following which use cookies:
· Vimeo
· Google maps
Disabling these cookies may break the functions offered by these third parties
Visitor Statistics Cookies
We use cookies to compile visitor statistics such as how many people have visited our website, what type of technology they are using (e.g. Mac or Windows which helps to identify when our site isn't working as it should for particular technologies), how long they spend on the site, what page they look at etc. This helps us to continuously improve our website.
Turning Cookies Off
You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies (Learn how here). Doing so however will likely limit the functionality of our and a large proportion of the world's websites as cookies are a standard part of most modern websites
The cookie information text on this site was derived from content provided by Attacat Internet Marketing http://www.attacat.co.uk/, a marketing agency based in Edinburgh. If you need similar information for your own website you can use their free cookie audit tool.
Data collected
In common with most web sites, our website automatically logs certain information about every request made of it (see below for more details). This information is used for system administration, for bug tracking, and for producing usage statistics. The logged information may be kept indefinitely. Relevant subsets of this data may be passed to computer security teams as part of investigations of computer misuse involving this site or other computing equipment. Data may be passed to the administrators of other computer systems to enable investigation of problems accessing this site or of system misconfigurations. Data may incidentally be included in information passed to contractors and computer maintenance organisations working for Baobab, in which case it will be covered by appropriate non-disclosure agreements. Otherwise the logged information is not passed to any third party except if required by law. Summary statistics are extracted from this data and some of these may be made publicly available, but those that are do not include information from which individuals could be identified. You should appreciate that a log is a record of what a server sees, not necessarily what was initially sent. If a request is sent via a proxy the log file will show the proxy's address.
Logged data
The following data is automatically logged for each request:
· The name or network address of the computer making the request. Note that under some (but not all) circumstances it may be possible to infer from this the identity of the person making the request. Note also that the data recorded may be that of a web proxy rather than that of the originating client.
· The date and time of connection
· The HTTP request, which contains the identification of the document requested
· The status code of the request (success or failure etc.)
· The number of data bytes sent in response
· The contents of the HTTP Referrer header supplied by the browser
· The content of the HTTP User-Agent header supplied by the browser
Logging of additional data may be enabled temporarily from time to time for specific purposes. In addition, the computers on which the web site is hosted keep records of attempts (authorised and unauthorised) to use them for purposes other than access to the web server. This data typically includes the date and time of the attempt, the service to which access was attempted, the name or network address of the computer making the connection, and may include details of what was done or was attempted to be
If you have any questions about how we use cookies, please contact us at: info@baobabsurvivors.org
If you have any questions about the Baobab Centre's Privacy Policy or data protection procedures, please contact: info@baobabsurvivors.org or telephone: 0207 263 1301 and ask to talk to the Operations Manager.