SAFA – Privacy and Cookies Policy

In brief:

The Policy below sets out how we will use data that you provide to us through this website, and information that we will store during and after your visit (these are called ‘cookies’). We recommend that you read the Policy in full, but in brief:

  • we’ll process ‘contact’ and ‘communications’ data that you provide to us so that we can deliver our services to you (for example, process referrals for counselling)
  • we’ll process ‘usage data’ about how you use the website – in particular the SAFA Self-Care Toolbox – so that we can make it better and undertake research about how the Toolbox helps support good mental health and wellbeing
  • if you register for our website we’ll process your ‘account data’
  • we’ll process all of this data in accordance with relevant data protection legislation
  • we’ll store cookies to help make the experience of using our website as good as possible.

In detail:

  1. Introduction
    1. We are committed to safeguarding the privacy of our website visitors.
    2. This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
    3. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of the website, we will ask you to consent to our use of cookies when you first visit our website.
    4. In this policy, "we", "us" and "our" refer to SAFA Cumbria. For more information about us, see Section 15.
  2. The personal data that we collect
    1. In this Section 2 we have set out the general categories of personal data that we process.
    2. We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you although some elements of the account data may be generated by our website.
    3. We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication, generated by our website.
    4. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is both our website and Google Analytics.
    5. Please do not supply any other person's personal data to us, except where you are making a professional referral to us as a GP or other health professional.
  3. Purposes of processing and legal bases
    1. In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
    2. Operations - We may process your personal data for the purposes of operating our website and providing our services (for example, providing information resources through the SAFA Self-Care Toolbox. The legal basis for this processing is our legitimate interest in the proper administration of our website and delivery of our services.
    3. Relationships and communications - We may process contact data, account data and or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interest in communicating with our website visitors and service users, the maintenance of relationships, and the proper administration of our website and services.
    4. Research and analysis - We may process usage data for the purposes of researching and analysing the use of our website and services. The legal basis for this processing is our legitimate interest in monitoring, supporting, improving and securing our website and services.
    5. Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services, and the protection of others.
    6. Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
    7. Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
  4. Purposes of processing and legal bases
    1. We may disclose your contact data to our suppliers or subcontractors (for example, counsellors) insofar as reasonably necessary for the development of our website – in particular the SAFA Self-Care Toolbox, and delivery of our services.
    2. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
  5. Retaining and deleting personal data
    1. This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
    2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
    3. We will retain your personal data as follows:
      1. contact data will be retained for a minimum period of one year following the date of the most recent communication between you and us, and for a maximum period of three years following that date;
      2. account data will be retained for a minimum period of one year following the date of closure of the relevant account, and for a maximum period of three years following that date;
      3. communication data will be retained for a minimum period of one year following the date of the communication in question, and for a maximum period of three years following that date];
    4. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
      1. the period of retention of usage data will be determined based on the timescales of any research and analysis relating to use of our website and services, in particular relating to the SAFA Self-Care Toolbox.
    5. Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  6. Your rights
    1. In this Section 8, we have listed the rights that you have under data protection law.
    2. Your principal rights under data protection law are:
      1. the right to access - you can ask for copies of your personal data;
      2. the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
      3. the right to erasure - you can ask us to erase your personal data;
      4. the right to restrict processing - you can ask us to restrict the processing of your personal data;
      5. the right to object to processing - you can object to the processing of your personal data;
      6. the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
      7. the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
      8. the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
    3. These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
    4. You may exercise any of your rights in relation to your personal data by written notice to us.
  7. Third party websites
    1. Our website includes hyperlinks to, and details of, third party websites.
    2. In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
  8. Personal data of children
    1. Our website and services are targeted at persons over the age of 11.
    2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
  9. Updating information
    1. Please let us know if the personal information that we hold about you needs to be corrected or updated.
  10. About cookies
    1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
    2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
    3. Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
  11. Cookies that we use
    1. We use cookies for the following purposes:
      1. authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to determine if you are logged into the website
      2. personalisation - we use cookies to store information about your preferences and to personalise the website for you
      3. security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally
      4. analysis - we use cookies to help us to analyse the use and performance of our website and services
      5. cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally
  12. Cookies used by our service providers
    1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
    2. We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.
  13. Managing cookies
    1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
      1. https://support.google.com/chrome/answer/95647 (Chrome);
      2. https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
      3. https://help.opera.com/en/latest/security-and-privacy (Opera);
      4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
      5. https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
      6. https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
    2. Blocking all cookies will have a negative impact upon the usability of many websites.
    3. If you block cookies, you will not be able to use all the features on our website.
  14. Amendments
    1. We may update this policy from time to time by publishing a new version on our website.
    2. You should check this page occasionally to ensure you are happy with any changes to this policy.
    3. We may notify you of significant changes to this policy by email.
  15. Our details
    1. This website is owned and operated by SAFA Cumbria.
    2. We are registered in England and Wales under the Company registration number 6344630 and the Charity registration number 1121122 and our registered office is at Phoenix Business Yard Unit 2 Walney Road Barrow in Furness LA14 5UT.
    3. Our principal place of business is at Phoenix Business Yard Unit 2 Walney Road Barrow in Furness LA14 5UT.
    4. You can contact us:
      1. by post, to the postal address given above;
      2. by telephone, on (01229) 832269
      3. by email, using help@safa-selfharm.com