This policy contains 12 sections.
- Who we are
- How we collect information about you
- Information we collect and why we use it
- Profiling: making our work more unique to you
- Legal basis for using your information
- Sharing your information
- Keeping your information safe
- How long we hold your information for
- Your rights
Who we are
Here at Empower Community Interest Company (CIC), we are committed to protecting personal information and making every effort to ensure that personal information is used fairly, openly and clearly.
The law on data protection has been updated and all organisations have to comply with the General Data Protection Regulations (known as GDPR). Under these regulations, we are a “data controller” for the purpose of some aspects of our work and a “data processor” for others. This means we are responsible for, and control the processing of your personal information.
For further information about our privacy practices, please contact our Data Protection Officer by
How we collection information about you
Everything we do is intended to ensure we can help people experiencing isolation, overcome barriers to work and vulnerability, in a supportive and respectful way. We want to make sure you receive the information and help most relevant, be it through visiting our website, or receiving emails, post or phone calls. We want to make sure people receive the best information at all times.
We collect information from you in the following ways
When you interact with us directly. This could be if you:
- Ask us about our activities
- Register with us for training or an event
- Ask a question about employability, mental health or housing
- Apply for a job or volunteering opportunity, or
- Provide us with your personal information. This includes when you phone us, submit a contact request when visiting our website, or get in touch through the post, or in person
When you contact us through third parties. This could be if you access support through the Community Rehabilitation Company (CRC), Jobcentre Plus, or similar trusted organisations working in partnership with us and agree for your personal information to be shared with us.
Information we collect and why we use it
If you agree to become a participant on our mentoring programme or other volunteering activity, we will keep details such as your name, date of birth, address where you are staying, email address, telephone number and emergency contact details, as well as any other information you choose to disclose which will provide the basis of our support.
We will mainly use the information to:
- Provide the services and support you have requested
- Keep a record of your relationship with us, or
- Where you volunteer, to administer the volunteering arrangement
We may also use your personal information to:
- Contact you about our work and how you can support Empower CIC (See section 6 on Marketing for further information)
- Invite you to participate in surveys or research
Sensitive Personal Information
Sensitive Personal Information can include information about a person’s health, criminal convictions, race or ethnic origin, political opinions, sex life, sexual orientation or religious beliefs.
You can of course decide if you want to remain anonymous, if you are happy to share your personal details with staff members or if you would like us to share your story with the media or other parties as part of our work, telling people’s personal stories about the progress they have made through the support we have provided (for example, on our blog).
A special note about the Sensitive Personal Information we hold
Data Protection Law recognises that some categories of personal information are more sensitive.
If you choose to provide details of a sensitive nature, we will only use this information:
- For the purposes of dealing with your support, training, and quality monitoring or evaluating the services we provide
- Where you have given us your express consent or otherwise clearly indicated to us (for example, by submitting your story through our blog) that you are happy for us to share your story, then we may publish it on our blog or in other media
- We will not pass on your details to anyone else without your express permission except in exceptional circumstances. Examples of this include
- reporting serious harm or posing a threat to themselves, others or children where we must adhere to our safeguarding responsibilities
- sharing serious issues such as physical abuse, neglect or exploitation. Our Safeguarding Policy may also be useful
Profiling: Making our work unique to you
We want to improve how we communicate to you and the information we provide through our website; services; products and information. To do this we sometimes use ‘profiling’ and screening methods so that we can better understand your preferences and needs to provide a better experience for you.
We may also work with third party organisations that provide additional insight; this may include general information about you that is publicly available.
This information can be added to the information that you have provided which allows us to use our resources more effectively by better understanding the background of our service users and supporters. Profiling is more accurately about understanding our participants more fully as a whole to provide services that meet your needs.
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 either you or a support organisation to which we are contracted (for example, because you have been referred for support by a partner organisation).
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 Empower CIC to process your information to help us to achieve our vision of ensuring that everyone experiencing barriers to work gets both support and respect.
Whenever we process your Personal Information under the ‘legitimate interest’ lawful basis we make sure that we take into account your rights and interests.
Some examples of where we have a legitimate interest to process your personal information are:
- Where we contact you about our work
- Where we may use your personal information for data analysis
- Conducting research to better understand who our service users are
- Improving our services, or
- For legal purposes (for example, dealing with complaints and claims); or
- For complying with guidance of statutory bodies
We may contact you about our work by letter, phone, email or text message, if you have agreed for us to contact you in this manner. We will always seek an opt-in for marketing purposes.
You can change your mind at any time. update your choices, or stop us sending you these communications at any time by clicking the unsubscribe link at the bottom of the relevant communication or by sending an email to us.
Sharing your information
The personal information we collect about you will mainly be used by our staff (and volunteers) at Empower so that they can support you.
We will never sell or share your personal information with organisations so that they can contact you for any marketing.
Empower 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 also adhere to data protection regulations and GDPR by storing the data securely; deleting when they no longer need it and never using it for any other purposes.
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).
Keeping your information safe
We take looking after your information very seriously. We’ve put in place appropriate physical and security measures to protect the personal information we have under our control, from improper access, use, alteration, destruction and loss.
Our secure Information Technology resources are provided by NHS Care Plus Group for infrastructure, storage and operation.
Although we do our best to protect your personal information sent electronically, it is important to be clear that this we cannot guarantee the security of data transmitted to us.
Our 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 used by other sites. Please be aware that advertisers or websites that have links on our site may collect personally identifiable information about you. This privacy statement does not cover the information practices of those websites or advertisers.
How long we hold your information for
We only keep your information for as long as reasonable and necessary, which may be to fulfil statutory obligations or, for example, retention periods set by funding requirements from organisations we are contracted to provide service for.
You have various rights in respect of the personal information we hold about you set out in more detail below. If you wish to exercise any of these rights or make a complaint, you can do so by contacting us at our office or by writing to us, by email or by phone. In all cases, we will acknowledge your request in five working days and respond more fully within twenty working days wherever possible, or we will contact you again to explain why we may need longer to deal with your request.
You can also make a complaint to the data protection supervisory authority, the Information Commissioner’s Office whose website address is: https://ico.org.uk/
Access to your personal information You have the right to request access to a copy of the personal information that we hold about you, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge. This is known as a ‘Subject Access Request’. Please make all requests for access in writing, and provide us with evidence of your identity.
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 on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Consent If you have given us your consent to use personal information (for example, for mentoring support), you can withdraw your consent at any time.
Rectification or ‘putting things right’ 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; where you have withdrawn consent, or where we have no lawful basis for keeping 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.
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.
Please note, some of these rights may only apply in certain circumstances and we may not be able to fulfil every request.
‘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.
They enable websites to recognise your device, so they work more effectively, and also gather information about how you use the site. A cookie by itself cannot be used to identify you.
The cookies we use
We use the categorisation set out by the International Chamber of Commerce in their UK Cookie Guide.
We use all four categories of cookies:
- Strictly necessary cookies are essential for you to move around our website and to use its features, which may include a shopping basket or blog comments
- Performance cookies collect anonymous information about how you use our site, like which pages are visited most
- Functionality cookies collect anonymous information that remember choices you make to improve your experience, like your text size or location. They may also be used to provide services you have asked for such as watching a video or commenting on a blog
- Targeting or advertising cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. As such, if you visit the Mind website, you may then be more likely to see advertising about their work on other websites as your browsing suggests this is an area of interest
No cookies please
You can opt out of all our cookies (except the strictly necessary ones). Find out how to control and delete cookies in your browser.
But, if you choose to refuse all cookies, our website may not function for you as we would like.
Your communications with our teams (including by telephone or email) may be monitored and/or recorded for training, quality control and compliance purposes to ensure that we continuously improve our customer service standards.