Privacy Notice: this document tells you how your personal information is collected, stored and processed as a result of you making contact with the Charity and submitting an application for funding.
The General Data Protection Regulation (GDPR) is concerned with the personal information that we collect about you and/or your child. This document is a summary of our Privacy Standard – that is our privacy policy.
The information is about all applicants to the Shannon Moore Trauma Trust (SMTT), whether they are adults or children. Where we say “you” and your child is the subject of an application for funding, we are referring to your child. There is also a version of our Privacy Notice specifically for Children and Young People – you can find it on our website and either share it with your child or use it to answer any questions they might have about how their information will be managed by us.
WHAT PERSONAL INFORMATION DO YOU COLLECT AND STORE AND WHY?
We collect information about you in order that:
- We can fully consider the request for funding from the Charity that you will or have applied for
- We can pass your details onto a therapy service who will be in a position to identify the right therapist to help you
- We can keep an up to date record of our financial accounts, including invoicing
In order to do this, we regularly collect the following information:
Personal information such as your name, gender, date of birth, relationships, parents, siblings, children, occupation, address, telephone numbers, email addresses, therapeutic history, medical conditions, medication history, employment, education and social life details.
We also keep sensitive information such as physical and mental health details, sexual life, racial or ethnic origin, religious or other beliefs, financial circumstances, convicted offences, and alleged offences.
We keep a record of our contact with you during the application process from the start of your request, up until the time that you are advised of the outcome of the funding application.
If you are awarded a grant to fund therapy, we will share the details of your online application with the identified therapy provider and we will remove the application information about your personal finances. This will mean that you do not have to repeat the information that they will need to know in order to identify a suitable therapist and make arrangements to start working with you.
We will also confirm with the therapy provider how much money has been given for either assessment and/or treatment and how much you are going to contribute to each session that you attend. The therapy provider will invoice the Charity each month for the cost of your therapy minus the contribution that you have agreed to make. They will invoice you separately for this balance sum.
The therapy provider will separately and additionally ask you to sign their consent contract, including your agreement to their privacy notice as their information and record keeping will be different to that of the Shannon Moore Trauma Trust.
After you have started therapy, we only record information about the invoices that we receive from the therapy service, in order to track the use of any funding that you have been given.
The Shannon Moore Trauma Trust will not routinely know any details of your ongoing therapy but may ask for a summary update of progress if you make a further request for funding beyond the initial grant.
We do need to understand the impact and outcomes that result from the funding grants given. As a registered Charity we are required to report to the Charity Commission and show that we are meeting our purposes. You will be asked to complete an outcome form at the start of your therapy and at the end of any phase of funding. Only a summary of all outcomes will be shared with the Charity Commission and included in our annual report. No personal information will be included and no applicants’ details will be shared. Outcome measures are also important in helping the Charity to understand whether it is making a difference to individuals who it has given grants to.
CAN YOU USE MY DATA FOR ANY OTHER PURPOSES?
We will only use your personal data for the purposes we have collected it for. If we did need to use your data for another reason, we will get in touch and explain the basis for us doing so and seek your consent. We never use your personal details for marketing purposes.
HOW MIGHT MY DATA BE SHARED?
We share the necessary aspects of your data as follows:
- Our Information Technology Support Service (that backs up data in the USA)
- It may be that to make a decision about your funding application it would be helpful to talk to someone in another agency, such as NHS mental health teams, your child’s school, Children’s Services or your GP. You will be asked for explicit signed consent (via an email) to share data or seek information from outside agencies.
- Should you or your child say anything that leads us to feel there is a risk to someone, our responsibility to follow up any safeguarding concerns can over-ride our need to obtain your consent to share your information. Where it is reasonable and safe to do so, we will always share with you our intention to follow up a safeguarding concern. We may however do this without telling you if we feel that doing so, will increase the risk to you or someone else.
It is important for you to know that all of the above agencies and individuals are also bound by GDPR rules, and each one should have their own privacy policy and privacy notice.
HOW IS MY DATA KEPT?
Your data is kept on a secure server, accessible only to the Charity Administrator and the Charity Trustees.
Individual laptops used by the Charity Administrator and its Trustees have security set up with passwords to prevent anyone being able to access your information.
If paper data needs to be stored, it is kept in a locked cabinet which is a secured by the Charity Administrator.
HOW LONG WILL YOU KEEP MY DATA FOR?
For all applicants to the SMTT, we will retain the information we have about you until three months after any application for funding has been considered and an outcome to decline or provide funding has been given. This is to ensure that any funding application has been fully concluded, with the outcome communicated to everyone who needs to know it.
All personal details and contextual information for the application will then be deleted from our records; although the Trust will retain a summarised log of any grant made or declined and it will maintain a log of the grant details for invoicing and accounts reasons.
For all employees of the SMTT, data will be retained for the duration of time they are working for the Charity, and for seven years following the end date of their work with us, if in that period of time: (1) there has been no apparent breach of the contract and/or (2) there have been no proven allegations made against the individual regarding safeguarding or professional poor practice
If there are such allegations about safeguarding relating to an individual, either during their working period with the SMTT or in the seven years following, we will retain their data for 10 years after they have retired, or when they reach 75, whichever is later.
False, malicious or unsubstantiated records are deleted from their personnel record, at the time that this is confirmed to be such.
WHAT IF I JUST MAKE AN ENQUIRY ABOUT FUNDING OR MY APPLICATION FOR A GRANT IS DECLINED?
If you get in touch with us with an initial enquiry and share personal information we will record this information and store it for 16 weeks. If we have not heard back from you after 16 weeks, your personal information will be destroyed. If you confirm that you do not want to pursue a grant application with us within those 16 weeks, we will destroy the information we hold about you immediately.
At the Shannon Moore Trauma Trust, YOU HAVE THE FOLLOWING RIGHTS:
- To be informed of what information we hold about you (this Privacy Notice)
- To see the information we hold about you (free of charge for the initial request)
- To correct any inaccurate information or incomplete personal information (we may ask for verification of this information)
- To request your personal information is erased/deleted/shredded, if you no longer wish for us to retain it. This request may be declined if the information is needed for us to practice lawfully and competently, or if there is an adverse reason (such as a complaint, safeguarding concerns or a legal reason).
WHO DO I CONTACT IF I HAVE A QUESTION ABOUT MY DATA?
Our Data Protection contact is Shoshanah Lyons. Our Charity Administrator is available for questions about anything to do with this Privacy Notice and our Privacy Standard. Please get in touch with us in writing via:
SM Trauma Trust, PO Box 5623, BRIGHTON, BN50 8YF
or email us on: [email protected]
WHAT DO I DO IF I AM UNHAPPY WITH YOUR DATA PROTECTION PROCEDURES?
In the first instance, we would encourage you to contact our Data Protection Officer contact via the central email address as given above. Alternatively, you have a right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk).
