This privacy notice provides information on how [WFRS Edinburgh Limited] (operating and known as “Beira’s Place – Edinburgh Women’s Sexual Assault Support Centre” and referred in this Notice as “Beira’s Place”) collects and processes your personal data when you visit our website at www.beirasplace.org.uk, call us, correspond with us, use our services or otherwise share your personal data with us.
We are committed to protecting the privacy and security of your personal information. [WFRS Edinburgh Limited, of 2 Atlantic Square, 31 York Street, Glasgow, Scotland, G2 8AS], is registered as a Data Controllers with the Information Commissioner’s Office (ICO) in line with the General Data Protection Regulations (GDPR) 2016 and is responsible for your personal data.
We have appointed a data privacy manager who can be contacted at email@example.com
The purpose of this Service User Privacy Notice is to inform you about the type of information Beira’s Place records and holds about your while you are using our service and what we do with that information during that time, and when you no longer need the organisation’s support services.
The Notice outlines:
- What information we need
- What we will do with that information and how we will store it securely and confidentially
- What your rights are in relation to this information
- Who we may share this information with, and why, in relation to safeguarding.
Your first contact with Beira’s Place
When you first contact Beira’s Place, we will ask you for some basic information to help us assess whether we are the right organisation for your needs. Beira’s Place provides support and advocacy services to women aged 16 years and over, who have experienced rape, sexual assault, sexual abuse, or sexual exploitation. If we are not the right service for you, we will provide you with support during your call with us and refer you on to an organisation or agency that will be able to offer you more specialised and appropriate services.
If you become a user of our service, we will use that information you provided at our first contact to help us assess what kind of support we can offer and discuss with you what the most appropriate service for your needs (e.g. in person support, online support, email support).
No information will be shared with any member of your family, carers, or friends unless you specifically ask us to do so, and your consent is given freely.
In addition, when you access our website, we may collect certain types of personal data, which we would use to improve your experience of our web-site’s use.
The information we hold
We may collect, record, and hold the following categories of information about you:
- Personal contact details such as name, addresses, telephone number, and email address
- Date of birth
- Next of kin and emergency contact information
- A record of contacts we have had, e.g., for setting up appointments, making enquiries, what information we have sent you.
We may also collect, record, and hold the following ‘special categories’ of more personal sensitive information:
- Information you share with us about your health and wellbeing, including information about any medical conditions or disabilities you may have, and information about your mental health and wellbeing
- Information you share with us about the sexual violence you have experienced
- Information you share about your sexuality, race, or ethnicity
- Information you share with us about any risks to your safety, or the safety of a child or other adult
- Information shared with us, with your consent, by the police, legal agencies and other third parties which relate to your support at Beira’s Place
Please note: We do not ask for medical information for any other reason than to be able to inform emergency services about this if ever required. If a woman becomes unwell at Beira’s Place, we will organise emergency medical care as appropriate. Staff at Beira’s Place are not medically qualified and cannot administer medication or advise on medical conditions.
In addition to these categories mentioned above, as you interact with our website, we will automatically collect the following categories of technical information:
- Internet protocol (IP) address
- Browser type and version
- Information about how you use our website
- Other technology on the devices you use to access this website.
How we will use your personal information
We will only use your personal information in accordance with the law. Most commonly, we will use your personal information in the following circumstances:
- Where you have consented for us to collect, hold, and record your personal information
- Where you have consented for us to receive information from a third party or share information with a third party, where this information relates to your support at Beira’s Place
- To deliver a service to you
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal obligation
We record and hold information relating to people using our services for the following purposes:
- To create a service user contact record on our contacts database, and update this with any changes as required. This record provides us with the relevant information we need to contact you safely and in accordance with how you prefer to be contacted.
- To create a service user support record on our database, and update this as required. Each of our service users are allocated a code by the database, which is not linked to any personally identifying data that would reveal the identity of the service user. We keep a brief factual record of each of our support sessions with a service user.
- To contact you to arrange support appointments.
- To make referrals or to share information with third party agencies, where you have given your explicit consent for this to take place
- Where required to protect someone using our service, a child, or another adult, where we have significant concerns about their safety, or health and wellbeing.
- Where required, to comply with a legal obligation, for example a court order.
- From time to time, to contact people who have used our services, where they have explicitly given consent for us to do so.
- To provide anonymised data about the services we provide to create a picture of the volume and types of support we are delivering so that we can quickly and effectively respond to service user needs and gaps in service provision.
- To improve our website or services.
Why we need this information
Beira’s Place needs to maintain some information about you to ensure that you receive the best possible service while you are with us. This information allows us to:
- Make sure you are getting the kind of support that you need, and that you can access that support regularly
- Ensure that you don’t have to retell your story over and over whenever you contact us
- Monitor the quality of your support so that you are always able to access the best support service we can provide
- If you wish to make a complaint, to ensure that we have as much information as possible to process it quickly and fairly.
Do we share your personal information?
Under most circumstances, we will only share your personal information with third parties with your explicit consent.
The exceptions to this is where we have significant concerns for your safety or health and wellbeing, or that of a child or a vulnerable adult. In these circumstances, we may require sharing your personal information with social services, medical services, or the police. We will always try to keep you informed if we are required to do this. Very rarely, we may also have to comply by law with court orders to share your information. Please refer to Beira’s Place Safeguarding Policy, available upon request.
Do any third-party service providers process your personal information?
Beira’s Place uses a password secure, cloud-based database “Oasis”, to record anonymised information about our work with women affected by sexual violence. The database assigns each woman who uses our service, a unique code. No personally identifiable information such as name, address or other contact details is entered into the database. The database is held securely by a central provider but accessed only by our own organisation. We have put in place appropriate measures to ensure that our third-party service providers treat your information securely, in accordance with law, and only in accordance with our instructions. For more information about this, please speak to your support worker or contact the data privacy manager.
How long will my information be held?
We will keep information relating to people using our service for a period of two years after the service user has exited our service. After two years, all records held by Beira’s Place relating to the service user will be disposed of securely. We keep service user records for two years as women who have used our service may wish to access their records after they have exited, for example if they decide to report to the police or to apply for compensation to the Criminal Injuries Compensation Authority (CICA).
Your consent may be required to collect, store, and process your personal data, especially ‘special categories’ of your personal data. Consent is not a precondition for you receiving our service, but it does help us provide a more effective service to you.
Consent means offering women genuine choice and control under GDPR and it requires a positive ‘opt-in’. We never use pre ticked boxes or any other type of consent by default. We will ask you for a very clear and explicit statement of consent to hold your data. We will:
- Be clear and concise about all aspects of the information we hold about you
- Make it easy for you to withdraw your consent at any time
- Keep consent under review and refresh it if anything changes in relation to your support service.
Although we will mainly rely on your consent as a legal basis for processing of your personal information, we may rely on other legal basis in order to collect, store and process some of your less sensitive or technical information, where it is necessary for our legitimate interest (such as to improve user’s experience of our website and/or services).
Your right to withdraw consent
Where you have provided your consent to the collection and holding of your personal information, you have the right to withdraw consent at any time. To withdraw your consent, please speak to your support worker or contact the data privacy manager.
Your rights under the new General Data Protection Regulations (GDPR)
GDPR gives the following rights for all individuals:
The right to request access to your personal information (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal information we hold about you. If you wish to access your personal information you can complete a Subject Access Form – please ask your support worker or contact the data privacy manager about this.
The right to request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
The right to request erasure of your personal information (also known as the ‘right to be forgotten’). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below)
The right to request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. The right to request a transfer of your personal information to another party.
If you want to review, check, correct or request erasure of your personal information, restrict the processing of your personal data or request that we transfer a copy of your personal information to another party, please speak to your support worker or the DPO
If you have any questions about this Privacy Notice or how we handle or process your personal information you can contact:
Isabelle Kerr, data privacy manager, Beira’s Place on firstname.lastname@example.org
If you would like to make a complaint to Beira’s Place, full information on how to do this can be found on our website at www.beirasplace.org.uk or a paper copy of the policy and procedure can be obtained by calling 0131 526 3944, or by emailing email@example.com
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UN supervisory authority for data protection issues. The ICO can be contacted at:
The Information Commissioner
Telephone: 01625 545700