Privacy Policy

At Project Salus CIC and Salus Solutions Ltd (“Salus”) we are committed to ensuring that your privacy is protected and respected. As an organisation, Salus is registered with the Information Commissioner’ Office and acts in accordance with the General Data Protection Regulations.

We are both a “data controller” and “data processor” 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”).

More information about the Information Commissioner’s Office can be found here ico.org.uk

This privacy policy explains how any personal information collected about you, or that you provide to us, will be processed.

1. Our Promise

  • To always store your personal details securely.
  • To only hold your information for as long as necessary.
  • To make sure you are always in control of how we use your information, and that you will always have the right to ask us to stop using it, which we will do promptly (unless we are required to retain it to fulfil our legal duties).
  • We will only contact you in the ways that you wish, making use of what you’ve told us and publicly available information to tailor our communications, so that they are more appropriate and relevant to your interests.

2. How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

  • By email
  • Or write to us at: FAO Data Protection Officer, Salus, Greenacres Barn, Pound Lane, Smeeth, Ashford, Kent TN25 6RJ

3. Your acceptance of this policy and our right to change it

By using our website, social media pages or providing your information to access a service, you consent to our collection and use of the information you provide in the way(s) set out in this policy and relevant Privacy Notice.

We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated on 16 May 2018.

4. What information do we collect about you?

Personal information is any information that can be used to identify you. So, for example, if you are referred or request our services, participate in surveys or request information we may collect and process the personal information that you have provided.

The information we collect differs depending upon the reason we are collecting it. Please see the relevant Privacy Notice for detailed information. If you are unclear where to locate this, please get in touch using the contact details at the end of this policy.

We will only ever collect the information we need – including data that will be useful to help improve our services.

Information may include:

  • Personal information such as name, age (if applicable to the service), postal address, phone number, email address, reasons for referral (if applicable), other agencies accessed (if applicable).
  • Non-personal information such as pages access and files downloaded. This helps us determine how many people use our website, how many people visit on a regular basis, and how popular our pages are. This information doesn’t tell us anything about who you are or where you live. It simply allows us to monitor and improve our services.

We collect this information in connection with specific services, such as referrals for support, training requests, mailing list sign up, feedback, etc. The information is either needed to fulfil your request or to enable us to provide you with an appropriate and personalised service.

You don’t have to disclose any of this information to browse our website. However, if you do choose to withhold requested information, we may not be able to provide you with complete or particular services.

You may give us information about you when you:

  • Sign up to our mailing list on our website or through direct contact
  • order services from us (e.g. training, qualifications)
  • make an enquiry about our activities or services
  • seek care, support and assistance from us (e.g. by making a referral to us and/or by attending one of our services)
  • request publications, newsletters or other information from us
  • volunteer with us or apply for a job (including sending us your CV)
  • report a problem with our website
  • otherwise give us personal information

You may give us this information when you correspond with us by our website, phone, email or otherwise.

Information we receive from other sources:

We may also obtain personal information about you from other sources, such as if a family member, a friend or an agency worker (such as a GP, Social Worker, Early Help Worker, Teacher or Pastoral Staff) contacts us on your behalf. We may also combine your personal information with other information we collect from third parties.

If you are aged 16 or under, you should usually seek your parent/guardian’s permission before you provide any personal information to us.

5. How will we use the information about you?

We will use the information you to:

  • Fulfil your requests – such as provision of information
  • Record any contact we have with you
  • Provide a bespoke service to you, and evaluate that service to measure whether it has made a difference
  • Provide you with information about other services and products we offer that are similar to those that you have already purchased or enquired about
  • Prevent or detect fraud or abuses of our websites and enable third parties to carry out technical, logistical or other functions on our behalf
  • Send you information and communications about what we do and how we can help you, and how you can help us
  • If you have agreed to it, provide you with information that we think may be of interest to you.
  • Carry out our obligations arising from any contracts entered into between you and us
  • Look into, and respond to, complaints, incidents, near misses, legal matters or any other issues.
  • Send you information and communication around your application, employment or volunteering role.

Marketing

We would like to send you information about products and services of ours which may be of interest to you. If you have consented to receive marketing, you may opt out at a later date. You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us at dpo@salusgroup.org.uk.

Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor us of our website and to compile statistical reports on website activity.

For further information visit aboutcookies.org or allaboutcookies.org.

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

6. What is our lawful basis for processing your information?

Salus will process personal information in most instances by obtaining your consent. This is the case, for example, where we seek to obtain your consent to receive marketing communications via email, and when you submit a referral to us for support.

If there are any safeguarding concerns, we may process personal information to comply with a court order or legal obligation, or where it is necessary to protect somebody’s vital interests.

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 Salus to process your information to help us to achieve our vision.

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.

Some examples of where we have a legitimate interest to process your personal information are where we contact you about our work via post, use your personal information for data analytics, improving our services or for our legal purposes (for example, dealing with complaints and claims).

7. How will we share your information?

The personal information that we collect about will be used mainly by our staff (including volunteers) to ensure that you receive the services that you require.

We will never sell or share your personal information with organisations so that they can contact you for any marketing activities.

We will only share your information if:

  • We are legally required to do so, e.g. by a law enforcement agency legitimately exercising a power or if compelled by a Court order or in response to a valid request from a competent authority.
  • We believe it is necessary to protect or defend our rights, property or the personal safety of our staff and volunteers, or visitors to our premises or websites.
  • We are working with a carefully-selected partner that is carrying out work on our behalf. These partners may include marketing agencies or IT specialists. We only choose partners we can trust. We will only pass personal data to them if they have signed a contract that requires them to:
    • Abide by the requirements of the General Data Protection Regulations.
    • Treat your information as carefully as we would.
    • Only use the information for the purposes it was supplied (and not for their own purposes or the purposes of any other organisation).
    • Allow us to carry out checks to ensure they are doing all these things.
  • We are obliged to under the terms of our contract with a third party. Where we are required to do this, we either provide anonymised information or seek your consent to share.
  • We have you your consent to share with other services who may be able to offer support to you or your family.

8. How will we store your information?

We place great importance on the security of all personal data and information. We have security measures in place to protect against the loss, misuse and alteration of personal data under our control.

The personal information that we collect from or about you is usually stored by us on a secure server located in the UK. We may transfer the information to other offices and to other reputable third party organisations as explained above. We may also securely store information in paper files.

On occasion, this information may be transferred to, and stored at, a destination outside the European Economic Area (EEA). By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with the relevant privacy notice.

We will keep your information only for as long as we need it to provide you with the goods, services or information you have requested, to fulfil our contract with you, to comply with the law, or to ensure we do not communicate with you if you have asked us not to do so. When we no longer need information, we will always dispose of it securely as outlined in our data retention guidance within specific Privacy Notices.

While we cannot ensure or guarantee that loss, misuse or alteration of data will not occur while it is under our control, we use our best efforts to try to prevent this.

9. What are your rights?

You have various rights in respect of the personal information we hold about you – these are set out in more detail below.

If you wish to exercise any of these rights or make a complaint, you can do so by emailing us at dpo@salusgroup.org.uk or writing to us at FAO Data Protection Officer, Salus, Greenacres Barn, Pound Lane, Smeeth, Ashford, Kent TN25 6RJ.

  • Access to your personal information: You have the right to request access to a copy of any 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, and how long we keep it for. You can make a request for access free of charge in most circumstances. Please make all requests for access in writing with proof of your identify.
  • 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.
  • Consent: If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time.
  • 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.
  • 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 only apply in certain circumstances and we may not be able to fulfil every request. For more information about your rights under the General Data Protection Regulations, go to the website of the Information Commissioner’s Office at www.ico.org.uk

10. How to make a complaint

If you would like to make a complaint about how we process your personal data, please contact our Data Protection Officer.

If you are not happy with how your complaint is dealt with, you should contact the Information Commissioner’s Office. Alternatively, you are entitled to make a complaint to the Information Commissioner’s Office without first referring your complaint to us. For further information please see the Information Commissioner’s guidance.

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