privacy NOTICE

The personal information we collect might include your name, address, email address, sensitive information regarding your mental or physical wellbeing, third parties including family members or medical practitioners, bank details for contractors and key personnel within those contracts. It also might include CCTV footage or phone recordings. This is not an exhaustive list and what personal information we collect is dependent upon the service you are engaging with.

We may collect your personal information in a number of ways. For example, when you:   

• Use our services
• Visit any of our website(s)
• Engage with us on social media
• Download or install one of our apps
• Contact us by any means with queries, complaints etc.
• Book to attend an event
• Choose to complete any surveys we send you
• Comment on or review our services
• Have had your information passed to us by a third party
• Attend our events where we may take photographs

We may use your information to:

• Enable Inspire Wellbeing to provide a service to you
• Seek your views or comments on the services we provide
• Notify you of changes to our services
• Promote our services or for fundraising
• To carry out our obligations arising from any contracts entered into by you and us

We understand that you trust us with your personal information and we are committed to ensuring you can manage the privacy and security of your personal information yourself.

In order to comply with data protection legislation, we need to keep a register of the full range of personal information that we hold and on this register we also must state the legal basis which allows us to hold this information. The law on information protection sets out a number of different bases on which an organisation may collect and process your personal information, including: 

• Consent 

In specific situations, we can collect and process your information with your explicit consent. 

• Performance of a contract 

In certain circumstances, we need your personal information in order to perform a contract that we have entered into with you. 

• Legal Obligation 

If the law requires us to, we may need to collect and process your information.  We may also need to pass your information onto a third party if required by law. 

• Legitimate interest 

In specific situations, we require your information to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and delivering our services.

Within Inspire Wellbeing, access is only available to those who need this information in order to provide a service to you or to fulfil the contract that we have with you. Access may be required by support departments within Inspire Wellbeing, such as ICT, Administration and Finance, as well as those involved in the direct delivery of services to you.

Third Party Providers/Partners that we work in association with

We work closely with various third party providers such as the health professionals, social services, Health Trusts or the Health Service Executive. This is necessary to ensure that we have a range of quality and reliable services designed to meet the needs of our Service Users. The relevant third party provider will use your details to provide Inspire Wellbeing with information and carry out both our and their obligations to you when using the services. In some cases, they will be acting as a data controller of your information and therefore we advise you to read their Privacy Policy.  These third party providers/partners will share your information with us which we will use in accordance with this Privacy Policy.

Third Party Service Providers working on our behalf

We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf for example:

• ICT support providers
• The media – when arranging for you to speak to media outlets (with your consent)
• Any member of our group of companies (this means the Inspire Group and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
• Our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
• Associate Counsellors who are contracted by our Professional Services to deliver a safe and effective clinical counselling service
• Associate Clinical Advisors who are contracted by our Professional Services insofar as to deliver a safe and effective clinical counselling service, assessing and managing risk, allocating services, supervision, clinical oversight and quality assurance.

In addition to the specific disclosures of personal data set out in this Section, 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.

However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.

Please be reassured that we will not release your information to third parties beyond Inspire Wellbeing, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

As long as necessary for the purpose/s it was collected for or for as long as we are legally required to.

This will vary depending on the type of information, legal requirements or other justifications permitted by Data Protection law. We have a Retention & Disposal Procedure which sets out retention periods. If you opt-out from fundraising communications we keep your information only to ensure we don’t inadvertently contact you.

We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations. We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.

The accuracy of your information is important to us. If any of your information that we hold is inaccurate or out of date, please notify us.

You have the right to ask for a copy of the information that Inspire Wellbeing hold about you. This is known as a Subject Access Request and we have 30 calendar days to comply with such a request. There is no charge.

Your Rights

You have the right to:

• Ask us not to process your personal information for fundraising or our marketing of Inspire. If you wish to do this, please contact the Data Protection Officer.
• See copies of information held about you – Subject Access Request (SAR). Please send your request in writing to the Data Protection Officer. Please include copies of up-to-date photographic ID. We will acknowledge as soon as possible and provide information not longer than one month from receipt
• Ask us to amend, update or delete your information in some circumstances or withdraw consent to our processing of your information for particular purposes by contacting the Data Protection Officer.

If you are unhappy with the way we are managing your personal information please contact our Data Protection Officer. If you are still unhappy you can register a complaint to the Information Commissioner’s Office (NI) or the Data Protection Commissioner (ROI).

The Information Commissioner’s Office (UK) is Inspire’s nominated commissioning authority.  If you are in the Republic of Ireland you may contact the Data Protection Commissioner (ROI)

Transfers of personal data to Third Countries

Transferring information abroad – Your personal information may be transferred to, and stored and processed outside the European Economic Area (“EEA”). If this is the case we will ensure that an equivalent level of protection for personal data standards of information security are maintained.

This applies to specific categories of Data Subjects including but not limited to:

• Sole traders and other suppliers to both Inspire Wellbeing CLG and EAP Consultants,
• HSE and TUSLA service users

Security precautions in place to protect the loss, misuse or alteration of your information

When you give us personal information, we take steps to ensure that it’s treated securely. Any confidential and sensitive information is securely filed and we apply software to our ICT to prevent unauthorised access to your information. We have appropriate procedures in place for data security and management of records. All of our staff are trained in data protection and GDPR.

We also monitor compliance with data protection procedures through our internal audit programme.

Should you have any queries regarding any aspect of Data Protection within Inspire Wellbeing, please contact:

Peter Hillier – Data Protection Officer

Inspire Wellbeing

Lombard House

10 – 20 Lombard Street

Belfast

BT1 1RD

Tel: 028 9032 8474 (From NI)

Tel: 0044 28 9032 8474 (From ROI)

Email: dpo@inspirewellbeing.org