1. Introduction
We, Women and Girls Network, take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws and the General Data Protection Regulation (GDPR-EU and GDPR-UK).
This privacy notice gives you information on how we collect and process your personal data through your use of this site and any data you may provide if you contact us regarding our products and services.
We have appointed a data protection officer (DPO) who is responsible for monitoring and providing guidance with our GDPR status. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO/us using the contact information in section 15 of this privacy notice.
2. Why we Collect your personal information
We collect personal information directly from you when you contact us by phone, Email, by post, when you fill out a form on our website, or when you meet us in person.
This includes personal information you provide when you:
- Call our telephone advice line or our dedicated sexual violence helpline
- Use our counselling services
- Receive body therapies
- Attend our groupwork sessions
- Use our independent sexual violence advocate (ISVA) service
- Attend support groups or workshops provided through our young women’s Advocacy project (YWAP)
- Access support through our indigo project
- Attend an accredited training course, workshop or seminar run by Women and Girls Network
- Take part in one of our service user involvement projects
- Fill out a form or make a donation via our website
3. What type of personal information do we collect?
We may collect, use, store and transfer the following kinds of personal information about you:
- Identity information such as your name, title, relationship status, date of birth, age, gender, address or borough, immigration status and employment status.
- Contact information such as your address, telephone numbers, email address and GP contact details.
- Support service information such as your involvement with external agencies (e.g., social workers, the police, medical professionals), the number of children you have, background information that you give us (e.g., information about your family and/or your experiences of abuse), a summary of your support needs and notes about any risks to you or others that we identify.
- Referral information including the name of the organisation and/or individual who referred you to WGN and any correspondence received from them.
- Communications and monitoring information such as what types of information you would like to receive from us, your communication preferences, photographs of you at WGN events, quotes from you that we may use in WGN marketing materials, and feedback that you provide on our services.
3.1 Special Category Data
We collect the following special category data from you:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
- Trade union membership
- Criminal offence information such as details of any offences that have been committed against you, crime reference numbers, bail conditions, judgments and details of claims made to the Criminal Injuries Compensation Authority (CICA).
- Information about your health, including any medical condition, health and sickness records, health assessment reports and accident records.
- Details of any absences (other than holidays) from work including time on statutory parental leave and sick leave.
- Where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.
We will only process special category data where we have an Article 9 exception allowing us to do so. In limited circumstance, we will rely on explicit consent. Less commonly, we may use special category data where it is needed in relation to legal claims as per Article 9 Paragraph 2 (f) of the UK GDPR or to protect your vital interests (or someone else’s vital interests) in circumstances where you are not capable of giving your consent as per Article 9 Paragraph 2 (c) of the UK GDPR.
3.2 Third Party Collection of Personal Data
We may also receive personal information about you when we receive referrals from third parties such as social workers, GPs, mental health services or solicitors.
4. LAWFUL BASIS OF PROCESSING INFORMATION
We only collect and use personal information about you when the law allows us to. Most commonly, we use it where:
- The data subject (you) has given consent to the processing activity taking place.
- If the processing is necessary for the performance of a contract
- If the processing is necessary for compliance with a legal obligation to which the controller is subject
- If the processing in necessary for the purpose of the legitimate interest pursed by us or our partners
- If processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent
- If processing is necessary for reasons of substantial public interest
Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three-part test covering:
The purpose test – to identify the legitimate interest
Necessity test – to consider if the processing is necessary for the purpose identified
Balancing test – considering the individual’s interests, rights or freedoms and whether these override the legitimate interests identified.
Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment. Where you have given consent for processing in relation to the processing of data, you have the right to withdraw this consent at any time writing to [email protected], but this will not affect the lawfulness of processing based on consent before its withdrawal.
5. How long do we keep your personal data for?
We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations, and professional obligations that we are subject to. All personal information collected has a defined retention period, which is in-line with our retention policy. If you would like to find out how long your information is being retained, please see “additional information”, section 14 of this notice.
6. Transfers To Third Parties
We may disclose information about you to any of our employees, officers, agents, suppliers, or subcontractors insofar as reasonably necessary for the purposes as set out in this privacy notice.
In addition, we may disclose your personal information:
- To the extent that we are required to do so by law;
- In connection with any legal proceedings or prospective legal proceedings;
- In order to establish, exercise or defend our legal rights;
- To the purchaser, or prospective purchaser, of any business or asset that we are, or are contemplating, selling; and,
- To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
- Except as provided in this privacy notice, we will not provide your information to third parties. For the avoidance of doubt, we will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.
7. Security of your personal information
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
- We hold your personal information in our database and on our on-site file servers, which are protected by both hardware and software firewalls.
- We have off-site back-up servers in secure locations.
- We password protect electronic information.
- We store papers in lockable cabinets in our offices when not being actively used.
- We ensure that our staff, volunteers, agents and contractors are aware of their privacy and data security obligations.
- We limit access to your personal information to people who have a need to know.
We have in place procedures to deal with any suspected personal data breach. We will notify the Information Commissioner’s Office (ICO) of a breach (or suspected breach) where we are required to do so. We will also contact you directly if the breach (or suspected breach) results in a high risk to your privacy.
8. Children’s information
We do not knowingly collect information on children. If we have collected personal information on a child, please contact us immediately using the details in section 15, so we can remove this information without any undue delay.
9. Your rights
In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under General Data Protection Regulation are:
- Right to Object
- Right of Access
- Right to be informed
- Right to Rectification
- Right to Erasure
- Right to Restrict Processing
- Right to Data Portability
- The right to object
You can exercise this right if
- Processing relies on legitimate interest
- Processing is for scientific or historical research
- Processing includes automated decision making and profiling
- Processing is for direct marketing purposes
- The right of access
- You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge.
- We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you.
- The right to be informed
- We are required, to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right.
- The right of rectification
- If you believe the personal data, we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made.
- The right to erasure
- If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.
- The right to restrict processing
- You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:
- Processing is unlawful
- We no longer need the personal data, but it is required for a legal process
- You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made.
- If you are exercising your right to rectification
- The right to data portability
- You can request that your personal data is transferred to another controller or processor in a machine-readable format if:
- Processing is based on consent
- Processing is by automated means (i.e. not paper based)
- Processing is necessary for the fulfilment of a contractual obligation
If you have any question about these rights, please see “additional information”, section 15 of this notice.
10. Consent
Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.
11. Failure To Provide Personal Information
Where we need to collect personal data by law or in order to process your instructions or perform a contract, we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.
12. Automated Decision Making
Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).
13. transfer your data outside the UK
In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the United Kingdom (UK).
We may share personal information to third parties outside of the UK. Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.
Where personal data is transferred outside of the UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:
- Standard Contractual Clauses with the UK Addendum
- International Data Transfer Agreement
- Binding Corporate Rules
- An exception as defined in Article 49 of the EU GDPR. For more information about transfers and safeguarding measures, please contact us using the information in section 16.
For more information about transfers and safeguarding measures, please contact us using the information in section 14.
14. Additional information
Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this privacy notice or if you wish to receive more in-depth information about any topic within it, please contact our DPO and Compliance Team via email on [email protected]
15. Right to complaint
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact us via email on: [email protected]
Alternatively, you can contact us:
By Post: Privacy, WGN, PO Box 13095, London W14 0FE.
Alternatively, you can make a complaint to the Information Commissioner’s Office:
By Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
By Website: Click Here
By Email: Click Here
By Phone: 0303 123 1113 (Local rate) or 01625 545 745 (National rate)
16. NOTICE Review and Amendments
We keep this Notice under regular review. This Notice was last updated on 24/07/2024.
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.