- Introduction and who we are
- Our privacy principles
- How we collect information about you
- Information we collect and why we use it
- Legal basis for using your information
- Using personal information
- Sensitive personal information
- Disclosing personal information
- International data transfers
- Retaining personal information
- Security of personal information
- Amendments to the policy
- Your rights
- Our details
1. Introduction and who we are
The Independent Mental Health Network (IMHN) is a registered charity in England (no.1171423) Registered office: IMHN, c/o Glenn Townsend, NHS South West, Marlborough Street, Bristol BS1 3NX
Here at IMHN, we are committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner.
We are a “data controller” 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”). This means that we are responsible for, and control the processing of, your personal information.
This policy explains how IMHN collects, uses and shares personal data, and your rights in relation to the personal data we hold. This is central to our values as an organisation. We want you to feel confident about how any personal information you share will be looked after or used.
If you are not satisfied with how we are processing your personal data, you can raise a concern with the Information Commissioner (ico.org.uk).
2. Our privacy principles
You can be confident that:
- We only use personal information in the ways we need to and that is expected of us.
- We will only use your personal information if you have previously given us consent to do so.
- We will keep you up to date with our work, current developments, useful resources and news from our wider membership.
- We will make it easy for you to tell us how you want us to communicate with you, including how to opt out from future communications.
- We will never release your information to organisations outside of IMHN for marketing purposes.
- We will respect all requests for anonymity when dealing with sensitive subjects and people who are at risk.
- We take all reasonable care to safeguard your personal information through security policies and secure business processes.
- We will always provide easy ways for you to contact us.
3. How we collect information about you
Everything we do, we do to ensure that we can help people experiencing a mental health problem have a voice in ensuring they get access to adequate support or have a route to raise concerns if they don’t get the experience they feel they deserve.
We want to make sure you receive the communications that are most relevant to you, be it through visiting our website or receiving emails, post or phone calls. We want to make sure you receive the best attention when you book one of our events, become a member or make a donation.
We collect information from you in the following ways:
When you interact with us directly: This could be if you ask us about our activities, register with us for training or an event, make a donation to us, ask a question about mental health, purchase something, apply for a job or volunteering opportunity or otherwise provide us with your personal information. This includes when you phone us, visit our website, or get in touch through the post, or in person.
When you interact with us through partners or suppliers working on our behalf: This could be if you access a service that is delivered through a trusted organisation working on our behalf and always under our instruction.
When you interact with us through third parties: This could be if you provide a donation through a third party such as BT MyDonate or one of the other third parties that we work with and provide your consent for your personal information to be shared with us.
When you visit our website: We gather general information which might include which pages you visit most often and which services, events or information is of most interest to you. We may also track which pages you visit when you click on links in emails from us. We also use “cookies” to help our site run effectively. There are more details below – see ‘Cookies’.
We use this information to personalise the way our website is presented when you visit to make improvements and to ensure we provide the best service and experience for you. Wherever possible we use anonymous information which does not identify individual visitors to our website.
4. Information we collect and why we use it
We may collect, store and use the following kinds of personal information that you will have given us this information whilst making a donation, registering for an event, placing an order on our website or any of the other ways to interact with us:
- Date of birth
- Membership status of IMHN
- Contact details:
- Telephone number
- Email address
- Postal address
- Other demographic information for equalities monitoring only (e.g. gender, ethnicity, sexuality);
- Credit/debit card details if we need to make a payment to you or if you make a donation or a purchase;
- Your personal health and social experiences for projects, research and consultations; however, you can decide if you want to remain anonymous;
- Your opinion and feedback in relation to any surveys or questionnaires issued by IMHN that you complete, such as feedback on our charitable activities and events; and
- Any other personal information you choose to send us.
We also gather general information about the use of our websites, such as which pages users visit most, and which services, events or facilities are of most interest.
We may also track which pages users visit when they click on links in IMHN ebulletins. This information may be used to make improvements to our website. Wherever possible we use aggregated or anonymous information which does not identify individual visitors to our websites.
We may collect personal information from you when you:
- Register as an IMHN member;
- Apply for a paid or unpaid role within IMHN, for the processing of your application;
- Donate to us;
- Order materials or training from us;
- Participate in a project or programme facilitated by us;
- Complete a survey or questionnaire;
- Contact us or become involved with us in another way.
5. Legal basis for using your information
In some cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a contract with you (for example, because you have placed an order on our website).
However, 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 IMHN to process your information to help us to achieve our vision of ensuring that everyone experiencing a Mental Health problem gets both support and respect.
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, conducting research to better understand who our supporters are, improving our services, for our legal purposes (for example, dealing with complaints and claims), or for complying with guidance from the Charity Commission.
6. Using personal information
Personal information submitted to us by email or through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
We may use your personal information to:
- Keep you informed about our activities and services through directed communications or newsletter (you can inform us at any time if you no longer require communications).
- Process and respond to requests, enquiries and complaints that we receive from you.
- Provide services or support requested by you and any related communications.
- Analyse the personal information we collect so we can better understand our members and supporters, their preferences, needs and important trends.
- Administer our website and activities.
- To process your donations or other payments, to claim Gift Aid on your donations and verify any financial transactions.
- To update you with important administrative messages about your donation, an event or services or goods you have requested.
- To comply with the Charities (Protection and Social Investment) Act 2016 and follow the recommendations of the official regulator of charities, the Charity Commission, which require us to identify and verify the identity of supporters who make major gifts so we can assess any risks associated with accepting their donations.
- To keep a record of your relationship with us.
- Where you volunteer with us, to administer the volunteering arrangement.
- Send statements, invoices and payment reminders to you, and collect payments from you.
- Update and maintain our records or for auditing purposes.
- Keep our website secure and prevent fraud.
- Provide third parties with statistical information about our members (but those third parties will not be able to identify any individual from that information);
- Meet any statutory or regulatory compliance.
All the personal data you provide is held on a central cloud database system and maintained by UK staff. All systems are password protected and no third parties have access to your personal data. Exceptions to this will only be in circumstances where the law allows them to do so.
We will not supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
We have data protection procedures in place to oversee the effective and secure processing of your personal data.
All our website financial transactions are handled through our payment services providers, (GoCardless and Xero). We will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our website, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
7. Sensitive personal information
You can of course decide if you want to remain anonymous, if you are happy to share your personal details with staff members or if you would like us to share your story with the media or other parties as part of our work telling people’s personal stories about mental health (for example, on our blog).
A special note about the Sensitive personal information we hold
Data Protection Law recognises that some categories of personal information are more sensitive. Sensitive personal information can include information about a person’s health, race, ethnic origin, political opinions, sex life, sexual orientation or religious beliefs.
If you contact us at IMHN you may choose to provide details of a sensitive nature.
We will only use this information:
- For the purposes of dealing with your enquiry, training, and quality monitoring or evaluating the services we provide.
- We will not pass on your details to anyone else without your express permission except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or posing a threat to others or children contacting us and sharing serious issues such as physical abuse or exploitation.
- Where you have given us your express consent or otherwise clearly indicated to us that you are happy for us to share your story, then we may publish it on our blog or in other media.
8. Disclosing personal information
The personal information we collect about you will mainly be used by our staff (and volunteers) at IMHN so that they can support you.
We will never sell or share your personal information with organisations so that they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity.
We will only disclose your personal information:
- If required to do so by law;
- In connection with any ongoing or prospective legal proceedings;
- In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
9. International data transfers
IMHN does not operate in any areas that do not have data protection laws equivalent to those in force in the European Economic Area (EEA).
Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
10. Retaining personal information
This section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain documents (including electronic documents) containing personal data:
- That we are required to do so by law;
- If we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
- In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
11. Security of personal information
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. Offline personal information is kept securely in our database and locked filing cabinets / premises.
We protect your personal information by:
- Ensuring that all electronic financial transactions entered into through our website will be protected by encryption technology;
- Storing all personal information you provide on our secure (password and firewall protected) servers;
- Having secure payment processing partners for any debit or credit card transactions.
The transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
Our website includes hyperlinks to, and details of, third party websites. Please be aware that this privacy statement does not cover the information practices of other websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
12. Amendments to the policy
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.
13. Your rights
You have various rights in respect of the personal information we hold about you – these are set out in more detail below:
- Access to your personal information: You have the right to request access to a copy 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, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge. Please make all requests for access in writing and provide us with evidence of your identity.
- 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.
- No automated-decision making: Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law. You also have certain rights to challenge decisions made about you. We do not currently carry out any automated decision-making.
Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.
You can find out more about your rights under data protection legislation at ico.org.uk.
To update or access your personal information, contact us by:
Writing: Independent Mental Health Network (IMHN), C/o Glenn Townsend, NHS South West, Marlborough Street, Bristol BS1 3NX
Cookies let websites recognise your device, so that the sites can work, or work better, and also gather information about how you use the site. A cookie, by itself, can’t be used to identify you.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
We use the categorisation set out by the International Chamber of Commerce in their UK Cookie Guide.
We use all four categories of cookies:
- Strictly necessary cookies are essential for you to move around our website and to use its features, like our shopping basket and your account.
- Performance cookies collect anonymous information about how you use our site, like which pages are visited most. No information that identifies you is kept.
- Functionality cookies remember choices you make to improve your experience, like your text size or location. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. They are anonymous.
- Targeting or advertising cookies collect information about your browsing habits in order to make advertising relevant to you and your interests.
You can opt out of all our cookies (except the strictly necessary ones). Find out how to control and delete cookies in your browser.
Most browsers allow you to refuse to accept cookies; for example:
- Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
- Firefox (version 47) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
- Chrome (version 52), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
You can delete cookies already stored on your computer; for example:
- Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
- Firefox (version 47), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
- Chrome (version 52), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.
Deleting cookies will have a negative impact on the usability of many websites. If you choose to refuse all cookies you may not be able to use our website properly.
15. Our details
This website is owned and operated by the Independent Mental Health Network (IMHN).
We are a registered Charitable Incorporated Organisation (CIO) in England (no.1171423).
Our registered office is IMHN, C/o Glenn Townsend, NHS South West, Marlborough Street, Bristol BS1 3NX
You can contact us:
By post: using the postal address given above
By email: firstname.lastname@example.org