This privacy policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by Harmless CIC or its associated projects (The Tomorrow Project, The Hope Project and The Academy at Harmless).

It covers how we use this information, the conditions under which we may disclose it to others and how we keep it secure. Please read the following carefully to understand our policy and procedures regarding your personal data. For the purpose of the Data Protection Act 1998 and General Data Protection Regulation (EU) 2016/679 (GDPR) and any subsequent UK data protection legislation the data controller for the data we collect from you is Harmless CIC, 1 Beech Avenue, Nottingham, NG7 7LJ.


Who we are?
We are Harmless CIC and we provide support, information, training and consultancy to those who self harm and/or experience suicidal thoughts, their friends, family and professionals. Harmless CIC is a registered company limited by guarantee (no. 7150904). Our registered address can be found at the bottom of this policy. Harmless CIC also manage our other associated projects i.e. The Tomorrow Project, The Hope Project and The Academy at Harmless.


What information might we collect about you?
The information we collect about you depends on the service you access from us, for example, we will collect more information about you if you access our therapy services than if you access our training services. The information we collect is appropriate and proportionate to the service you are accessing and we will only collect information for the purposes for which they are used. We may collect and process the following data about you:

• Information that you have submitted on a referral form (or have authorised a third party to submit on your behalf);
• Information that you have provided by completing one of our internal forms e.g. a training booking form;
• Information that you have provided in order for us to offer services appropriate to you;
• Information that you disclose to us when accessing our support services;
• If you contact us about our services, we may keep a record of that correspondence and
  the information enclosed. This includes information received verbally or by email, text, our website, our shop, social media messaging, social media posting and physical letters;
• Details of transaction you carry out through our website and online shop;
• Details of your visits to our websites including, but not limited to, your IP address, your log in data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website;
• Information about your marketing preferences and communication preferences.

In some circumstances, we may collect and process data (without your consent) where there is a risk, or a potential risk, to your life. This information may be received from external parties or by actively seeking the information ourselves. This is fundamental aspect of our service and the information collected will only be used to ensure that you are safe and in order to provide information to you about our support services. The Harmless website uses Cookies. Cookies are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. It is possible to switch off cookies by setting your browser preferences.


We may also collect sensitive data
Sensitive Data refers to data that includes details about your physical or mental health, race or ethnicity, religious or philosophical beliefs, sexual orientation, trade union membership and armed forces background. We may collect and process the following sensitive data about you:

• Sensitive Information you given to our team as part of a clinical assessment. This will be
  recorded on our clinical assessment forms.
• Sensitive Information you verbally disclose to our team when accessing our support services. These will in the form clinical notes written by our team.
• Sensitive Information that you have freely disclosed to us when contacting us for support
• Sensitive Information that you have provided to us on training monitoring reports. We collect information in this way to uphold equal opportunity requirements of external funders; however, you have the right to withhold this information.

When we collect and process sensitive data, we will clearly explain this to you.


How will we use the information about you?
Personal information which you supply to us may be used in a number of ways, including:

• Internal record keeping
• To carry out our contractual obligations arising from any contracts or service agreements entered in to between you and us;
• To provide a quote or information about the services we can offer you;
• To keep you safe when there are concerns over your wellbeing or there is a risk to life;
• To seek your views or comments on the services we provide;
• To send you communications (including direct marketing) that may be of interest to you;
• To uphold contractual obligations and reporting obligations with external funders;
• To process purchases of goods or services;
• To help us improve our services;
• For internal audit purposes;
• For research purposes;
• To inform you about any changes in our services.

Who has access to your information?
We will not sell or rent your personal information to any third parties. We use external online systems such as Eventbrite, Survey Monkey and Mail Chimp to collect some of your personal data. The personal data we collect on these systems are limited and only include basic information such as name, email address, organisation and job title. When purchasing good or services, your card information is not held by us, it is collected by our third-party payment processors, who specialise in the secure online capture and processing of credit / debit card transactions. We may disclose your personal information to third parties, if:

• We have a legal obligation to do so
• We have concerns over your safety, or there is a risk to life, and have to involve external
  agencies to ensure you are safe.
• You have given consent for us to disclose your personal information to a third party.

We disclose anonymised information to third parties, if:

• We have a contractual obligation to do so
• We want to enhance the business case of Harmless CIC in order to secure future funding
• For research purposes

How do we ensure that your data is secure?
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed without authorisation. All information you provide to us is stored on our secure systems or locked away in secure files. Only employees who have the authority to collect and process your personal information will be able to access it for the purpose it is intended. We will do our best to protect your personal data; however, the transmission of information via the internet is not completely secure. As such, we cannot guarantee the security of your data transmitted over the internet and is done at your own risk. Once we receive your information, we will use our secure internal procedures and systems to prevent unauthorised access.


What are your rights?
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email us using the details at the bottom of this document. You have a number of rights in relation to your personal data, including the right to:

• Find out about how we collect and use your data;
• Obtain a copy of your person data process concerning you (and supplementary
  information)
• Request that any incorrect or inaccurate personal data is rectified
• Request to have your personal data deleted
• Request the restriction on our processing of your personal data
• Object to the processing of your personal data
• Where we rely on legitimate interest for direct marketing, you can object to receiving
  communication of this nature
• Where we rely on consent, you can withdraw your consent to us processing your personal data (which includes any direct marketing).

To exercise any of your rights, you should contact Harmless using the details at the bottom of this privacy policy.

Data Retention – How long do we keep your personal information?
We retain personal data for no more than seven years after last contact with you. We keep information for this timeframe to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting, clinical governance or reporting requirements or claims.


Legal basis for processing your data
We may process your data because:

• The process is necessary to protect your life; or
• The process is necessary to uphold our contract with you to provide services; or
• You have asked us to take specific steps before entering into a contract; or
• It is in our legitimate interest to do so.

We may also rely on your consent to process personal data and where we do this, it will be clearly explained to you at the time.


Links to other websites
Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website, so we encourage you to read the privacy policies on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.


Changes to our privacy policy
We regularly review this privacy policy and any changes will be posted on our blog and, where appropriate, notified to you by email or in person when you access our services. By using our services and corresponding with us, you are agreeing to be bound by this policy.


How to contact us
If you have any questions, comments or requests about this privacy policy, you can contact us by:

• Email: admin@harmless.org.uk
• Phone: 0115 880 0280
• Post: Harmless CIC, 1 Beech Avenue, Nottingham, NG7 7LJ