Privacy notice

Introduction

This privacy notice describes how we process your personal data to deliver our services.

These are our reasons for collecting it, what we do with it and what your rights are under the UK’s data protection laws.

Who we are

Anxiety UK is the country’s largest anxiety, stress and anxiety-based depression charity dedicated to helping anyone affected by such conditions.

Anxiety UK is a registered charity (1113403), and a company limited by guarantee (company no. 5551121).

Our registered address is: Anxiety UK, Nunes House, 447 Chester Road, Old Trafford, Manchester M16 9HA.

We are the data controller for the processing described in this notice and are registered with the Information Commissioner’s Office – reference number Z6130270.

We have appointed a Data Protection Officer who can be contacted at the above address, or via privacy@anxietyuk.org.uk.

Purpose of processing personal data

We process your personal data to:

  • Ensure that members of Anxiety UK (including partner agency beneficiaries) are able to access Anxiety UK’s therapy services , online support services, and structured courses, and to ensure that psychiatric  or safeguarding risks (when disclosed) are safely and appropriately managed;
  • Deliver our membership benefits to you, for example by providing you with copies of Anxious Times magazine;
  • To be able to respond to your enquiries, and requests for support, whether by email, text, live online chat or via our helpline;
  • To process donations and to claim Gift Aid on donations where you have agreed to allow us to do so;
  • to ensure that subscribers to our newsletter receive the requested communications (for example Friends of Anxiety UK news);
  • To process online orders made via the Anxiety UK website;
  • To keep a record of your relationship with us;
  • To administer appropriate records where you are volunteering with us;
  • To communicate with you about our activities and ways that you can support us, e.g. fundraising, volunteering, purchasing products and services, accessing new and existing services.

Unfortunately, if you do not provide this information, then we will not be able to process your donation, sign you up as a volunteer or provide the products/services you have requested.

What Personal Data do we process?

For those using the Anxiety UK website for any of the following purposes: membership subscriptions/volunteering enquiries/therapist applications/e-newsletter sign-ups/training, consultancy, charity of the year, informal partnerships, research requests, fundraiser requests, advertising and sponsorship enquiries, therapy referral requests, self-help group listings, structured courses, webinars and those making an online purchase, we will collect all/some of the following information:

  • Name / name of company;
  • Gender;
  • Contact information including email address;
  • Date of birth;
  • Demographic information such as postcode, ethnic background, sexual orientation, religion, anxiety, stress or anxiety-based depression condition;
  • Gift aid status;
  • Recordings of online events where appropriate;
  • Details of fundraising activity/event;
  • Details of research project including contact details of researcher and (supervisor);
  • Whether you wish to participate in volunteering opportunities (including media work);
  • Where you heard about Anxiety UK;
  • Details of training/consultancy/partnership/informal partnership opportunity and proposed benefit to Anxiety UK;
  • Details of amount paid /donation given;
  • Details of training undertaken including professional body membership, qualifications, DBS status, referee information (and contact details);
  • Contact details of self help group facilitators and details of self help groups;
  • For therapy referral requests only: We collect information as follows:- GP contact details, mental health history including details of medication taken and interventions undertaken including support from crisis services, suicidal ideation risk rating, treatment preference, therapy fee tier rate (along with proof of financial eligibility), outcome data (severity of depression and anxiety as measured by PHQ9 and GAD7 scales), details of visual, hearing or learning difficulties;
  • For those using the Anxiety UK helpline/infoline service, email support/live chat/text service: We collect information as follows: email address, IP address (where available), contact phone number (where available); and
  • For those using the Anxiety UK website to make any online purchase: We collect name of purchaser, billing & shipping addresses (and other contact information provided), details of products purchased, amount paid, payment method, payment details.

Payment information such as credit card details are processed exclusively by our payments processing provider and we do not have access to those data.

We do not obtain data about you from any third party without your knowledge or written consent. The above information is collected by Anxiety UK to ensure that the services provided are accessible and for monitoring and evaluation purposes.  We collect all/some of the above information depending on the product or service that you wish to access and/or your reason for making contact with us.

Special Category Data

Some types of personal data are more sensitive and require additional protections – these are known as Special Category Data and include details of your ethnicity, beliefs, health and sexuality.  If you are a member or beneficiary then it is highly likely that we will be processing special category data about you, particularly those which deal with your health.

If you share your personal experience of anxiety with us or any data about your health and wellbeing we will treat this information with the upmost confidence and always in accordance with this notice.

In the event you provide us with any special category data we will only use this information:

  • For the purposes of dealing with your enquiry, providing products or services, training, and quality monitoring or reviewing the services we provide; and
  • Where you have given us your explicit consent to us (for example, by requesting a referral to an Anxiety UK approved therapist) that you consent for your special category data to be passed on to a specific third party (i.e. when you fill in a referral form it will be passed to an Anxiety UK approved Therapist) or to be used in a certain way.

We will never pass on your details to anyone else without your permission except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or when posing a threat to themselves or others.

If you share your personal experience with us for the purpose of it being shared on Anxiety UK’s blogs or in our magazine, you can of course decide if you want to remain anonymous or not, 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 then we will, subject always to you having provided your consent to such sharing.

The lawful basis for processing your data

We can only process your personal data where we have a lawful basis to do so, which varies according to the purpose of processing and the nature of your relationship with us.

Purpose Lawful Basis
Delivering our therapy services and other benefits to members Performance of a contract with you
Delivering our therapy services and other benefits to beneficiaries Our legitimate interest in providing the services we are contracted to provide
Responding to your enquiries as a member or potential member Performance of a contract with you, or taking the steps necessary to enter into a contract with you
Responding to your enquiries as a beneficiary Our legitimate interest in providing the services we are contracted to provide
Managing our relationship with you as a volunteer Our legitimate interest in managing the volunteer relationship and maintaining appropriate records
Managing our relationship with you as a donor Our legitimate interest in managing the donor relationship and maintaining appropriate records; our legal obligation to maintain accurate records of Gift Aid
To market our services to you Your consent for us to do so
To promote our charity to you for the purposes of fundraising Your consent for us to do so
Recording of online events, webinars and other online services Our legitimate interests where it is appropriate for us to maintain a record of the online event, webinar or other service
To process online orders Performance of a contact with you, or our legitimate interest in performing a contract with your organisation
To conduct research to improve our services Our legitimate interest in improving our services

 

Where we are processing special category data this will be with your explicit consent for us to do so.  There are exceptional circumstances where we may need to process special category data if we believe that there is a risk of harm to you or others, in which case we will process because it is in your vital interests to do so.

Call recording

We record our calls, or online interactions,  to:

  • Help improve the quality of our helpline service and to ensure the information we provide is consistent and accurate;
  • To have an accurate record of all calls relating to support any client transactions that take place over the phone; and
  • Establish the facts in the event of a complaint by a client accessing the helpline service.

Our lawful basis for recording calls is that it is in our legitimate interest to do so, for the above purposes, and we will always let you know when we are recording.

Anxiety UK’s helpline service is a confidential service. However, there are certain situations where information will need to be shared even if this is against the wishes of the service user. This includes situations where:

  • a client’s life is at risk;
  • other individuals’ lives are at risk;
  • it is a requirement of a court order; or
  • it is a requirement of law

We do this under the lawful basis of being in your vital interests (or the vital interests of another person) to do so, or where we have a legal obligation to do so.

There may also be occasions where there is a public interest justification for the disclosure of information including:

  • public accountability and monitoring purposes;
  • where there is a serious risk to public health; or
  • the prevention, detection or prosecution of serious crime.

Is my information being held securely?

Call data is stored in a Windows SQL database servers which are wholly owned by Call Handling Services (Call Handling Services provide the technology platform from which our helpline services are delivered). All call data is stored in the UK. Data is never transported or stored outside the UK for any reason. All call recordings are automatically deleted after 45 days.

Who will be able to access call recordings?

Call recordings will only be accessed by manager a relevant member of the Anxiety UK staff team/Board of Trustees/other parties involved with the investigation of any complaint arising from the provision of the helpline service. All staff are trained in the GDPR.

Sharing your personal data

Anxiety UK will never sell or rent your personal information to third parties and we promise to keep your details safe and secure. We will not share your personal information with third parties for marketing purposes.

Third Party Service Providers and Associates (including Anxiety UK Approved Therapists) 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 to process donations and send you mailings). 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. Please be reassured that we will not release your information to third parties beyond the Anxiety UK network for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law or for reasons of safety, for example, by a court order or for the purposes of prevention of fraud or other crime, or to comply with our safeguarding, confidentiality and risk assessment policies and processes.

Anxiety UK will not divulge information unless there is exceptional circumstances that we become aware of and after due consideration there is overriding reason that we may need to make a disclosure to appropriate authorities (police, courts, GP, social services etc). Anxiety UK would not usually need to contact your GP. However, as your welfare is of paramount importance, if issues of safety arise – for example, we believe or if you disclose that you are a risk to yourself or to others – we may need to contact your GP or relevant professional.

When you are using our secure online payment system, your payment is processed by a third party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions.

We may from time to time create statistical and aggregated data derived from your personal data to enable Anxiety UK to share aggregated outcome data for the purpose of evaluation, promotion, marketing and research of Anxiety UK’s therapy services. Any aggregated data will be in anonymous form and will not identify you as an individual in any way.

We use a number of third party systems providers to deliver our services, some of which are cloud-based packages.  Where we are using such third party systems we ensure that we have a data processing agreement in place to protect your rights and comply with data protection laws.

Marketing – it’s your choice

You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about the vital work that we do supporting those with anxiety, stress and anxiety based depression and our range of products and services, then you can select your choices by ticking the relevant boxes on the form on which we collect your information.

We will not contact you for marketing purposes by email, phone or text message unless you have given your explicit consent. We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted. You can change your marketing preferences at any time by contacting us by email: info@anxietyuk.org.uk or telephone on 0161 226 7727.

How long do we keep your personal data for?

We aim to retain personal data for no longer than is necessary, which is a core principle of UK data protections legislation.

This section describes our data retention policy for different kinds of personal data and for the different purposes we have.  We schedule data deletion activities on an annual basis in accordance with this schedule:

Type Of Record Retention Period Storage Media Location Reason for Retention
Staff Emails Up to 7 years Electronic Essential business continuity
Support Emails 6 months Electronic To deliver continuity of service
Tax including Gift Aid 7 years Electronic To comply with HMRC regulations
Therapy data Up to 7 years Electronic/Physical To comply with BABCP, BACP guidance
Training Records (externally delivered) 7 years Electronic/Physical Essential business continuity
Volunteer Records & Data 1 year post cessation of volunteering Electronic/Physical For supply of references
FAUK (Friends of Anxiety UK) Until subscription terminated Electronic To deliver continuity of service
Employee/Personnel Records 9 months after employment ceases Electronic/Physical For references and business continuity
Anxiety UK Approved Therapist records 2 years after resigning (NB therapy relationship data 7 years) Electronic/Physcial For business continuity
Fast Therapy & Therapy Referral Data 7 years Electronic To comply with BABCP, BACP guidance
Incidents, Complaints Data (including accident data) 7 years Electronic/Physical To comply with Charity Commission guidance
Membership forms 1 year Physical Essential business continuity
Membership info 1 year after end of membership Electronic Essential business continuity
Proof of Postage Receipts 1 year Physical Essential business continuity
Recruitment data 6 months post application Electronic/Physical For monitoring purposes & HR compliance
Fundraisers and donors Up to 7 years Electronic/Physical To comply w. Charity Commission guidance
Calm Club Subscription 1 year Electronic Essential business continuity
Shop sales records 1 year from purchase Electronic Essential business continuity

How we keep your personal data secure

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.

The following key measures help keep us keep your personal data secure:

  • Data collected via our website are all encrypted in transit
  • Where possible, suitable encryption is used for data at rest
  • We use multi-factor authentication where available
  • We conduct regular security assessments and penetration testing
  • We assess the security practices of our suppliers and partners
  • We use encrypted email services where appropriate
  • We password protect sensitive documents
  • We limit access to personal data to only those members of staff who need it
  • All members of staff have confidentiality clauses in their contracts of employment
  • We provide regular security training for our staff, volunteers and associates
  • We ensure that any paper files are kept in locked cabinets
  • Our premises are protected by CCTV

How can you help keep your personal data secure?

If you are using our online services please keep you password confidential and do not share it with anyone else.  We recommend that you follow the latest online security advice from the National Cyber Security Centre (NCSC) which you can access here.

Cookies

A cookie is a small file, installed on your device, which helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Session cookies are removed when you finish browsing and close your browser.

We always ask for your consent before installing any non-essential cookies on your device. These are the cookies we use:

Cookie Name Cookie Category Description Duration
wordpress_ 2 WordPress cookie for a logged in user. session
wordpress_logged_in_ 2 WordPress cookie for a logged in user session
wordpress_test_ 2 WordPress cookie for a logged in user session
wordpress_test_cookie 2 WordPress test cookie session
wp-settings- 1 WordPress also sets a few wp-settings-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface. 1 year
wp-settings-time- 2 WordPress also sets a few wp-settings-{time}-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface. 1 year
PHPSESSID 1 To identify your unique session on the website session
SESS 1 To ensure that you are recognised when you move from page to page within the site and that any information you have entered is remembered. session

Links to other websites

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy notice applicable to the website in question.

Children under 18

We are concerned to protect the privacy of children aged 17 or under. If you are aged 17 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.

International transfers of personal data

We primarily process data in the UK:  our website is hosted in the UK, and our Microsoft Office 365 environment is also hosted in the UK.

However we do use a number of cloud bases tools which are based outside the UK, including the USA.

We ensure that we have a lawful basis for such international transfers which most often means that we have Standard Contractual Clauses (SCCs) in place with each provider.  These SCCs are mandated by the Information Commissioner’s Office (ICO) and aim to safeguard your rights when your personal data are transferred to any nation which lacks an agreement to uphold UK resident’s data protection rights by default.

Your Rights

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data.  This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request and there may be some circumstances where Anxiety UK is allowed to withhold information from you.

Please contact us using the details in “Who we are” to make any request in relation to your rights under data protection law.

If you have a complaint

If you would like to lodge a complaint with us regarding the processing of your personal data then please contact us using the above details (see “Who we are”).

You also have the right to complain to the Information Commissioner’s Office (ICO).  You can contact the ICO on their helpline 0303 123 1113 or online at www.ico.org.uk.  If you should contact the ICO they will normally ask you to contact us first.

Review of this privacy notice

We keep this privacy notice under regular review. This privacy notice was last updated in November 2020.

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