Privacy Policy

Confidentiality and privacy are essential to our work. We want everyone who uses our services, or who supports our work by volunteering or through donations to feel confident that any personal information they share with us will be looked after properly.

This Privacy Policy sets out how we collect, use and protect your personal information (this means any information that identifies or could identify you).

This Privacy Policy may change in accordance with newly introduced legislation, so please remember to check back from time to time. This version has been updated to take into consideration the new EU General Data Protection Regulation 2016/679.

Contents

1. Who we are
2. How we collect information about you
3. Information we collect and why we use it
4. Legal basis for using your information
5. Marketing
6. Sharing your Information
7. Keeping your information safe
8. How long we hold your information for
9. Cookies
10. Your rights

1. Who we are

The Baobab Centre is committed to protecting your personal information and making every effort to ensure that your personal information is protected and used in a fair, open and transparent manner.

The Baobab Centre is 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.

For further information about our data protection practices, please contact our Data Protection Officer by:

• Writing to the Baobab Centre for Young Survivors in Exile, 6-9 Manor Gardens, London N7 6LA
• Calling us on 0207 263 1301
• Emailing to info@baobabsurvivors.org

2. How we collect information about you

Everything we do is focused on our charitable aims of providing psychotherapeutic and practical support to children, adolescents and young adults who are refugees or seeking asylum in the UK.  

We want to make sure you receive 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 make a referral, start attending the Baobab Centre for treatment and support, register for an event or make a donation.

We collect information from those who come into contact with our organisation in the following ways:

• When you interact with us directly: This could be if you are referred to our service, you make a referral to our service, ask us about our services, register with us for training or an event, make a donation to us, 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: This could be if your social worker, local mental health team, lawyer or GP has made a referral to us in discussion with you.
• When you interact with us through third parties: This could be if you provide a donation through a third party such as My Donate or 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 are visited most often and which services, events or information is of most interest to those visiting the website. We also use “cookies” to help our site run effectively. There are more details below – see ‘Cookies’. We use this information to make improvements and ensure we provide the best service and experience for you when visiting the site.

3. Information we collect and why we use it

3.1 Personal Information: Supporters, Volunteers and Participants in Events

Personal information we collect includes details such as your name, email address, postal address, telephone number and credit/debit card details if you are making a donation, or your bank details and National Insurance Number if you are working with us, and your date of birth if you are volunteering with us. It also includes the communications you exchange with us when you call, email or write to us. You will have given us this information whilst making a donation, registering for an event, placing an order on our website, making an application to become a volunteer, or in any number of other ways used to interact with us.

We will mainly use this information:

• To process your donations or other payments, to claim Gift Aid on your donations and verify any financial transactions.
• To provide the services or goods that you have requested.
• 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 communicate with you and manage our relationship with you.
• Where you volunteer with us, to administer the volunteering arrangement and comply with our safeguarding duties.
• Where you work with us to process payments, make PAYE and pension payments on your behalf and comply with our safeguarding duties and our duties as an employer.
• Where you have requested training or registered for an event to ensure that we provide training or other events that meet your needs.
• Your posts and messages on social media when you interact on social media platforms with us such as Instagram or Facebook.

If you do not provide this information, we will not be able to process your donation, sign you up for a particular event or provide goods and services you have requested.

We may also use your personal information:

• To invite you to participate in surveys or research as part of our monitoring and evaluation to improve our service.

3.2 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 have provided us with Sensitive Personal Information, we treat that information with utmost care and confidentiality and always in accordance with this Privacy Policy.

If you provide us with sensitive personal information, we will only use this information:

• For the specific purposes of dealing with your enquiry, treatment, 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 very exceptional circumstances, for example if we feel that you are in danger or someone else is in danger or when required by law. Examples of this might include anyone reporting serious self-harm or posing a threat to others or children, or 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 information in order to support you in accessing or engaging with services or to provide you with practical support, then we may share the information as discussed with you.
• Only if you have given your express consent for us to share your story, then we may publish it on our blog or in other media. 

3.3 Children 

We are committed to protecting the privacy of young people and we will only ever collect and hold information on a child under 13 with explicit parental consent or the explicit consent of those with parental responsibility. We will make clear the reasons for collecting the information and how the information will be used.

4. 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.

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 the Baobab Centre to process your information to help us to achieve our aim of ensuring that everyone experiencing a Mental Health problem gets both treatment and support.

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.

Examples of where we have a legitimate interest to process your Personal information are where we contact you for our legal purposes (for example, dealing with complaints and claims), or for complying with guidance from the Charity Commission.

5. Marketing

We will only contact you about our work and how you can support the Baobab Centre by phone, text or email if you have agreed for us to contact you in this manner. You can update your choices or stop us sending you these communications at any time by contacting info@baobabsurvivors.org. Or you can unsubscribe from our mailing list at any time by clicking on the link at the bottom of our emails. We use Mailchimp as our mailing list platform. By subscribing, you acknowledge that your information will be transferred to Mailchimp for processing. Learn more about Mailchimp’s privacy practices here.

We may send out general mailshots to all addresses in a local area about our work and how individuals can support Baobab which does not involve the processing of personal data. In doing so we ensure that we comply with the relevant guidelines and codes on marketing and advertising.

6. Sharing your Information

The personal information we collect about you will be used by our staff (and volunteers) at Baobab so that we can engage with you as required.

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 activity.

Baobab may however share your information with our trusted partners and suppliers who work with us on or on our behalf to deliver our services, but processing of this information is always carried out under our instruction. We make sure that they store the data securely, delete it when they no longer need it and never use it for any other purposes. Some examples of where we may share your information are with our fulfilment partners who help to create and send information to you to reduce our costs, with our partners who help us to process donations and claim Gift Aid and our partners who help us to manage our social media accounts.

We enter into contracts with these service providers that require them to comply with Data Protection Laws and ensure that they have appropriate controls in place to secure your information.

Legal disclosure

We may disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to enforce our conditions of sale and other agreements.

7. Keeping your information safe

We take looking after your information very seriously. We’ve implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on- and off-line, from improper access, use, alteration, destruction and loss.

The Baobab website may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites. This privacy statement does not cover the information practices of those websites or advertisers.

8. How long we hold your information for

We keep your information only for as long as is reasonable and necessary for the relevant activity.  The time we also hold onto records takes account of our legal and accounting obligations.  We are required to keep details of financial transactions, including donations, for seven years to meet HMRC requirements.

9. Use of cookies on our website

What is a cookie?

Our website uses cookies, as almost all websites do, to help provide you with the best experience we can.

• A cookie is a small text file that a website transfers to the browser on your computer’s hard disk so that the site can remember who you are.
• A cookie will typically contain the name of the website from which the cookie has come, the “lifetime” of the cookie, and a value, usually a randomly generated unique number.
• We cannot identify you personally by using a cookie. Cookies store no personal data and are not used to gather personal information.

Cookies set by baobabsurvivors.org

Name	Purpose	Expires	Purpose
Cookie preference	cookie_notice_accepted	1 year	This cookie is used to remember a user’s choice about cookies
Google Analytics	ga _ga	2 years	These cookies are used to collect information about how visitors use our website. We do this to help make sure the site is meeting the needs of its users and to help us make improvements.

Anonymous Visitor Statistics Cookies

We use cookies to compile visitor statistics such as how many people have visited our website, what type of technology they are using (e.g. Mac or Windows which helps to identify when our site isn’t working as it should for particular technologies), how long they spend on the site, what page they look at, etc. This helps us to continuously improve our website. These so called “analytics” programs also tell us if, on an anonymous basis, how people reached this site (e.g. from a search engine) and whether they have been here before helping us to better understand our audience.

Third party cookies

Our site, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube video. Some third party services embedded within this website set their own cookies. These are known as third party cookies because they are not set by our website. We have no control over the cookies that are set by third party services. Disabling these cookies will likely break the functions offered by these third parties.

Granting us permission to use cookies

If you accept cookies via our cookie notice banner (and the settings on your browser or software that you are using to view this website are adjusted to accept cookies) we take this, and your continued use of our website, to mean that you are fine with this. Should you wish to remove or not use cookies from our site you can learn how to do this below. You can learn more about all the cookies set by our website in the table above.

Turning cookies off

You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Learn how here. It may be that you concerns around cookies relate to so called “spyware”. Rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive. Learn more about managing cookies with antispyware software.

10. Your rights

You have various rights in respect of the personal information we hold about you – these are set out in more detail below.  

If you wish to exercise any of these rights or make a complaint, you can do so by contacting our Operations Manager at Baobab Centre, 6-9 Manor Gardens, London N6 7LA, info@baobabsurvivors.org and by phone on 020 7263 1301.  You can also make a complaint to the data protection supervisory authority, the Information Commissioner’s Office, https://ico.org.uk:

• Consent: If you have given us your consent to use personal information, you can withdraw your consent at any time.
• The right to be informed – primarily through this policy – about the collection and use of your personal data – including the purposes for processing personal data, retention periods for that personal data, and who it will be shared with.
• Access to your personal information: You have the right to request access to a copy of the personal information that we hold about you. 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 and we must respond within one month of receipt of the request.
• 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.
• 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.
• 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.
• 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.
• Rights related to automated-decision making: the Baobab Centre does not use automated decision-making. However, you may wish to know that 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 your consent.  In such circumstances, it is necessary for a contract to be drawn up between you and the organisation carrying out the decision making, 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.