Privacy Notice

Privacy Notice

We take your privacy seriously and are committed to protecting your personal information.

This Privacy Notice sets out the way in which your personal information will be used and provides information on how we process the personal data of different individuals with whom we interact for the purposes of delivery of our support services.

This Privacy Notice explains:

  • Who we are
  • When we collect information
  • What information we collect
  • Special Category Data
  • What your information is used for
  • Sharing of your information
  • Lawful basis to process your data
  • Storage and security of your data
  • How long we keep your data for
  • Your rights
  • Changes to this policy
  • How to contact us to change your preferences or make a complaint

Recent updates and future changes

We have updated our policy in line with UK data protection law which includes but not be limited to the UK Data Protection Act 2018, the Data Protection, Privacy and Electronic Communications Regulation 2020, the UK GDPR and the Privacy and Electronic Communications Regulation (PECR). This notice is intended to inform you about our processing activities in accordance with the requirements of UK Data Protection Law. Our full data protection policy is available upon request.

We have made it easy for you to let us know if you would like to change the way we process, store and use your data and the details can be found in the ‘contact us’ section of this document.

We may change this Privacy Notice at any time, so please check this page regularly to ensure that you are happy with any changes that may have been made. Any significant changes will be notified to you.

This notice was last updated on 14th May 2021. You should make sure you revisit this notice in the future to understand any amendments to the way we process your data.

Who are we?

Women in Prison exists to provide support to women in the criminal justice system in prisons, in the community and through our Women's Centres.

Women in Prison is a charity registered in England and Wales under sections 67 and 69 of the Charities Act 2011 (Registration Number 1118727) and a company limited by guarantee (company number 5581944).

Our registered address is 2nd Floor, Elmfield House, 5 Stockwell Mews SW9 9GX.

“we,” “our,” “us” are references to Women in Prison.

For the purposes of UK Data Protection Law, we are the data controller in respect of the personal information which we hold about you.

When do we collect information?

When we collect data directly from you.

For example, this might include but may not be limited to:

• When you discuss your support needs with us
• When you apply to work with us.
• When you are a member of staff.
• When you work as a volunteer.
• When you visit our offices.
• When you attend an event we organise.
• When you support us as a donor.
• When you provide us with a product or service.
• When you visit our website
• Whenever you correspond with us regardless of the means.

When you are referred to us for support

We will record the information you provide to us when we discuss your support needs. We might also gather personal information about you from other agencies if you are referred to us for support.

When we support an individual, they may provide the details of their family members, intimate partners or others they are associated. We may process such data where this is necessary to support the service user.

When you visit our website

When you interact with our digital platforms, we do not automatically capture or store personal data from our visitors, but we may automatically capture other information about your visit. This is to help us better understand how you use our digital platforms to enable us to create better content and more relevant communications. This may include:

• how you have reached our digital platform and the internet protocol (IP) address you have used
• your browser type, versions and plug-ins, and your operating system
• your journey through our digital platform, including which links you click on and any searches you made, how long you stayed on a page, and other page interaction information
• which videos you have watched and for how long
• what content you like or share
• which advertisements you saw and responded to
• which pop up or push messages you might have seen and responded to
• demographic information such as geographical location and gender if available
• information collected in any forms you complete

Cookies

The Women in Prison website, in common with many other website operators, uses standard technology called 'cookies' to make your site visit an effective experience. Cookies are small pieces of information that are stored by your browser on your computer's hard drive, and they are used to record how you navigate this website on each visit. When we use non-essential cookies, we will ask for your consent.

For more details please see our Cookie Policy.

Third party links

Please note that our website and other digital platforms may contain links to third party websites/digital platforms which are provided for your convenience. Women in Prison is only responsible for the privacy practices of our own websites and digital platforms. We recommend that you refer to the Privacy Policy of each website/digital platform you visit.

What information do we collect?

We may collect, store and use the following types of information about you depending on the level and type of interaction that you have with us:

• Your name, address, phone number, mobile number, email address and your communication preferences
• Your date of birth
• Special category data which may include: records of health conditions, your sexual orientation, religious or philosophical belief and your ethnicity. It may also include private information that will help us support you.
• Details of your criminal record where this is permitted
• Relationships between you and your family or others you may be associated with
• Bank account details
• Employment details
• Information automatically gathered when you access our website (see ‘When you visit our website’ above)

Do we collect Special Category Data?

This is personal data which the UK GDPR states as being more sensitive and therefore requires more protection. Examples of special category data are information about your health condition, religious beliefs, race, ethnicity, sexual orientation, and political opinions.

We do collect special category data when we are required to do so, for example:

  • We will collect details about your health to provide us with a better understanding of your needs
  • We will collect details of relationships of family members or others you may be connected with which may require collecting details of your sexual orientation, for which we will ask for your explicit consent.

What do we use your information for?

We process and use your personal information for a number of activities:

  • To contact you and to provide you with our services.
  • To assess whether we can assist you when you are working with us.
  • Offering you additional support opportunities
  • Evaluating and improving the services we offer.
  • Understanding your relationship with us.
  • Managing your communications preferences and consents where relevant.
  • Informing you of ways you can help including asking for financial and non-financial support such as campaigning, fundraising, research projects and evaluation of our services
  • Sending you materials about fundraising, campaigning and events
  • Analysis to understand how we can improve our services, products or information as well as sending you tailored communications and displaying relevant advertisements.
  • Analysis to ensure communications are appropriate to the recipients to ensure maximum cost effectiveness
  • Prevent fraud, misuse of services or money laundering and perform due diligence where required.
  • Financial management and audit of our accounts

Do we share your personal information?

We will not sell, trade or lease your personal information to others. We may share your data where this is permitted and in accordance with the law. This might be to offer you further support or to provide you with advice and guidance.

Sharing your information for service evaluation

Local and central government agencies frequently provide the funding for our services. In order to evaluate the part of our service which are in the public interest, they may require us to provide them with research data about our services and who is using them. We will let you know if any service is being evaluated, and you can chose not to take part in the research.

Please click this link for additional information on our current service evaluation.

Others we may share your data with:

  • We may provide your personal information to third parties in connection with any sale, merger, acquisition, disposal, reorganisation or similar change in our organisational structure
  • Any other person who is authorised to act on your behalf.
  • We will also provide your personal information to third parties where there is a legal obligation to do so, for example to regulators, government departments, law enforcement authorities, tax authorities and any relevant dispute resolution body or the courts.
  • Any relevant dispute resolution body or the courts.
  • We may need to disclose your details, if required, to the police, regulatory bodies or legal advisors, to comply with our legal obligations.
  • We may share your details with our service providers who assist us with fundraising appeals on our behalf.
  • We may share your details with our third-party IT providers, who assist us in providing our systems and databases.

Sharing data outside of the EEA countries and the UK

With the exceptions shown directly below all other data that we collect from you will be stored in the UK or the European Economic Area (EEA). We will not transfer your personal data outside the EEA or the UK without ensuring there are sufficient safeguards in place equivalent to those offered by UK data protection law.

The exception to this is use of a bulk email provider. We may use a company based in the US and by using their services we do pass your data to them. We will only pass data relevant to sending you any bulk emails such as our newsletter.

Our lawful basis for processing your data

The UK GDPR states that organisations must have a lawful basis in order to process personal data. There are 6 lawful bases for processing available within the UK GDPR. They include but are not limited to;

Specific consent and explicit consent

We may ask for explicit consent to process your data as our services mean that we may need to process sensitive information about you such as information related to your health. Due to the nature of our services, we are not always able to obtain explicit consent directly from individuals we support. Therefore, where we cannot obtain explicit consent directly and third party consent may not be valid, we will process the personal data including special category data in the legitimate interest of Women in Prison with a suitable exemption to such grounds for processing. This may include use of UK GDPR article 9 clauses. You have the right to withdraw your consent or explicit consent for any purpose at any time. However, withdrawing your consent or explicit consent may affect our ability to support you.

Legal obligation

Where we must comply with a legal or regulatory obligation such as reporting to the Charity Commission, Fundraising Regulator, Information Commissioner or Gambling Commission, or process Gift Aid.

Legitimate interests

This enables us to process your data where it is in our interest to do so, providing such interests are not overridden by your interests or fundamental rights and freedoms. Our legitimate interest will frequently also be the interests of the individual identified by the data we process.

We consider our legitimate interest to include delivering our support services, administering the charity, communicating with you by video message, telephone and post and analysing data to better understand you and others who may need support.

In order to meet our charitable aims we need to undertake processing activities, this will enable us to deliver against our mission, govern our charity and support operational administration. These activities may include but are not limited to:

• Recording your communication preferences and consent, including keeping limited data to ensure we don’t contact you if you have asked us not to.
• Using the data we have collected to analyse and profile those who use the Women in Prison Services to enable us to manage the services, and to recognise and implement improvements. We do this as long as it does not override your rights and freedoms, in which case we will ask for your consent.
• Keeping records up to date and accurate through the use of third-party registers (such as National Change of Address from Royal Mail)
• Use of personal information when we are monitoring use of our website for technical information and ability to improve.
• To contact you by post or phone (live calling only, no automated messages) to let you know about ways you can support the charity.

How do we secure your data?

We ensure we employ appropriate technical measures to keep your data safe. When we use other external companies to collect or process your data on our behalf, we undertake due diligence before we agree to engage with them and our contracts will include appropriate data security controls.

How long do we keep your data for?

Generally, we will not hold your personal information for any longer than is necessary for the uses outlined above, unless we are required to keep your personal data longer to comply with the law and any contract or regulatory requirements. We maintain a record of processing activities (RoPAs) where we record the period, we will retain each type of personal data we process.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements

What are your rights?

You have certain rights under the UK Data Protection Law which can be exercised by contacting us at: 2nd Floor, Elmfield House, 5 Stockwell Mews SW9 9GX

Your rights include:

• Request access to your personal data (commonly known as a "data subject access request SARs"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. We handle SARs in accordance with the ICO’s guidance and maintain a policy on such requests.
• Rectification of inaccuracies 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:
• Request the transfer (right of portability) 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 or your explicit 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.

Further details about your rights can be found on the ICO’s website at https://ico.org.uk/

There are some exemptions to the above rights that are permitted under the data protection legislation. If you have any queries as to what these are then please get in touch.

Please note that if you choose to exercise your rights to have personal data restricted or deleted, then we may not be able to provide you with a full service.

We will need you to provide identification in order to comply with your request to exercise your rights. Once we have received your information request, and your identification, we will respond within the required timescales unless a permitted exemption applies.

You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance (using the contact details noted below).

Contact Us

If you have any questions regarding this Privacy Notice or you are unhappy with how we handle your personal information you can contact us.

Email [email protected] or write to us at Women in Prison, Elmfield House, 5 Stockwell Mews, London SW9 9GX,

If you wish to complain about our handling of your data, please go to: Information Commissioner's Office, Wycliffe House Water Lane, Wilmslow, Cheshire, SK9 5AF

For further details about how to complain about our handling of your personal data please visit the regulator’s website: https://ico.org.uk/make-a-complaint