Turning Point treats the privacy of your personal data seriously. This notice identifies for you some key information about data processing and sets out the type of data we collect from you when visiting out website, why we collect it and how we manage it. Managing data includes identifying the lawful basis for processing data, as well as how we gather, store, process, share, protect and ultimately destroy data.
Our responsibilities relating to data processing are set out the General Data Protection Regulation 2016/679 (GDPR) and Data Protection Act 2018 (“DPA”). In line with these provisions, data processing is overseen by our designated Data Protection Officer (DPO) whose principle duties are to inform, advise and monitor Turning Point’s compliance with the GDPR.
3. What information do we collect about you?
We collect information about you when you register your interest in hearing from us via email or telephone. We also collect information when you voluntarily complete customer surveys, online forms and provide feedback. If you self-refer to a service or complete our online website form then this information is collected by Turning Point and we only use this information for the purpose it is being collected for. For example, if you are interested in being referred to a service, we will only pass this information on to the service and we will not use your details for any other communications.
Turning Point is responsible for collecting all data that comes through our website forms from site visitors.
If you opt to sign up for communications from us via an email, web form or social media link, then your information may be stored by a third party supplier. When your data is collected by a third party in this way, those third parties are legally bound to process your data only for the purposes explicitly set out by Turning Point.
4. How will we use your data?
Depending on the type of data you supply and the method with which you supply this, we may use your data for different reasons.
Our lawful reasons for processing data are detailed in the table below along with the type of data. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
5. Retaining your data
The length of time we will retain your information depends on who you are and the type of information. In general we will retain the information you provide for the purposes set out in this notice for a period 8 years after the last contact with you. The circumstance where this may be different includes if you are under the age of 18 when you start receiving services from us or if you are subject to the Mental Health Act. For a full description of how long we retain data for please request our Data Retention policy.
6. How do we keep data secure?
Turning Point uses industry-standard tools, such as firewalls and Secure Socket Layers, to safeguard the confidentiality of your personally identifiable information. We make every effort to protect against the loss, misuse and alteration of the information under our control.
Most web browsers (e.g. Microsoft Explorer, Mozilla Firefox, Safari, Google Chrome, etc.) support SSL. The link between your web browser and the server is secure if your web browser displays a small padlock or key symbol somewhere in the frame, or the address bar shows a web address beginning https:// (rather than http://). Turning Point’s website is https://www.turning-point.co.uk.
We endeavour to keep all supporter data inside the European Economic Area (EEA), and ensure that any time data is transferred outside the EEA exactly the same provisions on data security and processing are applied.
7. How we will communicate with you
Turning Point takes its obligations under the Privacy and Electronic Communications Regulations seriously. For any marketing communications about our service update and campaigns, we will only contact you via email and SMS if we have your consent to do so or where soft opt-in applies.
You may also see advertising online and on some social media sites if you have followed us via these channels, or if your use of these channels suggests that you would find our campaigns relevant.
Cookies are small files that are downloaded onto your computer (or your mobile phone) from websites that you visit. Cookies contain information that allows websites to recognise that you have used the site before.
This website also uses Google Analytics Advertising Features to enable us to better understand the interests of our audience and to tailor our communications to be more relevant to you. You may see Turning Point listed in locations such as in search results or on the Google Display Network.
If you do not wish to see these adverts, you can:
All browsers allow you to control which cookies you accept and which you delete. You will usually find these settings under the ‘Preferences’ or ‘Tools’ menu of your browser. For more information about cookies, please see www.allaboutcookies.org.
9. Data Subject Rights
The following information is intended to help you understand you rights in relation to personal and sensitive data as provided by either the Data Protection Act (1998) or the General Data Protection Regulation 2016.
The right to be informed: This relates to what information we are required to provide you about data processing. This Privacy Notice and the wider Turning Point Privacy represents the way in which we inform you of this information.
Right of access: You (i.e. the data subject) have the right to access particular personal and sensitive information that we hold about you. This is known as a Subject Access Request. We shall respond promptly (usually within one month from the point of receiving the request and all necessary information from you). This provision is usually free of charge. However we retain the right to charge a reasonable fee when we believe a request is unfounded, excessive or repetitive. Further information is contained in our found in our Information Governance Policy (Personal Information Procedure).
Right to rectification: You have the right to obtain from us, without undue delay, the rectification of inaccurate or incomplete personal data that we hold concerning you.
Right to erasure: You have the right to request the deletion or removal of personal data where there is no compelling reason for its continued processing. We have the right to refuse to comply with a request for erasure and if this applies we will tell you the reason why.
Right to restrict processing: Subject to exemptions, you shall have the right to restrict processing where:
· You contest the accuracy of the information we hold and it is restricted until the accuracy is verified,
· You have objected to processing (where it is necessary for the performance of a public interest task / legitimate interest) and we are considering whether our grounds override your rights
· Processing is unlawful and you oppose erasure, requesting restriction instead,
· We no longer need the data, but you require the data to establish, exercise or defend a legal claim.
Right to Data Portability: This applies when processing is carried out in an automated way. You shall have the right to receive the personal data you have provided to us in a structured, commonly used and machine readable format. Where technically feasible, this right extends to us transmitting the data to another organisation at your request. For data portability to apply, the processing of your data must relate to information that is either i) based on your consent or ii) processed for the performance of a contract.
Right to Object: You have the right to object to processing on grounds relating to your personal circumstances. This provision applies to the processing that is undertaken for legitimate interests / the performance of a task in the public interests (includes personal profiling) and processing for purposes of scientific / historical research and statistics. In such cases we will stop processing unless we can demonstrate i) compelling legitimate grounds which override your interests, rights and freedoms ii) the processing is for the establishment , exercise or defence of legal claims. This right extends to processing for the purposes of direct marketing (including profiling) which must be stopped outright.
Right not to be subject to decisions based solely on automated processing: We do not carry out any automated processing which may lead to automated decision making based on your personal data.
Information accuracy: We take all reasonable steps to ensure the accuracy of the personal/ sensitive data that we hold and provide
Invoking your rights: If you would like to invoke any of these rights, please write to our
Data Protection Officer, Turning Point, The Exchange, 3 New York Street, Manchester, M1 4HN Email DPO@turning-point.co.uk