Privacy Policy

Lifespace Trust
("We") are committed to protecting and respecting your privacy.This policy (together any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1.  Definitions

Data controller - A controller determines the purposes and means of processing personal data. 
Data processor - A processor is responsible for processing personal data on behalf of a controller. 
Data subject – Natural person 

Categories of data:

Personal data and special categories of personal data Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies. 

Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs. 

Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 

Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we? 
Lifespace Trust is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Lifespace Trust, Tyler House, Tyler Street, Stratford-upon-Avon, Warwickshire CV37 6TY. For all data matters contact our data representative using the details above.

3. The purpose(s) of processing your personal data
We use your personal data for the following purpose: To deliver safe and effective mentoring services to children and young people to help them reduce distress, build resilience and achieve more. 

4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

• Personal data (for example, your name, gender, date of birth, school/college (if applicable))
• Special categories of data (for example, information about your physical or mental health if supplied to us by you or by the person or organisation that requested mentoring for you.)

We have obtained your personal data from the mentoring request form completed by the person or organisation that requested mentoring for you and, once mentoring has started, from you during mentoring sessions. 

5. What is our legal basis for processing your personal data? 

a) Personal data (article 6 of GDPR) Our lawful basis for processing your general personal data: Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject To deliver safe and effective mentoring services to children and young people to help them reduce distress, build resilience and achieve more.   

b) Special categories of personal data (article 9 of GDPR) Our lawful basis for processing your special categories of data: Processing necessary to protect the vital interests of a data subject or another individual where the data subject is physically or legally incapable of giving consent This relates to data supplied to us by the person or organisation that requested mentoring for you prior to us agreeing to provide mentoring for you. Processing relates to personal data manifestly made public by the data subject This relates to data provided to us by you during mentoring sessions   More information on lawful processing can be found on the ICO website.

6. Sharing your personal data 
Your personal data will be treated as strictly confidential, and will be shared only with your Lifespace mentor and, if required to facilitate delivery of a safe and effective mentoring services, our small administrative team.

7. How long do we keep your personal data? 
We keep your personal data for no longer than reasonably necessary and we only retain your data either in limited form to record that you received a service from us or in more detailed form in the case of any legal claims/complaints or child protection purposes etc. 
 
8. Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data but failure to do so could result in us not offering a mentoring service to you or stopping an existing mentoring service.

9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

10.   Transfer of Data Abroad
We do not transfer personal data outside the EEA.

11. Automated Decision Making
We do not use any form of automated decision making in our business.

12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

13. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be made available through our usual communication channels (e.g. our website) and, where appropriate, communicated directly to you. 
 
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our data representative using the following contact details: Lifespace Trust, Tyler House, Tyler Street, Stratford-upon-Avon, Warwickshire CV37 6TY. If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.