Inspire Group Privacy Notice
(Updated March 2020)
At Inspire Wellbeing, we are committed to protecting and respecting your privacy.
This privacy notice describes how Inspire manages your personal information in accordance with the law and your rights, specifically with regards to Data Protection Act 2018 and General Data Protection Regulation legislation.
It does not cover every situation so please read notices on forms, web pages or other points where you give us information about yourself. These will describe specifically how we use your information, the reasons and legal basis for holding it as well as your rights.
We understand that privacy and the security of your personal information is extremely important. Because of that, this notice sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. This gives effect to our commitment to protect your personal information. We may update this statement from time to time so please check our website for the most recent version.
This notice tells you:
- Who we are
- What type of information we hold
- How your information is used
- The legal basis we rely on to process personal information
- Who has access to your information
- How long do we keep your information for
- How can you access and update your information
- Our Data Protection Officer Contact Details
Who we are
Inspire Wellbeing provides a wide range of services, including Mental Health services, Learning Disability services, Addiction services, Counselling, and Training with work across all of Ireland. The term “Inspire Wellbeing” is used to cover all companies within the Inspire Wellbeing group including:
- Inspire, Inspire Mental Health and Inspire Community Resilience are operating names of Inspire Wellbeing, a company limited by guarantee Company Number: NI025428/Charity Number103470.
- Inspire Disability Services is a company limited by guarantee, Company Number NI073751/Charity Number 101899.
- Inspire Workplaces, Inspire Students and Inspire Knowledge and Leadership are operating names of Carecall (NI) Limited Company Number NI038960/VAT Registration Number: 179 1484 72.
What type of information is collected from you?
The personal information we collect might include your name, address, email address, sensitive information regarding your mental or physical wellbeing, third parties including family members or medical practitioners, bank details for contractors and key personnel within those contracts. It also might include CCTV footage or phone recordings. This is not an exhaustive list and what personal information we collect is dependent upon the service you are engaging with.
We may collect your personal information in a number of ways. For example, when you:
- Use our services
- Visit any of our website(s)
- Engage with us on social media
- Download or install one of our apps
- Contact us by any means with queries, complaints etc.
- Book to attend an event
- Choose to complete any surveys we send you
- Comment on or review our services
- Have had your information passed to us by a third party
- Attend our events where we may take photographs
How is your information used?
We may use your information to:
- Enable Inspire Wellbeing to provide a service to you
- Seek your views or comments on the services we provide
- Notify you of changes to our services
- Promote our services or for fundraising
- To carry out our obligations arising from any contracts entered into by you and us
We understand that you trust us with your personal information and we are committed to ensuring you can manage the privacy and security of your personal information yourself.
The legal basis we rely on to process personal information
In order to comply with data protection legislation, we need to keep a register of the full range of personal information that we hold and on this register we also must state the legal basis which allows us to hold this information. The law on information protection sets out a number of different bases on which an organisation may collect and process your personal information, including:
In specific situations, we can collect and process your information with your explicit consent.
- Performance of a contract
In certain circumstances, we need your personal information in order to perform a contract that we have entered into with you.
- Legal Obligation
If the law requires us to, we may need to collect and process your information. We may also need to pass your information onto a third party if required by law.
- Legitimate interest
In specific situations, we require your information to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and delivering our services.
Who has access to your information?
Within Inspire Wellbeing, access is only available to those who need this information in order to provide a service to you or to fulfil the contract that we have with you. Access may be required by support departments within Inspire Wellbeing, such as ICT, Administration and Finance, as well as those involved in the direct delivery of services to you.
Third Party Providers/Partners that we work in association with
Third Party Service Providers 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:
- ICT support providers
- The media – when arranging for you to speak to media outlets (with your consent)
- Any member of our group of companies (this means the Inspire Group and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
- Our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- Associate Counsellors who are contracted by our Professional Services to deliver a safe and effective clinical counselling service
- Associate Clinical Advisors who are contracted by our Professional Services insofar as to deliver a safe and effective clinical counselling service, assessing and managing risk, allocating services, supervision, clinical oversight and quality assurance.
In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
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 and not to use it for their own direct marketing purposes.
Please be reassured that we will not release your information to third parties beyond Inspire Wellbeing, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
How long do we keep your information for?
As long as necessary for the purpose/s it was collected for or for as long as we are legally required to.
This will vary depending on the type of information, legal requirements or other justifications permitted by Data Protection law. We have a Retention & Disposal Procedure which sets out retention periods. If you opt-out from fundraising communications we keep your information only to ensure we don’t inadvertently contact you.
We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations. We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.
How you can access and update your information
The accuracy of your information is important to us. If any of your information that we hold is inaccurate or out of date, please notify us.
You have the right to ask for a copy of the information that Inspire Wellbeing hold about you. This is known as a Subject Access Request and we have 30 calendar days to comply with such a request. There is no charge.
You have the right to:
- Ask us not to process your personal information for fundraising or our marketing of Inspire. If you wish to do this, please contact the Data Protection Officer.
- See copies of information held about you – Subject Access Request (SAR). Please send your request in writing to the Data Protection Officer. Please include copies of up-to-date photographic ID. We will acknowledge as soon as possible and provide information not longer than one month from receipt
- Ask us to amend, update or delete your information in some circumstances or withdraw consent to our processing of your information for particular purposes by contacting the Data Protection Officer.
If you are unhappy with the way we are managing your personal information please contact our Data Protection Officer. If you are still unhappy you can register a complaint to the Information Commissioner’s Office (NI) or the Data Protection Commissioner (ROI).
The Information Commissioner’s Office (UK) is Inspire’s nominated commissioning authority. If you are in the Republic of Ireland you may contact the Data Protection Commissioner (ROI)
Information Commissioner’s Office (UK)
Water Lane Wilmslow
Cheshire SK9 5AF
Data Protection Commissioner
Portarlington R32 AP23
Transfers of personal data to Third Countries
Transferring information abroad – Your personal information may be transferred to, and stored and processed outside the European Economic Area (“EEA”). If this is the case we will ensure that an equivalent level of protection for personal data standards of information security are maintained.
This applies to specific categories of Data Subjects including but not limited to:
- Sole traders and other suppliers to both Inspire Wellbeing CLG and EAP Consultants,
- HSE and TUSLA service users
Security precautions in place to protect the loss, misuse or alteration of your information
When you give us personal information, we take steps to ensure that it’s treated securely. Any confidential and sensitive information is securely filed and we apply software to our ICT to prevent unauthorised access to your information. We have appropriate procedures in place for data security and management of records. All of our staff are trained in data protection and GDPR.
We also monitor compliance with data protection procedures through our internal audit programme.
Should you have any queries regarding any aspect of Data Protection within Inspire Wellbeing, please contact:
Peter Hillier – Data Protection Officer
10 – 20 Lombard Street
Tel: 028 9032 8474 (From NI)
Tel: 0044 28 9032 8474 (From ROI)