PRIVACY POLICY

Walking With The Wounded (WWTW) takes the privacy of our employees, beneficiaries, supporters and volunteers very seriously.

This policy sets out our responsibilities under the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and other applicable laws in England and Wales relating to the processing and security of personal information.

Who are we?

We are Walking With The Wounded (“WWTW”, “us”, “we”, “our”). We are a registered charity in England and Wales under registration number 1153497, in Scotland under registration number SC047760, with our registered office located at Stody Hall Barns, Stody, Melton Constable, NR24 2ED.

WWTW deliver employment, mental health & care coordination in collaboration with the NHS to get those who served, and their families, whether mentally, socially or physically wounded, back on their feet and making a positive contribution once more. Why? Because those who served, deserve.

We are registered with the UK supervisory authority, the Information Commissioner’s Office in relation to our processing of Personal Data under registration number ZA127381.

Under the UK GDPR, an organisation must have a lawful basis for processing your personal data. The lawful basis for which WWTW will rely upon to process your personal data will depend on our relationship with you and how you interact with our organisation. This Privacy Policy deals with each area separately.

Service Users

If you require support from WWTW we will need to gather personal data from you. This will include contact details, details about your social situation, your service history and your mental & physical health. We need this data to provide you with a tailored service for your needs.

We store your data on a secure database.

From time to time we may need to share your data. Typically this is on an individual basis, such as sharing your data with a medical professional co-supporting your care plan. Occasionally WWTW will share data with an organisation for the purposes of evaluating the success of our services, in these circumstances data will be shared securely and limited to the data required for the evaluation.

In exceptional circumstances, we may process your personal data to comply with the law. This could include, but is not restricted to, anyone contacting the charity to report abuse; serious self-harm; anyone expressing an intention to harm someone else or any matter regarding national security.

We are relying on the following lawful bases to process data for service users:

Public task

WWTW holds several contracts with the NHS to deliver veteran services under Op Courage. This means that service users engage initially with the NHS for support, and the NHS allocate a WWTW caseworker to those individuals.

Where WWTW staff are under an NHS contract, our grounds for processing data for the clients that are referred to us, falls under Article 6(1)(e) UK GDPR - where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested, and covers WWTW workers under NHS contracts to exercising official authority on behalf of the NHS.

For special category data, we rely on Article 9(2)(h) UK GDPR; that data is processed for the purposes of the provision of social care pursuant to contract with a health professional. Under the list of roles covered by this clause, we would fall under ‘social workers’.

Legitimate Interests

For service users who are not under an NHS contract, WWTW relies on Article 6(1)(f) UK GDPR for the processing of your personal data. This is where we consider that the processing is necessary for the purposes of the legitimate interests pursued by us as the Controller, and we are not harming any of your rights and interests by carrying out such processing.

For special category data, we rely on Article 9(2)(a) UK GDPR; where data is processed with your explicit consent.

After we have received your referral form, we will issue you a simple consent form explaining what you agree to and what you can expect from us.

You agree that:

• You will provide, to the best of your knowledge, your accurate personal information for us to provide tailored assistance to you
• Your caseworker or other staff at WWTW, may share the personal information provided with other organisations as is necessary to provide the required assistance on your case. This may include care providers or agencies
• Your personal information may be shared with the Ministry of Defence and its agencies, for the purpose of verifying Service in the Armed Forces
• You may be asked to share some of your 'sensitive personal data' also known as Special Category Data, relating to physical or mental health, ethnic origin, genetic/biometric identifiers, religious or political views, trade union membership, sexual orientation and any criminal convictions or offences
• WWTW may share some of your data with government bodies and research organisations for the purposes of evaluating the service to continuously improve how we deliver to veterans now and in the future
• WWTW can share information relating to your support via email and text messages to the contact details that you have provided above. You understand information received may be personal and confidential and is transmitted over a public network and as such may not be secure
• In exceptional circumstances, WWTW may be required to pass on your data and that we may be required by law to do so. This could include, but is not restricted to, anyone contacting the charity to report abuse; serious self-harm; anyone expressing an intention to harm someone else or any matter regarding national security

We, Walking With The Wounded, agree that we will:

• Only use the personal information provided to deliver the best possible support service to you and your household OR to review and monitor our support services so that we can improve those services.
• Only collect the information/data that is actually needed
• Only share your personal information/data with those who need to see it to do their jobs
• Only retain your personal information/data for a reasonable period of time (WWTW store data for 7 years from the end of your provision of support – at this point identifiable data is anonymised)
• Protect your information/data from unauthorised or accidental disclosure
• Provide you with a copy of your personal information/data on request
• Correct any inaccurate information/data as soon as possible

Fundraisers and Supporters

If you donate to WWTW, sign up to an event or complete a form on the website, we may gather your data. This may include your name, postal address, email address and telephone number, date of birth, and payment card details.

As you sign up to WWTW or a WWTW activity, we obtain your explicit consent to process data to fulfil the activity you have signed up for or expressed an interest in. Consent is the lawful basis under Article 6(1)(a) UK GDPR. Service users can consent to receive marking emails too, this is an additional opt in and separate to the provision of support.

WWTW will not use your personal information/data for marketing purposes if you have indicated that you do not wish to be contacted. You can change your preferences at any time by contacting us, or by unsubscribing via our website (contact details at the end of this policy).

We need your data to:

• Provide you with services, products or information you have asked for
• Process orders you have submitted
• Process job applications
• Keep a record of your relationship with us
• Deal with your enquiries, requests and comments
• Provide information about our programmes and services
• Advise on our fundraising activities, appeals and campaigns
• Contact you to promote our services and activities
• Profile usage so we can offer our supporters products that are relevant to them

We may need to share your information/data with our partners and associated stakeholders for the purposes described above.

You should also know that we gather general information/data about the use of our website such as which pages are visited the most, and which services, events or facilities are of most interest. We may use this information/data to make improvements to our website and ensure it delivers the best service for our users. Wherever possible, information/data is anonymized to prevent the identification of individual visitors to our website. Please refer to cookie usage for further information.

From time to time, where you have not provided consent, WWTW will use the Article 6(1)(f) UK GDPR lawful basis 'legitimate interests'. This means that we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests.

Before doing this, we will carefully consider and balance any potential impact on you and your rights. Some typical examples of when we might use the approach are for preventing fraud, direct marketing, maintaining the security of our system, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns and fundraising.

Exercising your data protection rights

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

How is your personal information/data protected?

We use a secure server when you make a donation or payment via our website and take appropriate measures to ensure that the personal information/data disclosed to us is kept secure, accurate and up to date. We will ensure that your personal information/data is kept only for as long as is necessary for the purposes which it was collected and is securely destroyed in accordance with our Records Management policy.

Do we share personal information/data with external parties?

We may pass on your information to our third-party service providers, suppliers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process donations and send you mailings). However, when we use third parties, we disclose only the personal information that is necessary to deliver the services. Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes unless 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.

International transfers

Your Personal Data may be processed outside of the UK. This is because the organisations we use to provide our service to you are based outside the UK.

We have taken appropriate steps to ensure that the Personal Data processed outside the UK has an essentially equivalent level of protection to that guaranteed in the UK. We do this by ensuring that:

• Your Personal Data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation) or
• We enter into an International Data Transfer Agreement (“IDTA”) with the receiving organization and adopt supplementary measures, where necessary. (A copy of the IDTA can be found here international-data-transfer-agreement.pdf (ico.org.uk))

Cookie usage

A cookie is a small piece of information sent by a web server (e.g. website) to a web browser (an individual), which enables the server to collect information from the browser.

Cookies can help web browsers (individuals) have a better experience as they allow web servers (websites) to understand which areas are of particular interest. Our cookies are not used to identify you personally. Cookies collect anonymous information on the pages visited. We do not use advertising cookies. Most browsers allow you to turn off cookies, however by turning cookies off you may restrict your use of our website.

When you first visit our website you are given the opportunity to opt-out of cookies that are not strictly necessary but please be aware that this may restrict the use of our website.

Trademarks and copyright

The WWTW website contains material which is protected by copyright and/or other intellectual property rights. All copyright and intellectual property rights including names, images and logos are owned by WWTW unless otherwise stated. All rights are reserved.

You are responsible for complying with all applicable copyright laws. WWTW permits you to make copies of information on the WWTW website as necessary and you may take a print of such information for your personal as is reasonable for private purposes. All other uses are prohibited. Nothing in these terms shall be construed as conferring any right to use any trademark logo patent right or copyright of WWTW.

The WWTW website may contain links to other websites/organisations that are beyond our control and not covered by this Privacy Policy. WWTW is not responsible for the privacy practices of these other websites and you are requested to read their privacy policies carefully.

Your choices

You have a choice about whether you wish to receive information from us. If you do not want to receive direct marketing communications from us about the important work we do in support of vulnerable veterans and their families, updates on our expeditions, charity news and events and the products you can buy, then you can select your choices by ticking the relevant boxes on the form used to collect your information.

We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted and will retain your details on a suppression list to help ensure we do not contact you. We may still need to contact you for the purpose of administration or the purpose of processing a donation or to thank you for participating in an event.

How to contact us

WWTW are committed to putting you in control of your data so you are free to change your marketing preferences (including to tell us that you don’t want to be contacted for marketing purposes) at any time by emailing Dataofficer@wwtw.org.uk  or by post or telephone with the contact details that follow:

Data Officer, Walking With The Wounded, Stody Hall Barns, Stody, Melton Constable, Norfolk, NR24 2ED. Telephone: 01263 863 900

Please contact us if you want further information or return to the homepage.