The privacy and security of your personal information is extremely important to us. This privacy promise explains how and why we use your personal data, to make sure you stay informed and can be confident about giving us your information.

At Seashell we are committed to protecting your personal information and being transparent about what we do with it. We will do our best to use your personal information in accordance with Data Protection law, and not do anything with your information that you wouldn’t reasonably expect. 

In this promise whenever you see the words “we”, “us”, “our” or “Seashell” it refers to the legal entity Seashell Trust.

If you want to learn more about what we do click here.

On this page

Overview

Our Privacy Promise sets out how and why we obtain, use, and protect your personal information. We may undertake additional processing which is subject to separate Privacy Policies, and we will draw them to your attention where this is the case.

The privacy and security of your personal information is extremely important to us. This Privacy Promise explains how and why we use your personal data, to make sure you stay informed and can be confident about giving us your information.

This Privacy Promise applies to those that we support and their family/carer or legal guardians, our supporters, our customers, as well as to the general public, suppliers and contractors, partner organisations, volunteers, health, education or social care service partners, visitors to our premises and to journalists. If you are an employee, or a potential or past employee or others defined under ‘employee’ please contact us for a copy of our Employee Privacy Policy.

For information about the rights you may have in relation to your personal data please see Your Rights below. If you would like to exercise any of your rights, please contact us.

Lawful basis for processing

UK Data Protection laws require us to have a specific lawful basis for each purpose for which we process your personal and personal sensitive information, as permitted by the UK GDPR, The UK Data Protection Act 2018, and Privacy of Electronic Communications Regulations (2019) We explain these purposes and the corresponding lawful basis in the section on How we use your data.

We will notify you at the time of collection of the personal data of how we intend to use that data and will only use that data in accordance with that notification and any preferences you express.

Our Heads of Services and professional services partners might use personal and personal sensitive data to evaluate the effectiveness of our services. This evaluation allows us to ensure our services support our users as effectively as possible and to potentially scale up the provision of and identify other areas for evaluation.

We and our partners collect and process your personal information for various purposes, in accordance with applicable laws for example, but not exhaustive (Education Act 1996, 2002 and 2011, The Care Act 2014, Mental Capacity Act 2005, Deprivation of Liberty Safeguards, The Children’s Act 1989 and 2004, Education and Skills Act 2008 and the Equalities Act 2010, Crime and Disorder Act 1998, Working together to Safeguard Children 2023)

It may occasionally be used for purposes not obvious to you where the circumstances warrant such use (e.g. in investigations).

We generally process your personal information on one of the following bases:

  • the processing is necessary for our legitimate interests (as identified in the section on How we use your data), except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information;
  • we have obtained your consent to use your personal data for the stated purpose;
  • the processing is necessary for compliance with a legal obligation. to which we are subject; or
  • the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract.

We may also rely on other bases (for example, where the processing is necessary in the performance of a task carried out in the public interest, or where the processing is necessary to protect your vital interests or those of another person) on an exceptional basis, if none of the above conditions apply.

We collect special category data (usually but not only health data, equal opportunities data) mainly so that we can provide our services and keep you safe and well when using our services, or meet our obligations for Equality, Diversity, and Inclusion. Also, to determine what services are relevant to you or to provide other services and support to you.

We may also collect this information in other situations, for example, when we are carrying out service development, new options to the services we already provide and therefore may collect this information when you agree to help us with our work.

In order to process any special category data, we need to ensure that we have a particular reason to do so, in addition to the general lawful bases set out above. This reason needs to relate to one of the additional lawful bases for processing set out under UK Data Protection laws.

We process your special category data only:

  • with your explicit consent, or that of your parent/guardian/legal representative in line with the requirements of the Mental Capacity Act, depending upon your age;
  • to follow Employment, Social Security or Protection Law;
  • in your Vital Interests i.e., protect your life (or someone else’s life), in situations where you are physically or legally incapable of giving consent;
  • to provide Health and Social Care, and it is used by, or under direction of a professional obliged to confidentiality under law;
  • where you have 'manifestly made public' this information;
  • legal claims;
  • is necessary for substantial public interests (as set out in UK Data Protection law) e.g., crime, serious risks to individuals we are responsible for, to protect vulnerable children and adults
  • is necessary for reasons of public interest in the area of public health e.g., reporting infectious diseases; or
  • in Legitimate Activities

In our use of health and care information, we satisfy the common law duty of confidentiality because:

  • you have provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
  • we have a legal requirement to collect, share and use the data; or
  • for specific individual cases, we have assessed that the public interest to share the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime). This will always be considered on a case-by-case basis, with careful assessment of whether it is appropriate to share the particular information, balanced against the public interest in maintaining a confidential health service

We only process this type of data where we have a clear legal basis to do so under UK Data Protection law. This is usually where the processing in question is necessary for the purposes of preventing or detecting unlawful acts.

For example, we might process such data:

  • if we had a recording of a theft captured on CCTV cameras at one of our premises which we needed to share with the police;
  • Request to share safeguarding data, or when requested to provide data by the police for law enforcement investigations; or
  • to allow us to investigate, and if appropriate bring prosecutions against, persons using Seashell to carry out fraudulent fundraising supposedly on our behalf

We’ll keep this promise updated to show you all the things we do with your personal data. This promise applies if you’re a supporter of Seashell; member, donor, volunteer, supplier, contractor, customer, supporting parent/carer or legal guardian, employee, ex- employee, employee family member, governor, trustee, supplier, facilities user, health, education or social care partner, placement trainee, student, pupil, child, young person.

Additionally when you use any of our services, visit our website, message us on social media, email, call or write to us.  In certain circumstances we may also provide an additional privacy notice, which will always refer to this promise.

We will only provide this privacy promise to you once, generally at the start of our relationship with you. However if this privacy promise is updated substantially, then we may provide you with details of the updated version. You are encouraged to check back regularly for updates.

If you'd like more information, please contact us today

If you have questions about this Privacy Promise or if you would like to exercise any of your privacy rights, please contact us by email at data@seashelltrust.org.uk or write to the Information Manager Change and Governance, Seashell Trust, Stanley Road, Cheadle Hulme, Cheshire SK8 6RQ

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