Privacy Policy

INTRODUCTION

The Open Door Centre (‘we’ or ‘us’) are committed to protecting and respecting your privacy. We are a registered charity under charity number 1151421 and have our registered office at Bloom Building, Unit 1, Abbey Close, Birkenhead, Wirral, CH41 5FQ.

‘Bazaar’ is a therapeutic intervention intended to support young people and young adults around issues such as anxiety, low mood, stress and panic attacks. The programme is remote-based and offers eight sessions of support to help improve symptoms. This policy sets out the basis on which any personal data we collect from you, or that you may provide to us, will be processed by us as part Bazaar Solus. Please read the following carefully to ensure you understand our views and practices regarding your personal data and how we will treat it.

We keep our privacy policy under regular review. This version was last updated in July 2021.

Our processing of your personal data is governed under the EU General Data Protection Regulation as it forms part of domestic law in the United Kingdom (“UK GDPR”). For the purpose of the UK GDPR, we are a data controller in respect of your personal data.

WE MAY COLLECT AND PROCESS THE FOLLOWING PERSONAL DATA ABOUT YOU:

Contact information you provide to us through our website. We collect information that you provide by filling in form on https://temp.bazaarmindmarket.co.uk (‘our site’). This includes information provided at the time of registering to use our site, subscribing to our services, posting material and/or requesting further services. This may include but is not limited to your name and job title, contact information including e-mail address, gender, occupation and company details and interests in order to provide you with details of our products and services.

If you contact us, we may keep a record of that correspondence in accordance with our retention policy detailed below.

Usage information we collect automatically through our website. We may collect details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access. Information relevant to any recruitment process, IP addresses and cookies may also be included.

Aggregated data. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about users’ browsing actions and patterns and does not identify any individual.

Our use of cookies. We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies help us to improve our site and to deliver a better and more personalised service.

SPECIAL CATEGORIES OF PERSONAL DATA

In addition to the above personal information, we may also process special category (sensitive) data with regards to a participant’s mental health and wellbeing symptoms and demographic information that participants provide to us. The purpose of this processing is to ensure that we can monitor a participant’s progress and that participants are suitably safeguarded. This also helps us to ensure that the support is received by appropriate participants. We will also track responses within sessions utilising quantitative scales for anxiety and depression including clinical tools PHQ-9 and GAD-7 as well as suicidal ideation. There is the opportunity for participants to enter qualitative information about their experiences and progress as far as they feel comfortable in doing so.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so.

Purpose Lawful Basis
To carry out our obligations arising from any contracts entered into between you and us. This includes allowing you to participate in interactive features of our service and ensuring that the support is received by appropriate participants and anonymised data informs us of how we can continually improve the programme.
  • Performance of a contract with you.
  • Necessary to comply with a legal obligation.
  • Necessary for our legitimate interests (to provide our services to you and to continually improve our services for other participants).
To ensure that we can monitor a participant’s progress and that participants are suitably safeguarded.
  • Performance of a contract with you (if applicable).
  • To protect a participant’s vital interests (if applicable).
  • Necessary for our legitimate interests (to respond to your inquiry or request and for customer service satisfaction).
To provide you with information, products or services that you request from us or which we feel may interest you including as part of direct marketing, where you have consented to be contacted for such purposes.
  • Consent that you have provided.
  • Necessary for our legitimate interests (to respond to your inquiry or request, for customer service satisfaction and to develop and grow our business).
To ensure that content from our site is presented in the most effective manner for you and for your computer and to speed your searches.
  • Necessary for our legitimate interests (to ensure our site operates correctly and to keep it updated and relevant).
To estimate our audience size and usage pattern.
  • Necessary for our legitimate interests (to keep our site updated and relevant, to develop our business and to inform our marketing strategy).
To store information about your preferences for when you return to our site, and so allow us to customise our site according to your individual interests.
  • Necessary for our legitimate interests (to ensure our site operates correctly and for customer service satisfaction).
Internal record keeping.
  • Necessary for our legitimate interests (to keep our records of participants updated).
Recruitment and selection purposes.
  • Consent that you have provided.
  • Necessary for our legitimate interests (to process applications and grow our business).
To pass your details to accountants, consultants and other professional, for the purpose of obtaining professional advice and complying with our contractual obligations.
  • Necessary to comply with a legal obligation.
  • Necessary for our legitimate interests (to effectively maintain our business).
To ensure legal compliance, such as responding to a subpoena or court order.
  • Necessary to comply with a legal obligation.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law

WHERE WE STORE YOUR PERSONAL DATA AND OUR SECURITY MEASURES

All information you provide to us is stored on our secure servers. We put in place appropriate technical and organizational measures to protect participants’ personal data, including by limiting access to this information to a small group of staff who need access to ensure the support delivered is safe and appropriate as well as password security measures to manage access to data. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

All our staff are also bound by confidentiality agreements through their contract of employment and the system is only accessible via a password and username function.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features, including those described above, to try to prevent unauthorised access.

WE ALSO USE INFORMATION HELD ABOUT YOU IN THE FOLLOWING WAYS:

Research and dissemination. Any data that is used for research or dissemination purposes will only be in relation to general outcomes. All personal data will be fully anonymised, containing no personal information that could in any way be traced back to an individual participant. No person has access to any personal data for the purposes of research except a core staff of team within The Open Door Charity, the parent organisation of Bazaar Solus. Your data will not be shared with any third party and is only stored for the purpose of your support and general, overall outcome reporting. Data is stored in the back end of the programme and is only stored for a period that is reasonably necessary to ensure we provide adequate support and effectiveness to participants.

Marketing. We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you, including services similar to those previously provided to you, and we or they may contact you about these by post, telephone or electronic means (e-mail or SMS). Where required by law, we will ask you to explicitly opt in to receive marketing communications from us and any third parties.

We may share aggregated information to third party advertisers above site users’ browsing actions and patterns, although this information does not identify any specific information.

If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please contact us at any time by contacting us in writing at our registered office at The Open Door Charity, Bloom Building, Unit 1, Abbey Close, Birkenhead, Wirral, CH41 5FQ. Please note that if you do opt-out of receiving marketing communications from us, we may still send you important account-related or other administrative messages.

RETENTION OF YOUR PERSONAL DATA

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your name may be retained on our marketing database. The database enables us to select contacts to receive a variety of marketing materials including legal update service, newsletters and invitations to seminars and events. It details your name, address, telephone, fax, email, website, mailing requirements and other comments if any. Please ensure you update our marketing team with any changes. You have the right to correct any data that relates to you.

DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may disclose your personal information to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • if The Open Door Charity or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
  • to exchange information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We may disclose if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of The Open Door Centre or participants (including you).

YOUR RIGHTS

You have the right to withdraw your consent for us to process your personal data for marketing purposes. You can exercise the right at any time by contacting us at The Open Door Charity, Bloom Building, Unit 1, Abbey Close, Birkenhead, Wirral, CH41 5FQ.

You also have the right to:

  • request access to your personal data;
  • request correction of your personal data;
  • request erasure/deletion of your personal data;
  • object to processing of your personal data;
  • request restriction of processing your personal data;
  • request transfer of your personal data to you or to a third party.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

If you wish your personal data held by us to be deleted, please email info@opendoorcharity.com and we will arrange for all of your data to be removed with confirmation of this being completed.

ACCESS TO INFORMATION

The GDPR gives you the right to access information held about you. Your right of access can be exercised in accordance with the GDPR.

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

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

USE OF COOKIES

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. To find out more about cookies, including how to see what cookies have been set, visit https://solus.bazaarmindmarket.co.uk/cookies/.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

CONTACT US

You may contact our Data Protection Officer in writing Greg Edwards, The Open Door Charity, Bloom Building, Unit 1, Abbey Close, Birkenhead, Wirral, CH41 5FQ. You may also contact us at info@opendoorcharity.com.

FILING A COMPLAINT

Should you have a complaint, have any questions or concerns around your storage of data, please contact us on info@opendoorcharity.com.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before your approach the ICO so please contact us in the first instance.

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