This privacy notice contains information about how South West Surrey Domestic Abuse Service (SWSDAS) uses and protects personal data provided by users of, or referrals to, our services either by accessing our services in person, by phone, email or text message.
When we collect personal data, we are legally required to ensure that it complies with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK-GDPR).
Who we are
SWSDAS is a registered charity providing domestic abuse services. Our charity number is 1200638. As a data controller we are registered with the Information Commissioners Office and our registration number is ZB507492.
What information will SWSDAS collect about me?
The information we collect about you will depend on why you contact us and what purposes we have for using your data. We’ve set out the data we collect and how we get the data below.
When you contact us, and depending on the context, we will collect:
- Your name
- Contact information
- Address information
- Information relating to your personal circumstances
- Information relating to any children or vulnerable adults.
Special category data
Some data that we collect about you will be considered particularly sensitive and we are legally required to take extra care when we collect this type of data which may depending on the context of our purposes for collecting include:
- Health or medical data
- Data about your race, ethnic origin or religious beliefs
- Data about your sexual orientation.
When you email us
We will collect and store your email address and contact information and any information contained in your email in order to provide our services and, where necessary, provide you with access to external services and support.
When you call us
If you call for advice, we will store your contact information, including your name and phone number, and make any relevant notes in our case management system relating to the context of the conversations with our staff.
When you text us
If you text us a short message for advice, our team will contact you to explain how we use your details and ask for your consent to record and store your personal information. Having received your consent, your contact details and any other personal information you have provided us with will be copied into our case management system.
In some cases we will receive personal data in the form of referrals from a range of partner organisations who will provide us with contact information and referral details for support and advice.
Our partner organisations include;
- Law enforcement agencies
- Public bodies
- Charities aligned with our work
We also automatically collect information transmitted by your browser when you access this website. This includes your IP address, the date and time of the request, the pages accessed, the access status/ HTTP status code, the data volume transmitted at any one time, the website from which the request has come, your browser, your operating system and interface, as well as the language and version of the browser software. The legal basis for collecting and processing this personal data is to monitor the use of the website and improve the service we offer.
What will SWSDAS do with my personal information?
When we collect your personal data we can only use it for clear and specific purposes. Principally, we will use your personal information for the purpose of responding to your query and providing support and/or other services as you or other relevant agencies may request, and we are able to provide, as part of this service.
Our lawful basis for processing
When we collect personal data, either directly from you or from another source, we have to have a legal reason to have the data. This is known as a lawful basis under the Data Protection Act 2018 and UK-GDPR. The lawful basis we use will depend on the context of why we have the personal data and what we are doing with it. We’ve set out our lawful basis below:
Lawful Basis: Consent
When we seek your consent, we will only do this when you have a genuine choice to say no without any detriment to you. If we rely on your consent, you are free to withdraw your consent at any time.
We currently expressly seek your consent for:
- Event registration
- Signposting to other services in order to share your data.
- Using your photo/image or words in promotional material such as school workshops.
Please note that we do not need to seek consent for some of our purposes.
Lawful Basis: Legal Obligation
Part of our work involves monitoring and reporting on compliance with safeguarding and domestic abuse legislation and some personal data held in our systems for this purpose.
Lawful Basis: Vital Interest
Where we believe there is a risk to life we will take appropriate steps to share personal data with appropriate authorities and public bodies.
Lawful Basis: Public Task
Much of our work focuses on providing help and support to reduce the impact of domestic abuse and we rely on this lawful basis for much of the operational work of the charity including:
- Providing one to one support
- Carrying out risk assessments
- Referring users to other services
- Providing housing support and scheme management
- Engaging with other services and sharing personal data where appropriate.
- Acting as independent advisors
- The provision of counselling services
Lawful Basis: Legitimate Interest
Some of our purposes rely on legitimate interest which balances our need to process personal data against the rights and freedoms of data subjects. Our legitimate interests are as follows:
- We need to keep our systems and networks secure
- We need to collect data including usage data, aggregate and statistical data for monitoring and performance purposes
Processing Special Category data
When we collect Special Category data, we must have an additional lawful basis as well as the ones listed above.
In the context of our processing of Special Category data, our lawful basis are either
- Schedule 1 Article 17 – Counselling or
- Schedule 1, Part two article 18 – safeguarding of children or of individuals at risk.
How long will SWSDAS keep my personal information?
Data protection law requires us to keep personal data either for as long as is necessary to achieve the purpose for which the data was collected or if there is a legal requirement to keep the data for a specific period.
Will the SWSDAS share my personal information with anyone else?
Generally we will not share your personal information with anyone, including other organisations involved in domestic abuse services, without your explicit consent.
In exceptional circumstances where we need to share your personal information and are unable to ask for your consent, we will make sure that we have a legal basis for that sharing and we will not share any more personal information than is strictly necessary.
SWSDAS is a signatory to the Surrey Multi-Agency Information Sharing Protocol (MAISP), which lays out an agreed set of principles about sharing personal or confidential information.
Sometimes our funders or sponsors ask us to share statistics and example case studies to demonstrate how we are meeting our aims and goals as a charity, or as a funding requirement. Information supplied in response to these requests will always be aggregated and/or anonymised.
Will SWSDAS send my personal information outside of Europe?
No, your personal information will be stored in servers in the UK.
What rights do I have in respect of my personal information?
- When we collect and use your personal data, you have rights in relation to how your data is managed.
- You have the right to update and correct personal information we hold about you if you believe it is incorrect.
- Subject to certain legal limitations, you also have the right to request a copy of the personal information that we hold that relates to you.
- You have the right to request restriction of the processing of that data
- In some limited circumstances you may have the right to request that we delete your personal data.
- Finally, you may also have the right to object to our continued processing of your personal data
- If you have a complaint about the way in which we use your personal information you have the right to complain to the Information Commissioner at ico.org.uk
Note: The SWSDAS service is no longer provided through Citizens Advice Waverley but continues to be provided through SWSDAS registered charity number 1200638.