Tameside Oldham and Glossop Mind Privacy and Cookies Policy

Neighbourhood Mental Health Team Privacy Notice

Tameside, Oldham, and Glossop (TOG Mind) want everyone who accesses our services, supports us, or interacts with us to be informed and comfortable with how we process your personal information.

This policy explains when and why we collect personal information about people who use our services, how we use it, the situations in which we may share your information and how we ensure the security of your personal information. Personal information is anything that identifies or could identify you.

We may change this policy to reflect changes in our practices and procedures so please refer to the latest version of this policy when you need to understand how we use your information. Should we make any changes to this policy, this will be communicated on our website, and we will inform you through your stated communication preferences.

TOG Mind’s policies are underpinned by our values:

Relationships: we listen and ask questions to understand others and to build trust. People matter to us both inside and outside our organisation.
Aspiration: we support one another, clients, and communities to achieve better mental health.
Learning: we seek insight and grow from experience; finding new or better ways to contribute to the field of mental health.
Potential: we encourage personal responsibility for development by discovering and realising the abilities and energies of people.

1. Who we are
2. How we collect information about you
3. Information we collect and why we use it
4. Legal basis for using your information
5. Marketing
6. Storing your information and keeping it safe
7. Sharing your Information
8. How long we hold your information and when we archive / destroy it
9. Your individual rights concerning your information
10. How to complain
11. Cookies
12. Monitoring
13. Frequently Asked Questions (FAQs)
14. Further Resources

Appendix A – Information about our use of Cookies

1. Who we are

We are a mental health charity, first formed in 1978. In 2008 we re-registered as Tameside, Oldham, and Glossop (TOG) Mind and became a wellbeing service. Our aim is to provide the best quality local mental health services in prevention, early intervention, and primary care; alongside empowering individuals and our communities to live well. As defined by the Data Protection Act 1988 and the General Data Protection Regulation, at times we are a ‘data controller’ and at other times we are a ‘data processor’. This means that we collect, process, and store your personal information, but depending on the service, purpose or activity, our authority and responsibility will change.

For further information about our privacy practices you can contact our Data Protection Officer by:

Writing to 216 - 218 Katherine Street, Ashton-under-Lyne, OL6 7AS.
Calling 0161 330 9223.
Emailing datarequest [at] togmind.org.

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2. How we collect information about you

We collect information from you in the following ways:

Information you give to us (Submitted Information)

You may submit information to TOG Mind when you correspond with us by phone, email or otherwise. You may also submit information to us when you complete forms (paper or digital) supplied by TOG Mind, these may be registration forms for training, service forms, feedback forms or otherwise. You may also submit information to us when you make a donation or otherwise engage in monetary or financial activities with us in a personal or professional capacity.

Information we collect about you

We may collect information about you when you visit our website through cookies and other digital tools. No other channels will result in your information being collected automatically. For more information about cookies, please see the sections below on cookies and our use of them. Click here to view our Cookies section.

Information we receive from other sources

We may receive information about you if you use any of the partner sites that we work with, this includes donation platforms, event registration platforms or analytics providers. We may also receive information about you from other mental health, physical health, or social services – the nature of this information sharing will be dictated by an Information Sharing Agreement and could be in the joint delivery of services or in the delivery of services on behalf of another organisation. We may also receive information about you from other sources where you have consented to this type of information sharing, an example may be where you have consented to a referral from one organisation to us at TOG Mind.

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3. Information we collect and why we use it

By using our services, accessing our website, fundraising for, or working with us, you acknowledge and consent to TOG Mind collecting and processing information submitted by you or any other organisations you are working with.

Information you give to us (Submitted Information)

The information you give us may include: your name, address, email address and phone number, age, username, password, and personal details including health information or information about your private life, your occupation and employer, your bank details, and any other information you provide.

Information we collect about you

The information we collect about you may include: technical information such as the type of device you use to access our sites, your IP address, your location at the time of access, and your mobile operating system, browser, and network. We may also collect information about which pages on our site you visit and which services, events and information is of interest to you – we may also collect similar information when you click on links included in TOG Mind communication materials such as emails and social media posts.

Information we receive from other sources

The information we receive from other sources depends on the purpose of the information sharing. We may receive information you have previously submitted to another organisation and information collected about you from another organisation. If we receive information in support of your care, this is likely to include contact details and personal details about you such as health information or your NHS number. We may also receive information about your bank details or organisational financial activity as part of processing payments or invoices.

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4. Legal basis for using your information

In some cases, we will only use your personal information where we have your consent, however, there are other lawful reasons that allow us to process your personal information.

The table below displays all the processing activities TOG Mind engages in including the legal basis for processing your information:

Processing Activity and Purpose	Information Source/s	Legal Basis of Processing Article 6	Legal Basis of Processing Article 9 (Special Category Data)
Collecting, storing, and using identifiable client data for providing our services and training – communication and treatment	The client Referring organisations	Legitimate Interests Consent, where applicable Contract, for training	Provision of Health or Social Care Not-for-profit
Reporting internally and externally de-personalised information	Client Databases	Legitimate Interests Public Task, where applicable	Provision of Health or Social Care Not-for-profit – mission analysis Public Health, where applicable
Referrals of clients to other health and social organisations	The client	Consent	Explicit Consent
Safeguarding procedures to prevent harm	The client Other organisations Client Databases	Vital Interests, where applicable Legal Obligation	Vital Interests, where applicable Provision of Health or Social Care
Processing website and digital platform data for marketing and communications analysis	Cookies Google Analytics Communication tools	Legitimate Interests	N/A
Processing donations and supporting fundraising activities	Fundraiser / donor / supporter	Legitimate Interests Contract Consent	Not-for-profit

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5. Marketing and Communication Preferences

We will only contact you about our work, how you can support us, and upcoming events and services if you have agreed for us to contact you with this information. However, if you have provided us with your postal address, we may send you information about our work and how you can support us by mail unless you have told us that you would prefer not to hear from us in that way.

You can update your choices or stop us from sending you these communications at any time by contacting 'datarequest [at] togmind.org’ or clicking the unsubscribe link at the bottom of the relevant communication.

We will never sell or share your personal information with organisations for the purposes of their marketing activities. We will never sell any information about your web-browsing activity.

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6. Storing your information and keeping it safe

Your information is securely stored. We are committed to preserving the confidentiality and integrity of your information, ensuring it is only available to those who have authorised access. We ensure that when your information is stored, our practices are legally compliant, and meet your expectations. We encrypt your information to make it harder for unauthorised people to access it, we use secure passwords, and we keep audit trails on all our systems to see who has access to your information. We have a variety of physical and digital protections in place to keep your information safe, and we ensure that data protection is a core part of staff training. We will let you know if your information is at risk in instances where a data breach could cause harm to you.

For more information about how we store your information, you can request to see our Information Security Policy.

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7. Sharing your Information

We may need to share information across organisational and professional boundaries to deliver our services and provide appropriate safeguards. We will always operate in the best interests of the people we help and work in a way that retains trust and remains compliant with the law. We respect your rights to govern your personal information and we will always be open and honest with you about what information we share and why we need to share it. Information may be shared routinely or in one-off situations, it may also be shared in a de-personalised way, such as for reporting to our funders, or information sharing may include identifiable information, such as when we need to ensure your safety. Whenever we share your information, we will comply with the principles of data protection and security.

For more information about our information-sharing practices, you can request to see our Information Sharing Policy and specific sharing activities may be governed by an Information Sharing Agreement (ISA) and/or a Data Protection Impact Assessment (DPIA)

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8. How long we hold your information and when we archive / destroy it

We hold your information for a variety of purposes and each purpose requires that we hold your information for a specific amount of time. Sometimes the length of time we hold your information is dictated by the law, sometimes by our funders or regulators, and other times we make our own judgement about how long we need your information. Information is only kept for as long as is necessary to achieve the purpose it was collected for. Typically, each type of information will have a ‘trigger point’ for when the retention period applies – for example, we hold client information for 7 years from the point of last contact, if you contact us again within this 7-year period, the retention period resets.

We perform regular checks to see if we need to keep your information or whether it can be securely archived or destroyed. We may decide to archive or destroy your information earlier than the end of the given retention period if the information is no longer required. We may also destroy your information at your request if the request is suitable and we do not need the information for any other purpose – in instances where the information is needed for a statutory or legal purpose, it may not be eligible for destruction, even if you request this. When we destroy your information, we do so in a secure and confidential manner.

For more information about how long we keep your information, including a detailed retention schedule and processes for how your information is destroyed, you can request to see our Data Retention Policy.

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9. Your individual rights concerning your information

Under data protection law you have rights, including:

Your right to be informed – You have a right to know how we process your information, any changes to this processing or your information, and if your rights have been affected.

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

Rights in relation to automated decision-making and profiling – TOG Mind do not engage in this activity, so this is not applicable. You can find information about this right on the ICO website.

You are not required to pay any charge for exercising your rights. If you make a request, we typically have one month to respond to you, however, there may be instances where an extension is applicable.

If you wish to exercise your rights and/or make a request, please contact us by:

Writing to 216-218 Katherine St, Ashton-Under-Lyne, OL6 7AS
Calling 0161 330 9223
Emailing datarequest [at] togmind.org

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10. How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us by:

Writing to 216-218 Katherine St, Ashton-Under-Lyne, OL6 7AS
Calling 0161 330 9223
Emailing datarequest [at] togmind.org

For details about TOG Mind’s complaints process, please refer to the complaints policy available on our website.

You can also complain to the ICO if you are unhappy with how we have used your data. You can access more information and contact the ICO via the following channels:

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

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11. Cookies

Our site(s) uses cookies to distinguish you from other users of our site(s). This helps us to provide you with a good experience when you browse our sites(s) and allows us to improve our sites(s). For detailed information on the cookies we use and the purposes for which we use them see the section ‘Information about Our use of Cookies’.

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12. Monitoring

Your communications with our teams (including by telephone or email) may be monitored and/or recorded for training, quality control and compliance purposes to ensure that we continuously improve our customer service standards.

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13. Frequently Asked Questions (FAQs)

What is a Privacy Policy?

A Privacy Policy is a legal document or statement that informs individuals about the data being collected from them, how that data is used, and what rights they have regarding their data.

Why do you have a Privacy Policy?

We are required to have a Privacy Policy by law. Data Protection laws state that we must be transparent about how we process data and for what purposes, as well as provide information so you can hold us accountable and make informed choices/decisions concerning your information.

What’s the difference between a Privacy Policy and Terms & Conditions?

A Privacy Policy tells you how we process your information but there is no obligation on your part to do anything. Terms & Conditions set out rules, standards and requirements that you would have to follow if you want to use a specific website, service or app. Terms & Conditions might place restrictions on you when a Privacy Policy would never do this.

Can you provide me with more information or explain something that I don’t understand?

We would be happy to provide you with more information. You can get this if you contact our Data Protection Officer by:

Writing to 216-218 Katherine St, Ashton-Under-Lyne, OL6 7AS
Calling 0161 330 9223
Emailing datarequest [at] togmind.org

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14. Further Resources

For more information about data protection, your rights and more, you can visit the Information Commissioners website: https://ico.org.uk/for-the-public/

For more information about how our partners process information, please refer to their specific Privacy Policies below.

National Mind: https://www.mind.org.uk/legal-info/privacy-policy/

Appendix A - Information about our use of Cookies

'Cookie' is a name for a small file, usually of letters and numbers, which is downloaded onto your device, like your computer, mobile phone or tablet when you visit a website.

They let websites recognise your device so that the sites can work more effectively and gather information about how you use the site. A cookie, by itself, cannot be used to identify you.

How do we use cookies?

We use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you come to our website and allows us to improve the user experience.

The cookies we use

We use the categorisation set out by the International Chamber of Commerce in their UK Cookie Guide.

We use all four categories of cookies:

Strictly necessary cookies are essential for you to move around our website and to use its features, like our shopping basket and your account.
Performance cookies collect anonymous information about how you use our site, like which pages are visited most.
Functionality cookies collect anonymous information that remembers choices you make to improve your experience, like your text size or location. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
Targeting or advertising cookies collect information about your browsing habits to make advertising relevant to you and your interests. As such if you visit the Mind website you may then be more likely to see adverts about Mind’s work on other websites as your browsing suggests that this is an area of interest.

No cookies, please

You can opt out of all our cookies (except the strictly necessary ones). Find out how to control and delete cookies in your browser.

But, if you choose to refuse all cookies, our website may not function for you as we would like it to.

Policy Revisions

This policy will be reviewed every year, and any amendments made as necessary or earlier if changes to national legislation or operational procedures at TOG Mind occur. We welcome feedback on policies to help us continuously improve. If you would like to provide any suggested improvements on the content of this policy, please email your feedback to HR [at] togmind.org

All policies are subject to Executive Committee approval.

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Tameside Oldham and Glossop Mind Privacy and Cookies Policy

Relationships: we listen and ask questions to understand others and to build trust. People matter to us both inside and outside our organisation.

Aspiration: we support one another, clients, and communities to achieve better mental health.

Learning: we seek insight and grow from experience; finding new or better ways to contribute to the field of mental health.

Potential: we encourage personal responsibility for development by discovering and realising the abilities and energies of people.

1. Who we are

2. How we collect information about you

3. Information we collect and why we use it

4. Legal basis for using your information

5. Marketing

6. Storing your information and keeping it safe

7. Sharing your Information

8. How long we hold your information and when we archive / destroy it

9. Your individual rights concerning your information

10. How to complain

11. Cookies

12. Monitoring

13. Frequently Asked Questions (FAQs)

14. Further Resources

Writing to 216 - 218 Katherine Street, Ashton-under-Lyne, OL6 7AS.

Calling 0161 330 9223.

Emailing datarequest [at] togmind.org.

Information you give to us (Submitted Information)

Information we collect about you

Information we receive from other sources

Information you give to us (Submitted Information)

Information we collect about you

Information we receive from other sources

Processing Activity and Purpose

Information Source/s

Legal Basis of Processing

Article 6

Legal Basis of Processing

Article 9 (Special Category Data)

Your right to be informed – You have a right to know how we process your information, any changes to this processing or your information, and if your rights have been affected.

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

Rights in relation to automated decision-making and profiling – TOG Mind do not engage in this activity, so this is not applicable. You can find information about this right on the ICO website.

Writing to 216-218 Katherine St, Ashton-Under-Lyne, OL6 7AS

Calling 0161 330 9223

Emailing datarequest [at] togmind.org

Writing to 216-218 Katherine St, Ashton-Under-Lyne, OL6 7AS

Calling 0161 330 9223

Emailing datarequest [at] togmind.org

What is a Privacy Policy?

Why do you have a Privacy Policy?

What’s the difference between a Privacy Policy and Terms & Conditions?

Can you provide me with more information or explain something that I don’t understand?

Writing to 216-218 Katherine St, Ashton-Under-Lyne, OL6 7AS

Calling 0161 330 9223

Emailing datarequest [at] togmind.org

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