This Policy explains when and why we collect personal information about our service users and/or others that encounter us, how we use it, the conditions under which we may disclose it to others and how we keep it secure. We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes.

Any questions regarding this Policy and our privacy practices should be sent by email to: info@positive-expressions.co.uk or write to:

Paul Lavery, 5 The Crescent, Ardeley, Stevenage, SG2 7AL.

Who are we?

Positive Expressions (“PE, we, us, our”) is the trading name of Positive Expressions Limited, a private company limited by guarantee registered with Companies House in England and Wales under company number: 13690178. Our registered office is at 5 The Crescent, Ardeley, United Kingdom, SG2 7AL. For the purposes of this policy, and applicable law on data protection, we are the data controller and data processor for matters related to your engagement with us (whether that be as a service user, service provider for services involving us, or otherwise interacting with us for whatever query you may have). Where agents or sub-contractors or similar are providing services on our behalf, they will receive data and information necessary to do this and become a data processor acting on our behalf.

How we collect your information

We collect information from you via a variety of sources, including when you apply for one of our services, complete one of our forms, when you call, write, e-mail or meet with us. We may collect information when you use our website. We will also require personal data where you are applying to work with or through us.

From time to time, we may operate CCTV / sound recording and / or use photography to capture evidence of alleged anti-social behaviour or crime or otherwise as a deterrence to such behaviour.

We may also take photographs at our events and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with their (or their legal guardian’s) consent.

We may receive information about you from third parties including:

• A council or similar referring agency.
• Welfare or support organisations dealing with you/your young person.
• Councillors, MPs or other representatives acting on your behalf/instruction.
• Regulatory authorities such as the police, DBS or other organisation or agency.
• Former employers or other referees.

What information we collect about you

The information we may require from you includes:

• Full name (and proof of your identity / photo ID).
• Date of birth
• National Insurance number (your unique identifier).
• Contact details (phone, e-mail or correspondence address).
• Details of anyone authorised to act on your behalf if applicable.
• Banking details if you are working with or through us.
• Other personal information that will vary on a case-by-case basis to help us determine how best we may support any query or services you or your young person may require
• Disabilities or vulnerabilities. We use this information to tailor our service to better meet your or your young person’s particular circumstances and needs. We may use this information for safeguarding of staff.
• Health and medical information. We may use this information to tailor our service to better meet your or your young person’s particular circumstances or needs. We may use this information for safeguarding of staff or others where appropriate.

If you do not provide the information, we need then we may not be able to provide all our services to you, and ultimately support you with whatever your query may be.

What processing we do with information collected

The information we require from you is used to resolve whatever the query is you may have, or otherwise in the delivery or performance of our services. Whilst ‘performance of a contract’ is usually the legal basis for us processing your information, other bases may apply, for example we may be legally required to process data in certain circumstances (e.g. referring safeguarding matters to a safeguarding authority or similar).

The processing activities we conduct can be summarised as:

• Managing your relationship with us, whether that be as a worker/agent, service user, parent of guardian of a service user, referring or otherwise interested professional.
• Complying with relevant legislation and regulation.

We operate a range of information and communications systems and technologies for the efficient operation of our business. Personal information is stored and managed within those systems which are maintained to achieve a high level of confidentiality, integrity and availability including following best practice cyber security standards.

We hold information in IT systems which may be copied for testing, backup, archiving and disaster recovery purposes. All data is held within the UK.

How we will communicate with you

Most of our contact with you will be face-to-face or via phone/email. Where relevant we may interact via standard post, or other digital platforms such as Microsoft Teams, Zoom or similar.

We do not currently operate any direct marketing, activities however if any such campaign or other thing related to marketing is formulated, we will seek the consent of anybody whose data we may have and wish to contact in this regard in advance of doing so. Should you consent (‘opt in’) you may withdraw (‘opt out’) that consent at any time.

In the normal course of business, we will not discuss or share your details with anybody other than you or somebody authorised by you unless we have a legal obligation to do so – e.g. where we are compelled to report a concern or incident to a local authority safeguarding team. You can authorise someone temporarily verbally over the phone or permanently in writing to deal with any or all matters related to your interactions with us. If any of your personal data is communicated to a third party without your consent we will always endeavour to be as transparent as possible about this, however it is important to bear in mind that we may not always be able to provide specific detail where there is a lawful reason not to, such as safeguarding referrals.

Who we share data with and how long we keep information

We share limited personal data with our agents/contractors who are carrying out services on our behalf. Our agents/contractors are required to comply with the law and our data processing policy to ensure data is managed appropriately and for specified purposes related to service provision or fulfilment.

We may need to share personal information with government departments and agencies, with regulators, or with medical and other professional professionals or with other organisations and agencies where we are legally allowed or obliged to do so.

Your personal data will be stored by us for as long as it is needed to fulfil the purpose for which it was collected and any statutory or otherwise best practice run-off period.

What we will not do

We will not send you unsolicited marketing material. We will not sell your personal data on to third parties. We will not pass on your personal data to unrelated third parties unless we are allowed or required to do so by law, or we have your explicit permission to do so.

We will not transfer or store your personal data outside of Europe (the European Economic Area) outside of the control of the UK / European regulations.

Your rights, the right to complain and the ICO

You have the right to request a copy of the data we hold about you. If you wish to request access to any of your personal data, please email info@positive-expressions.co.uk We will endeavour to acknowledge your request within 48 hours of receipt and will respond substantively within a calendar month thereafter.

Where we must clarify what your request relates to understand its subject matter this may extend the response deadline accordingly. It is important to understand that we may be unable to fulfil a request, either in full or in part where a lawful reason to reject it exists. Further it is important to understand that we may not be able to provide detailed reasons for any restriction or rejection were doing so may prejudice another person’s rights.

You have the right to correct information that we hold. Please advise us of any changes or corrections by contacting info@positive-expressions.co.uk. You may withdraw your consent to use any information that was previously provided with your consent. Please advise us if you wish to withdraw any consent previously given to info@positive-expressions.co.uk Where any data is being stored and/or processed for reasons other than your consent you do not have the right to withdraw that consent to the processing of that data.

You also have other rights which can be seen by visiting the Information Commissioner’s Office (ICO) website and reading about Data Protection law.

You have the right to complain about any matter relating to our service, including how we use your personal data. In the first instance please refer to our Complaints policy.

If you wish to complain about our use of your personal data you may complain to the UK Information Commissioner’s Office (ICO).

Changes to our Privacy Notice

Our Privacy Notice is regularly kept up to date and this version was updated on 09/09/24