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Privacy Policy

SiT Privacy Policy – Service Users

This notice applies to all Survivors in Transition (SiT) data subjects (a living individual, in this case a service user of SiT) whose personal data is collected, in line with the requirements of the General Data Protection Regulation (GDPR) 2018. SiT is a registered Charitable Incorporated Organisation (CIO) with the Charity Commission No. 1159782 and registered with the ICO ZA529178. 


  • SiT is responsible for ensuring that this notice is made available to data subjects prior to Survivors in Transition processing their personal data. 
  • All Employees and volunteers of Survivors in Transition who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention. All data subjects are required to review this privacy notice and agree to the lawful reasons for processing. 
  • Data subjects reserve the right to object to processing at any time. 

Personal Information 

SiT is committed to the responsible handling and protection of personal information. 

Personal information means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person. 

We collect, use, disclose, transfer, and store personal information when needed to provide our services effectively and for our operational and business purposes as described in this Privacy Notice. We want to be clear about our privacy practices so that you can make informed choices about the use of your information. 

How we use your information  

SiT processes (collects, stores and uses) personal information for the following purposes: 

  • Service user information for referral, assessment, allocating and running 1:1 and group programmes, 1:1 and group therapy and support services

We are committed to ensuring that the information we collect and use is appropriate for these purposes and does not constitute an invasion of your privacy. 

Special Category Information 

Occasionally we process what may be considered special category information (sensitive personal information). 

Sensitive personal information is a subset of personal information and is generally defined as any information related to: 

  • Racial/ethnic origin political opinions 
  • Religious beliefs 
  • Trade union membership  
  • Physical or mental health 
  • Sexual life preferences 
  • Other medical information including biometric and genetic data 

We will only process this information if it is necessary to support you whilst you are a SiT service user. If we wish to pass your sensitive personal information onto a third party we will only do so once we have obtained your written consent unless we are legally required to do otherwise. 

Lawful Processing  

We must have a valid lawful basis in order to process your personal information. This ensures that the processing is necessary. 

The following information explains what personal information we process and the lawful basis for processing against each purpose. 

1. Provision of support, therapy and group activities 

Lawful basis – Contract 

When you come into contact with SiT we will ask you to provide personal information that is necessary to manage and support (sustain) the services that we provide. When you contact us, we will update and add notes to our computer systems and files. Access to your personal information will be limited to members of SiT requiring information to carry out our business. We may pass your personal information on to third-party service providers contracted to SiT, or to whom SiT is contracted to. Any third parties that we may share your information with are obliged to keep your details securely, and to use them only to fulfil the services they provide on our behalf. 

Personal details will include: 

 Full name, DOB, gender, age, health-related issues, disabilities and vulnerabilities, communication needs, next of kin, correspondence address, diversity information including: nationality, gender, sexual orientation, first language, ethnic origin and religion/beliefs, pregnancy/maternity, gender re-assignment, age, marriage or civil partnership. 

Communication with SiT including: 

      • Processing of internal and external mail (external via third party) 
      • Website bookings 
      • Service user, volunteer and employee contact details 

 Lawful basis – Legitimate Interest 

We process personal information for certain legitimate interests related to the business purposes listed above. ‘Legitimate Interest’ means the interest of our charity in conducting and managing our business (to enable us to give you the best service in the most secure way). 

      • Advice by phone, post, text or email 
      • Whistleblowing for the protection of staff and service users 

Lawful basis – Legal Obligation 

We process personal information for certain legal obligations. This is where the processing is necessary to comply with legislation or the law. 

      • Safeguarding (protection of service users) and sharing relevant information with social services or police 
      • Where we require identification for proof of who you are to minimise fraud

2. For the welfare of our service users 

    • Liaison with associated welfare services, advice and support 
    • Emergency contact details of service users, employees and volunteers 
    • Medical details of service users, employees and volunteers 

3. Legal proceedings 

    •  Share personal information with the Multi Agency Safeguarding Hub (MASH), Children’s or Adult Safeguarding Boards or Police

4. Feedback from research and surveys on how we can provide better services

    • Carrying out research 
    • Contact to complete surveys/ feedback forms after you have received a service from us and use the information you provide to improve our services 

5. Communication with our service users to provide updates relating to our business, appointments and services  

    • Email or text with the promotion of our services 

6. Information, system, network, and cybersecurity 

    • Overall information security operations of SiT to prevent unauthorised access, intrusion, misuse of charity systems, networks, computers and information, including prevention of personal data breaches and cyber-attacks 
    • Detection and investigation of security incidents – processing of personal data of individuals involved in an incident 
    • Website security
    • Monitoring access to systems and any downloads 
    • Use of information gathered from physical access control systems for investigation incidents 
    • Investigating and reporting of data breaches 

7. General corporate operations and due diligence 

    • Sharing necessary and relevant personal information with external providers 
    • Monitoring physical access to offices, and any visitors  
    • Business intelligence 


How long we keep your personal information  

We will hold your personal information securely while you are a service user with us.  

Records will be held in line with retention legislation, following which we will delete all personal information unless you owe us any money, have ongoing legal proceedings with us, or where there is a logged complaint.  

Document  Time retained   
Service users -  If alive  If deceased 
Counselling records  20 years  8 years 
Psychological therapies/assessment  20 years  8 years 
Video/voice recordings  8 years  8 years 
Post suicide    10 years 
Referral letters   20 years  8 years 
Not taken on   2 years   

How we secure personal information 

SiT takes data security seriously, and we use appropriate technologies and procedures to protect personal information. Our data processing, data protection and IT policies and procedures are closely aligned with widely accepted standards and are reviewed annually and updated as necessary to meet our business needs, changes in technology, and regulatory requirements. 

Policies and procedures 

We have measures in place to protect against accidental loss and unauthorised access, use, destruction, or disclosure of data including the following:  

  • We operate a paperless office, and this keeps personal details etc. in one safe environment 
  • We place appropriate restrictions on access to personal information 
  • We implement appropriate measures and controls, including monitoring and physical measures, to store and transfer data securely 
  • Data protection training for all employees who have access to personal information and other sensitive data 
  • We take steps to ensure that our employees and volunteers operate in accordance with our data processing policies and procedures and any applicable contractual conditions 
  • We require third party contractors or sub-contractors to have appropriate agreements in place to ensure personal information is processed in line with the General Data Protection Regulation. 

Your rights as a data subject (service user of SiT) 

At any point while we are in possession of your personal data you, the data subject, have the following rights: 

  • Right of access – you have the right to request a copy of the information that we hold about you. 
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete. 
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. 
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing. 
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation. 
  • Right to object – you have the right to object to certain types of processing such as direct marketing. 
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling. 
  • Right to withdraw consent at any time. 

GDPR gives you greater control over your data held by us. 

You may express your rights, in writing or verbally, by addressing your request to SiT, by: 

  • Email: [email protected] 
  • Writing to, or dropping in at, 84 Fore Street, Ipswich IP4 1LB
  • Calling 01473 232499 

We may need identification or other information to confirm who you are.  This will clarify your right to access the data and exercise your rights and avoid incorrect disclosures. 

Valid forms of identification may include a passport, driving licence or birth certificate. 

SiT will respond to your request within one calendar month.   

Normally, no fee will be charged unless the request is excessive. 

If we are unable to fulfil your request (for example, a legal obligation), or need to take longer to process your request, we will explain why. 

Complaints about SiT mishandling your information 

Right to judicial review: if SiT refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain to the Information Commissioner’s Office (ICO) details below: 

Information Governance department
Information Commissioner’s Office
Wycliffe House
Water Lane
SK9 5AF 

Policy Monitoring Matrix: 

Original Policy Prepared by:  F Ellis  
Date of 1st Issue  05/2018 
This Version  4.0 
Last Date Reviewed & Board Ratified  06/2021 – F Ellis  
Further information to assist with implementation of this policy   
Distribution  All volunteers, staff and trustees have signed a compliance statement stating they have read and will adhere to this policy / procedure 


Failure to comply with SiT policies and procedures will be addressed without delay and may ultimately result in dismissal/exclusion from the organisation. 




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