Privacy Policy

Lawful bases and data protection rights

Under UK (United Kingdom) data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK General Data Protection Regulations (GDPR). You can find out more about lawful bases on the Information Commissioners Office (ICO) website.

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Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

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• Your right of access: You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

• Your right to rectification: You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

• Your right to erasure: You have the right to ask us to delete your personal information. Read more about the right to erasure.

• Your right to restriction of processing: You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.

• Your right to object to processing: You have the right to object to the processing of your personal data. Read more about the right to object to processing.

• 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. Read more about the right to data portability.

• Your right to withdraw consent: When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

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If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

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Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:​

• Consent: We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract: We have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation: We have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests: We’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:​

  • To ensure the wellbeing of our clients

  • To ensure that we are being equitable, inclusive, and diverse across our policies, frameworks, governance

  • To ensure our client base is diverse and that we are providing inclusive, equitable and accessible services

  • To ensure that training is delivered to diverse cohorts

  • Our specialist client service offer means that we gather this data for research and reporting purposes to identify trends and developments in our sector and make them available to the wider public.

• To provide the service we are being contracted

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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.​

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• Vital interests: Collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

• Public task: We have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

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Client and customer accounts

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:​

• Consent: We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract: We have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation: We have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests: We’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • To provide the service we are being contracted

  • To ensure the wellbeing of our clients

  • To ensure that we are being equitable, inclusive, and diverse across our policies, frameworks, governance

  • To ensure our client base is diverse and that we are providing inclusive, equitable and accessible services

  • To ensure that training is delivered to diverse cohorts

  • Our specialist client service offer means that we gather this data for research and reporting purposes to identify trends and developments in our sector and make them available to the wider public.

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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

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• Vital interests: Collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

• Public task: We have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

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Personal information for updates and marketing

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:​

• Consent: We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract: We have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation: We have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests: We’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • To provide the service we are being contracted

  • To ensure the wellbeing of our clients

  • To ensure that we are being equitable, inclusive, and diverse across our policies, frameworks, governance

  • To ensure our client base is diverse and that we are providing inclusive, equitable and accessible services

  • To ensure that training is delivered to diverse cohorts

  • Our specialist client service offer means that we gather this data for research and reporting purposes to identify trends and developments in our sector and make them available to the wider public

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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

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• Vital interests: Collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

• Public task: We have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

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Personal information for research and archiving

Our lawful bases for collecting or using personal information for research or archiving purposes:

• Consent: We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract: We have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation: We have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests: We’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • To provide the service we are being contracted

  • To ensure the wellbeing of our clients

  • To ensure that we are being equitable, inclusive, and diverse across our policies, frameworks, governance

  • To ensure our client base is diverse and that we are providing inclusive, equitable and accessible services

  • To ensure that training is delivered to diverse cohorts

  • Our specialist client service offer means that we gather this data for research and reporting purposes to identify trends and developments in our sector and make them available to the wider public

  • All research will be underpinned by robust ethical practices and be validated by an independent ethical review panel; participant consent; information sheets; and complaints procedures

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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

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• Vital interests: Collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

• Public task: We have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

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Compliance with legal requirements

Our lawful bases for collecting or using personal information to comply with legal requirements:

• Consent: We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract: We have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation: We have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests: We’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • To provide the service we are being contracted

  • To ensure the wellbeing of our clients

  • To ensure that we are being equitable, inclusive, and diverse across our policies, frameworks, governance

  • To ensure our client base is diverse and that we are providing inclusive, equitable and accessible services

  • To ensure that training is delivered to diverse cohorts

  • Our specialist client service offer means that we gather this data for research and reporting purposes to identify trends and developments in our sector and make them available to the wider public

  • For legally mandated and regulatory reporting purposes

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

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• Vital interests: Collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

• Public task: We have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

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Protecting client welfare

Our lawful bases for collecting or using personal information to protect client welfare are:​

• Consent: We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract: We have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation: We have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests: We’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • To provide the service we are being contracted

  • To ensure the wellbeing of our client

  • To ensure that we are being equitable, inclusive, and diverse across our policies, frameworks, governance

  • To ensure our client base is diverse and that we are providing inclusive, equitable and accessible services

  • For compliance and reporting to the Department for Work and Pensions Access to Work scheme

  • To provide support workers with confidential client information

  • To ensure that training is delivered to diverse cohorts

  • Our specialist client service offer means that we gather this data for research and reporting purposes to identify trends and developments in our sector and make them available to the wider public

  • All research will be underpinned by robust ethical practices and be validated by an independent ethical review panel; participant consent; information sheets; and complaints procedures

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

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• Vital interests: Collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

• Public task: We have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

Recruitment

Our lawful bases for collecting or using personal information for recruitment purposes are:​

• Consent: We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract: We have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation: We have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests: We’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • To provide the service we are being contracted

  • To ensure the wellbeing of our clients

  • To ensure that we are being equitable, inclusive, and diverse across our policies, frameworks, governance

  • To ensure our client base is diverse and that we are providing inclusive, equitable and accessible services

  • For compliance and reporting to the Department for Work and Pensions Access to Work scheme

  • To provide support workers with confidential client information

  • To ensure that training is delivered to diverse cohorts

  • Our specialist client service offer means that we gather this data for research and reporting purposes to identify trends and developments in our sector and make them available to the wider public.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

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• Vital interests: Collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

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Dealing with queries, complaints, or claims

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Consent: We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract: We have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation: We have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests: We’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • To provide the service we are being contracted

  • To ensure the wellbeing of our clients

  • To ensure that we are being equitable, inclusive, and diverse across our policies, frameworks, governance

  • To ensure our client base is diverse and that we are providing inclusive, equitable and accessible services

  • For compliance and reporting to the Department for Work and Pensions Access to Work scheme

  • To provide support workers with confidential client information

  • To ensure that training is delivered to diverse cohorts

  • Our specialist client service offer means that we gather this data for research and reporting purposes to identify trends and developments in our sector and make them available to the wider public

  • All research will be underpinned by robust ethical practices and be validated by an independent ethical review panel; participant consent; information sheets; and complaints procedures.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

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• Vital interests: collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

• Public task: we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.​​