Privacy Policy

Privacy Policy
Headway Jersey Brain Injury Charity has always taken great care over the data that we hold for
the service users and contacts that we work with.
Privacy Policy / Data Protection Policy
Our updated Data Protection Policy is detailed below and is available on our website.
Our Privacy Policy – your information, your rights and how we use it
Headway (Jersey) Limited is committed to protecting your personal information.
Our Privacy Policy contains important information about what personal details we collect; what
we do with that information; who we may share it with and why; and your choices and rights
when it comes to the personal information you have given us.
We may need to make changes to our Privacy Policy from time to time. Please check back
here. If there are important changes such as changes to where your personal data will be
processed, we will contact you to let you know.
If you require access to the data we hold on you, we may require additional information from you
to confirm your identity before we release any data we hold.
Who we are
We are Headway (Jersey) Limited, Brain Injury Charity.
This Privacy Policy applies to Headway (Jersey) Limited
How to contact us
If you have any questions about our Privacy Policy or the information we collect or use about
you, please contact:
FAO Data Controller
Headway(Jersey)Limited.
Le Coie Centre, Springfield Road, St Saviour, Jersey. JE2 7DN
Email: headwayinjersey@gmail.com
Information we collect and use
Information about you that we collect and use includes:
 Information about who you are e.g. your name, date of birth, address and contact details
 Information about your contact with us e.g. meetings, emails / letters and phone calls
 Information on your contact points in case of an emergency
 Professional contacts, for liaison purposes if required, e.g Doctor, Social Worker
 With your consent, information classified as ‘sensitive’ personal information e.g. relating
to your health. This information will only be collected and used where it is needed to
provide the service you have requested or to comply with our legal obligations
Where we collect your information
We may collect your personal information about you, from a variety of sources, including:
 A Consent form for a service we provide
 phone conversations with us
 emails or letters you send to us
 meetings with one of our team members
 registering for an event with us e.g. Carers event, Fundraising activities
 participating in surveys to help us understand you better and improve our services
 our online services such as websites and social media
 make a donation to us
 request marketing to be sent to you
 give us feedback on our work
 Third parties or publicly available sources. We may receive personal information about
you from various third parties and public sources as set out below:
o Identity information, and contact and financial details from third party
organisations with whom we fundraise in partnership (for example, when you sign
up for an event or fundraise for us though a third party such as the London
Marathon or through fundraising websites such as JustGiving and Virgin Money
Giving); and
o Identity information, contact and financial details, and health information from
third party organisations to whom you gave permission to share your details with
us, including your GP, States of Jersey Health & Social Services dept or other
charities and agencies.
What we collect and use your information for
We take your privacy seriously and we will only ever collect and use information which is
personal to you where it is necessary, fair and lawful to do so. We will collect and use your
information only where:
 it is necessary to provide the service you have agreed to participate in following
assessment. e.g. Day Centre, Specific Rehabilitation
 it is necessary for us to meet our contractual, legal or regulatory obligations e.g.
accounting for promotional prizes and to tell you about changes to Terms and Conditions
or for the detection and prevention of fraud
 it is in the legitimate interests of Headway (Jersey) Limited e.g. to deliver appropriate
information and guidance so you are aware of the options that will help you get the best
outcome from our services
 where we need to process your information to better understand you and your needs so
we can send you more relevant communications about the services you use with us and
to develop new services into the future
 it is in the legitimate interests of a third party e.g. crime reduction
 it is necessary for us to meet our legal or regulatory obligations e.g. to verify your identity
 it is in the legitimate interests of Headway (Jersey) Limited e.g. to understand our user
demographics and use of our website and online services
 to send invoices or reminder notices or otherwise notify you of changes to our online
services, and any other purpose related to or ancillary to any of the above.
 Marketing and communications preferences for receiving information from us about
our support services, research, campaigning, volunteering and fundraising activities
(including ways to donate) and how you would like us to communicate with you
If you do not wish us to collect and use your personal information in these ways, it may mean
that we will be unable to provide you with our services.
Who we may share your information with
We may share your information with third parties for the reasons outlined in ‘What we collect and
use your information for.’
These third parties include:
 Headway (Jersey) Limited employees
 Companies we have chosen to support us in the delivery of the services we offer to you
or companies who can help us in our contact with you, for example an internet service
provider.
 Health providers like States of Jersey Health & Social Services dept or other agencies
and charities, to whom we might refer you for additional support as part of delivering a
service to you.
Where we wish to share your personal information with third parties who are not listed above
then we shall seek your consent before doing so, unless the data is anonymised (i.e. it does not
identify individuals) – in which case we may share the information without first obtaining your
consent.
We will never sell your details to someone else. Whenever we share your personal information,
we will do so in line with our obligations to keep your information safe and secure.
Where your information is processed by Headway (Jersey) Limited
All of the information provided to Headway (Jersey) Limited is processed by us in Jersey
How we protect your information
We take information and system security very seriously and we strive to comply with our
obligations at all times. Any personal information which is collected, recorded or used in any way,
whether on paper, online or any other media, will have appropriate safeguards applied in line
with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident,
negligence or deliberate actions. Our employees also protect sensitive or confidential information
when storing or transmitting information electronically and must undertake training on this.
Our security controls are aligned to good practice; providing a control environment that effectively
manages risks to the confidentiality, integrity and availability of your information.
Protection of Personal Data
Protection of all service user information provided or received by us is of paramount importance
to us. Headway (Jersey) Limited goes to great lengths to ensure that the information provided to
us in the course of our business is kept secure at all times. Headway (Jersey) Limited is a Data
Controller under the GDPR, in line with the Data Protection (Jersey) Law 2018 and the Data
Protection Authority (Jersey) Law 2018 and any personal and financial information that we hold
about you will be held on secure server/computer and/or in paper files and processed subject to
the GDPR. This information will be used to deal with queries and to bring to your attention
additional services that may be of benefit to you. If we are advised that the confidentiality of your
information is breached, we will inform you as soon as possible if the breach is likely to result in a
high risk of adversely affecting your rights and freedoms. We also have a duty to report certain
types of personal data breach to the relevant supervisory authority within 72 hours of becoming
aware of the breach, where feasible. We will document all breaches regardless of whether or not
reporting is required.
How long do we keep your information?
We have detailed in this Privacy Policy the ways in which individuals can have their information
deleted from our records or request amendments to the data we hold.
The information we hold for individuals will be maintained for the course of our ongoing business
to maintain correct client/user records. Information will be deleted in line with Headway (Jersey)
Limited’s retention policy.
The individual rights available to you
You have several rights in relation to how Headway (Jersey) Limited uses your information. They
are:
Your right of access
You have the right of access to your personal information. If you wish to receive a copy of the
personal information we hold on you, you may make a data subject access request.
We reserve the right to charge a small administration fee for requests that are manifestly
unfounded or excessive.
Your right to be informed
You have a right to receive clear and easy to understand information on what personal
information we have, why and who we share it with, if at all.
Your right to request deletion
We shall, upon receipt of a written request from the Service User, return all Service User
Personal Data at the end of the provision of the Services to which the Service User Personal
Data relates, otherwise it will remain on file in accordance with our retention policy. This will not
apply to any Service User Personal Data that we must retain in accordance with any legal and
regulatory requirements, and will be directed by any guidance that has been issued in relation to
deletion or retention by the Office of the Information Commissioner
You can ask for your information to be deleted or removed if there is not a compelling reason for
Headway (Jersey) Limited to continue to have it.
We reserve the right to charge a small administration fee for requests that are manifestly
unfounded or excessive.
Your right to request that your personal information be rectified
If your personal information is inaccurate or incomplete, you can request that it is corrected.
We reserve the right to charge a small administration fee for requests that are manifestly
unfounded or excessive.
Your right to restrict processing
You can ask that we block or suppress the processing of your personal information for certain
reasons. This means that we are still permitted to keep your information – but only to ensure we
don’t use it in the future for those reasons you have restricted.
How to make a complaint
We will always strive to collect, use and safeguard your personal information in line with data
protection laws. If you do not believe we have handled your information as set out in our Privacy
Policy, please contact us directly and we will work to resolve any issues.
If you are still unhappy, you can complain to the Office of the Information Commissioner. Their
contact details are:
Information Commissioner’s Office
One Liberty Place,
Liberty Wharf,
La Route De La Liberation,
St Helier,
Jersey JE2 3NY
Tel: +44 (0)1534 716530
Or
E-Mail: enquiries@oicjersey.org
Or
By completing an online enquiry complaints form by following the link below:
https://oicjersey.org/online-enquiry/#/complain/form