Privacy Policy


1. Introduction

B Bartlett needs to collect and use certain types of information about the

Individuals or Service Users who come into contact with B Bartlett in

order to carry on our work. This personal information must be collected and dealt

with appropriately whether is collected on paper, stored in a computer database, or

recorded on other material and there are safeguards to ensure this under the Data

Protection Act 1998.

2. Data Controller

B Bartlett is the Data Controller under the Act, which means that it

determines what purposes personal information held, will be used for. It is also

responsible for notifying the Information Commissioner of the data it holds or is likely

to hold, and the general purposes that this data will be used for.

3. Disclosure

B Bartlett may share data with other agencies such as the local authority,

funding bodies and other voluntary agencies.

The Individual/Service User will be made aware in most circumstances how and with

whom their information will be shared. There are circumstances where the law

allows B Bartlett to disclose data (including sensitive data) without the

data subject’s consent.

These are:

a) Carrying out a legal duty or as authorised by the Secretary of State

b) Protecting vital interests of a Individual/Service User or other person

c) The Individual/Service User has already made the information public

d) Conducting any legal proceedings, obtaining legal advice or defending any

legal rights

e) Monitoring for equal opportunities purposes – i.e. race, disability or religion

f) Providing a confidential service where the Individual/Service User’s

consent cannot be obtained or where it is reasonable to proceed without

consent: e.g. where we would wish to avoid forcing stressed or ill

Individuals/Service Users to provide consent signatures.

B Bartlett regards the lawful and correct treatment of personal information

as very important to successful working, and to maintaining the confidence of those

with whom we deal.

B Bartlett intends to ensure that personal information is treated lawfully

and correctly.

To this end, B Bartlett will adhere to the Principles of Data Protection, as

detailed in the Data Protection Act 1998.

Specifically, the Principles require that personal information:

a) Shall be processed fairly and lawfully and, in particular, shall not be

processed unless specific conditions are met,

b) Shall be obtained only for one or more of the purposes specified in the Act,

and shall not be processed in any manner incompatible with that purpose

or those purposes,

c) Shall be adequate, relevant and not excessive in relation to those


d) Shall be accurate and, where necessary, kept up to date,

e) Shall not be kept for longer than is necessary

f) Shall be processed in accordance with the rights of data subjects under

the Act,

g) Shall be kept secure by the Data Controller who takes appropriate

technical and other measures to prevent unauthorised or unlawful

processing or accidental loss or destruction of, or damage to, personal


h) Shall not be transferred to a country or territory outside the European

Economic Area unless that country or territory ensures an adequate level

of protection for the rights and freedoms of Individuals/Service Users in

relation to the processing of personal information.

B Bartlett will, through appropriate management and strict application of

criteria and controls:

• Observe fully conditions regarding the fair collection and use of information

• Meet its legal obligations to specify the purposes for which information is


• Collect and process appropriate information, and only to the extent that it

is needed to fulfill its operational needs or to comply with any legal


• Ensure the quality of information used

• Ensure that the rights of people about whom information is held, can be

fully exercised under the Act. These include:

o The right to be informed that processing is being undertaken,

o The right of access to one’s personal information

o The right to prevent processing in certain circumstances and

o The right to correct, rectify, block or erase information which is

regarded as wrong information)

• Take appropriate technical and organisational security measures to

safeguard personal information

• Ensure that personal information is not transferred abroad without suitable


• Treat people justly and fairly whatever their age, religion, disability,

gender, sexual orientation or ethnicity when dealing with requests for


• Set out clear procedures for responding to requests for information

4. Data collection

Informed consent is when

• An Individual/Service User clearly understands why their information is

needed, who it will be shared with, the possible consequences of them

agreeing or refusing the proposed use of the data

• And then gives their consent.

B Bartlett will ensure that data is collected within the boundaries defined

in this policy. This applies to data that is collected in person, or by completing a form.

When collecting data, B Bartlett will ensure that the Individual/Service User:

a) Clearly understands why the information is needed

b) Understands what it will be used for and what the consequences are

should the Individual/Service User decide not to give consent to


c) As far as reasonably possible, grants explicit consent, either written or

verbal for data to be processed

d) Is, as far as reasonably practicable, competent enough to give consent

and has given so freely without any duress

e) Has received sufficient information on why their data is needed and how it

will be used

5. Data Storage

Information and records relating to service users will be stored securely and will only

be accessible to authorised staff and volunteers.

Information will be stored for only as long as it is needed or required statute and will

be disposed of appropriately.

It is B Bartlett responsibility to ensure all personal and company data is

non-recoverable from any computer system previously used within the organisation,

which has been passed on/sold to a third party.

6. Data access and accuracy

All Individuals/Service Users have the right to access the information B Bartlett holds about them. B Bartlett will also take reasonable steps

ensure that this information is kept up to date by asking data subjects whether there

have been any changes.

In addition, B Bartlett

will ensure that:

• It has a Data Protection Officer with specific responsibility for ensuring

compliance with Data Protection

• Everyone processing personal information understands that they are

contractually responsible for following good data protection practice

• Everyone processing personal information is appropriately trained to do so

• Everyone processing personal information is appropriately supervised

• Anybody wanting to make enquiries about handling personal information

knows what to do

• It deals promptly and courteously with any enquiries about handling personal


• It describes clearly how it handles personal information

• It will regularly review and audit the ways it hold, manage and use personal


• It regularly assesses and evaluates its methods and performance in relation to

handling personal information

• All staff are aware that a breach of the rules and procedures identified in this

policy may lead to disciplinary action being taken against them

This policy will be updated as necessary to reflect best practice in data management,

security and control and to ensure compliance with any changes or amendments

made to the Data Protection Act 1998.

In case of any queries or questions in relation to this policy please contact the Data Protection Officer: B Bartlett, Email

Signed: B Bartlett

Position: Director

Date: 03.07.2020

Review Date: 03.01.2020

Glossary of Terms

Data Controller – The person who (either alone or with others) decides what personal

information B Bartlett will hold and how it will be held or used.

Data Protection Act 1998 – The UK legislation that provides a framework for responsible

behaviour by those using personal information.

Data Protection Officer – The person(s) responsible for ensuring that B Bartlett follows its data protection policy and complies with the Data Protection Act 1998.

Individual/Service User – The person whose personal information is being held or

processed by B Bartlett for example: a client, an employee, or supporter.

Explicit consent – is a freely given, specific and informed agreement by an

Individual/Service User in the processing of personal information about her/him. Explicit

consent is needed for processing sensitive data.

Notification – Notifying the Information Commissioner about the data processing activities of

B Bartlett, as certain activities may be exempt from notification.

The link below will take to the ICO website where a self-assessment guide will help you to

decide if you are exempt from notification:

Information Commissioner – The UK Information Commissioner responsible for

implementing and overseeing the Data Protection Act 1998.

Processing – means collecting, amending, handling, storing or disclosing personal


Personal Information – Information about living individuals that enables them to be identified

– e.g. name and address. It does not apply to information about organisations, companies

and agencies but applies to named persons, such as individual volunteers or employees

within (GROUP).

Sensitive data – refers to data about:

• Racial or ethnic origin

• Political affiliations

• Religion or similar beliefs

• Trade union membership

• Physical or mental health

• Sexuality

• Criminal record or proceedings