How we Process Your Data Through Blossome Activities and Programmes
What information may you be asked to provide
The Blossome CIC activities and programme exists to address an unmet public health need. All activities offer support and social connection with people who have been affected or bereaved by someone else’s alcoholism or addiction. All activities and programmes teach self care, mindfulness and self compassion. Through learning self care and self compassion, you can safeguard and improve your own wellbeing. While the activities and programmes differ in their duration or scope, you may be asked to provide information.
Current Activities and programmes include:
- Self Care for Grieving Hearts
- Sunrise Dips
- Sunrise Mindful Walks
- Mindful Gardening
- Forest Bathing
- Art for Grieving Hearts
- Journalling for Wellbeing
We will never ask for more information about you than is necessary to ensure the quality of the service you receive. An outline of what information may be required is outlined below:
Contact Information – this may include an address, contact telephone number and/or email address depending upon how you enter one of our activities or programmes. This information may be used to create you a membership to access our wellness portal dependent upon which activity or programme you are engaging in and to contact you to progress your request.
Demographic Information – demographic information such as gender and date of birth may be required for certain programmes where such demographic information may impact expected outcomes or to help us understand how programmes outcomes differ so that we can improve our programmes to better serve anyone affected by someone else’s alcoholism or addiction.
GP Details – we may ask you to provide your GP details so we can inform them of your participation, for reporting on positive impacts from community based activities.
Outcomes Related Information – to evidence the impact of our activities and programmes at the individual level and societal level, you may be asked to provide specific information that allows us to understand your current state of health and wellbeing and any subsequent changes as a result of taking part in a programme. These can take the form of questionnaires or objective assessments such as an online self care or self compassion assessment.
You will be fully briefed prior to undertaking any objective assessment to ensure you understand what is involved and the purpose.
Where we may collect your information from
Depending upon the activity or programme you are taking part in, we may collect your information from multiple ways outlined below:
Internet based forms – Some programmes require you to complete an online application form whilst in other flagship programmes, you may be emailed a link to a secure online form to complete more detailed information that may be used to progress you through different stages of a flagship programme.
Email – In some programmes or after activities, you may receive an email with a secure link to complete an online questionnaire to help us understand how a programme might be affecting you.
Telephone / Video call – Some information may be recorded by our staff as part of a telephone call or video call such as the Video Welcome or coaching calls.
Why we need this information and how we might use it
We are required to collect the information that we have outlined above for a number of different purposes which are listed below and will vary depending on which programme you are taking part in.
Identifying individuals – The individual delivering your flagship will need to identify you in the result that any results or questionnaire responses require follow-up or where they need to contact you with regard to the delivery of the flagship programme you are taking part in.
Account creation – Some programmes will provide you with an account for an online self care portal, to support you and track your progress through a flagship programme to ensure you receive the correct communications or questionnaires at the correct time points.
Billing – Whilst some flagship programmes are delivered for free, others are delivered at cost price which may be paid for either by the individual or by an organisation such as your Employer.
Evidencing Impact – All programmes exist to improve the health and wellbeing of the individuals they service. To allow us to continually assess the impact
Research – One way we can help improve the health of the nation is to be open and transparent about our programmes, detailing how they are conducted and how they might affect the individuals who take part. One way to achieve this is to publish anonymised data from our programmes as research studies. We will always ask for your consent before using your anonymised data for research purposes. Please note that this is not a data protection consent. No research will take place without prior ethical approval from an academic institution.
When things go wrong
Blossome CIC pride ourselves with the quality of our services and consistent positive community satisfaction, however, we understand that in a small number of cases you may have cause to raise a concern regarding an element of your self care journey. It is important that Blossome CIC learn from these episodes to continually enhance services and as such we carry out thorough investigations. In order to fully investigate your concern, we may need to share information with our compliance team, senior programme leaders or other parties not directly involved with your participation. For example, if you were referred to a Programme such as the Self Care for Grieving Hearts via your GP, we might need to discuss your concern with your GP in order to fully investigate it. In any case, we will only share a limited amount of information, as little as is necessary to investigate the concern. We may also need to share details of your concern with your clinician, rehabilitation specialist or other professionals involved in your care for the purposes of the investigation.
Who your Personal Data may be shared with
There are variations on who your data may be shared. These differences are outlined below.
Bill payer – Where a programme has an associated cost to take part, we may share some data with the bill payer as part of an agreed service delivery specification. We will never share more data than is absolutely necessary.
Employer – Where you may have been referred to take part in a programme from your employer, we may share anonymised, aggregated data with them with your prior consent. We will never share more data than is absolutely necessary.
GP – With your prior consent, we may share relevant data with your GP to ensure continued wellbeing support or to inform your GP of your inclusion, exclusion or completion of any programme. We will never share more data than is absolutely necessary.
For research purposes – Where data from a programme may be used for the purposes of research, we may share anonymised data with a third party for the purposes of conducting research. This may include academic institutions. Please note, no data will be shared without your consent.
Fair and Lawful Processing
Each organisation is required to demonstrate that they are processing personal data fairly and lawfully, to do this we must have a ‘lawful basis for processing’ personal data.
For the purpose of delivering programmes, Blossome CIC will mainly be processing data based on the following lawful basis for processing:
- The data subject has given consent to the processing of his or her personal data for one of more specific purpose
- Processing is necessary for the performance of a contract to which the individual is party or in order to take steps at the request of the individual prior to entering into a contract.
- Legitimate interests: the processing is necessary because of a legitimate interest or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
What does this actually mean?
In order to provide you with the level of support agreed to in our contracts in a safe and effective way we need to process the data discussed, and as such, we are doing so lawfully. This means we may not always ask your consent each time we use your data if what we are doing is linked to your treatment or doing something we must do by law.
Your rights in respect of your Personal Data
The law gives you certain rights in respect of the information that we hold about you. Below is a short overview of the key rights available to you.
Data Subject Access Request – with some exceptions designed to protect the rights of others, you have the right to a copy of the personal data that we hold about you. Where the data is data that you have given to us, you have the right to receive your copy of it in a common electronic format, and to provide copies of it to other people if you wish (Right to Data Portability).
Right to Rectification – you have the right to have the personal data we hold about you corrected if it is factually inaccurate. This right does not extend to matters of opinion, such as assessments of performance or fitness to work.
Right to Erasure – in some limited circumstances, you have the right to have personal data that we hold about you erased (the “right to be forgotten”). This right is not generally available where we still have a valid legal reason to keep the data (for example, because we are obliged to do so by law).
Right to Restrict Processing – you also have the right in some circumstances to request that temporary restrictions are placed on how we process your personal data, for example if you contest its accuracy or where we are processing it on the basis of our legitimate interest and you contest our assessment that our interest overrides your rights.
The above is not a complete and exhaustive statement of the law.
How long we will keep your Personal Data for
The length of time that Personal Data is stored is set by national legislation. Where your data is collected as part of a programme such as the JSelf Care for Grieving Hearts programme or other, it may form the basis of anonymised research publications if you have given consent for your data to be used as such. In this instance, your personal data may be held for up to 10 years.
For further information about how your data may be processed or to ask any questions please raise this with the member of staff delivering your programme who can direct your query to the relevant persons within the Team. If you are not satisfied with how we handle your personal data or a request to exercise one of your rights in relation to your data, you can contact the Data Protection Officer on [email protected]
Should you remain dissatisfied you have a right to complain to the Information Commissioner’s Office on 0303 123 1113 or through their website.