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Privacy and Cookies Policy

At a glance

This policy explains:

✓ What information ABF collects

✓ Why we collect it

✓ How we protect it

✓ When we may share it

✓ Your rights

✓ How to contact us

Welcome

At Advance Brighter Futures (ABF), we understand that when you contact us for support, attend one of our services, volunteer, donate or visit our website, you are placing your trust in us.

Protecting your privacy is important to us. We are committed to handling your personal information with care, respect and transparency. We will only collect the information we need, explain why we need it, keep it secure and only use or share it where there is an appropriate and lawful reason to do so.

This Privacy and Cookies Policy explains:

  • what personal information we collect;

  • why we collect it;

  • how we use it;

  • who we may share it with;

  • how we protect it;

  • how long we keep it;

  • your rights; and

  • how to contact us if you have any questions or concerns.

We aim to make this policy easy to understand. If anything is unclear, please contact us and we will be happy to explain it.

Who this policy applies to

This policy applies to anyone whose personal information Advance Brighter Futures collects or processes, including:

  • people who access or enquire about our mental health and wellbeing services;

  • children and young people;

  • parents, carers and people with parental responsibility;

  • people referred to us by another organisation;

  • professionals making referrals;

  • training participants;

  • donors, fundraisers and Friends of ABF members;

  • staff, volunteers and trustees;

  • job applicants;

  • contractors and partner organisations; and

  • visitors to our website and social media pages.

We may provide additional privacy information for particular services, activities or groups of people where this helps explain how their information is used.

For example, we provide or may provide specific privacy information for:

  • children and young people;

  • parents and carers;

  • staff and volunteers; and

  • people applying to work or volunteer with ABF.

These additional notices should be read alongside this policy where they apply.

Who we are

Advance Brighter Futures (ABF) is a registered charity and company limited by guarantee based in Wrexham. We provide mental health and wellbeing services, support, training and community projects across North East Wales.

For the purposes of data protection law, Advance Brighter Futures is the data controller. This means ABF is responsible for deciding why and how personal information is processed.

Advance Brighter Futures
3 Belmont Road
Wrexham
LL13 7PW

Telephone: 01978 364777
Email: info@abfwxm.co.uk

Registered Charity Number: 1089638
Company Registration Number: 04052135

If you have questions about this policy or about how ABF uses your personal information, please contact our Chief Officer, who has responsibility for overseeing data protection within ABF.

What information we collect

The personal information we collect depends on your relationship with ABF and the service or activity you are involved with. We aim to collect only information that is relevant and necessary for the particular purpose.

Personal and contact information

This may include:

  • your name;

  • date of birth or age;

  • address;

  • telephone number and email address;

  • preferred name, pronouns or communication preferences;

  • emergency contact details; and

  • information about a parent, carer, advocate, representative or other person involved in your support, where appropriate.

Information about your support and wellbeing

If you enquire about or access one of our services, we may collect information that helps us understand your circumstances, decide whether a service is appropriate and provide safe and effective support.

Depending on the service, this may include:

  • information about your mental health and emotional wellbeing;

  • relevant physical health information;

  • the reasons you have contacted or been referred to ABF;

  • your goals, needs and circumstances where relevant to your support;

  • information about other services or professionals involved in your support;

  • risk or safeguarding information where necessary;

  • assessments and outcome measures;

  • appointments, attendance and engagement with our services;

  • notes and records about the support we provide; and

  • feedback about your experience of our services.

Some of this information, particularly information about health, ethnicity or other sensitive aspects of your circumstances, is given additional protection under data protection law.

Equality and monitoring information

We may ask for information such as ethnicity, gender identity or other equality and monitoring information. This helps us understand who is accessing our services, identify whether particular communities are being reached and meet appropriate monitoring or commissioning requirements.

Providing equality and monitoring information is normally optional and choosing not to answer will not normally affect the support you receive.

Wherever possible, information used for statistical monitoring and reporting is anonymised or aggregated so that individuals cannot be identified.

Safeguarding information

Where there is a concern about the safety or welfare of a child, young person or adult, we may record information necessary to understand, manage and respond to that concern.

This may include information provided by you or by other people or organisations involved in the situation.

Training, fundraising, donations and events

If you attend training, make a donation, become a Friend of ABF, fundraise for us or take part in an event, we may collect information needed to administer your involvement.

This may include contact details, booking or attendance information, payment or donation information and relevant communication preferences.

Staff, volunteers and job applicants

If you work or volunteer for ABF, or apply for a role with us, we collect additional information necessary for recruitment, employment, volunteering, safeguarding and organisational administration.

This may include employment history, qualifications, references, right-to-work information, payroll and pension information, emergency contacts, training and performance information and, where appropriate, health information and information relating to criminal-record checks.

More detailed information about this processing is provided in our Staff and Volunteer Privacy Notice and Recruitment Privacy Notice.

Website information

When you use our website, we may collect limited technical information about your visit, including information about your device or browser and your cookie preferences.

Further information is provided in the Cookies section of this policy.

How we receive your information

Most of the personal information we hold is provided directly by you when you:

  • contact us for information, advice or support;

  • complete a referral or registration form;

  • attend one of our services, groups, training courses or events;

  • communicate with a member of the ABF team;

  • make a donation, fundraise for us or become a Friend of ABF;

  • volunteer with us;

  • apply for a job or volunteering opportunity; or

  • contact us through our website, email, telephone or social media.

We may also receive personal information about you from another person or organisation. Depending on the circumstances, this may include:

  • your GP or another healthcare professional;

  • NHS Wales services, including Betsi Cadwaladr University Health Board;

  • Wrexham County Borough Council or another local authority;

  • a school, college or other education provider;

  • another charity or community organisation;

  • a parent, carer or person with parental responsibility;

  • an advocate or representative;

  • another professional involved in your support;

  • an organisation referring you to one of our services; or

  • referees and other relevant organisations where you apply to work or volunteer with us.

Where someone makes a referral to ABF on your behalf, we normally expect them to have discussed the referral with you beforehand and to have told you that relevant information will be provided to ABF.

There may be exceptional circumstances where information is provided to us without your prior knowledge, for example where there is a safeguarding concern or another lawful reason for doing so.

Where we receive personal information about you from someone else, we will provide appropriate information about how ABF uses your personal information, unless an exception under data protection law applies.

How we use your information

ABF uses personal information to provide and manage our services and activities safely, effectively and appropriately.

Depending on your relationship with ABF, we may use your information to:

  • respond to enquiries and referrals;

  • review referrals and assess whether a service is suitable for you;

  • provide mental health and wellbeing support;

  • plan, record and review the support we provide;

  • communicate with you about appointments, activities, training or other services;

  • record attendance and engagement with our services;

  • use appropriate assessments and outcome measures to understand progress and evaluate the support we provide;

  • work with other people or organisations involved in your support where appropriate;

  • identify and respond to safeguarding concerns and risks to you or other people;

  • monitor, evaluate and improve the quality and effectiveness of our services;

  • meet appropriate reporting requirements for organisations that fund or commission our services;

  • produce anonymised or aggregated information about the people who use our services and the outcomes achieved;

  • manage training, events, donations, fundraising activities and Friends of ABF membership;

  • recruit, support and manage staff, volunteers and trustees;

  • manage complaints, concerns and requests relating to personal information;

  • meet our legal, regulatory, financial, safeguarding, contractual and commissioned-service responsibilities; and

  • protect the rights, safety and wellbeing of the people we support, our staff, volunteers and others.

Wherever possible, information used for statistical reporting, monitoring and evaluation will be anonymised or aggregated so that individuals cannot be identified.

Some commissioned services require ABF to provide limited identifiable information to the organisation funding or commissioning the service. Where this applies, we will explain what information is required and why through the relevant service or privacy information.

We will not use personal information for a new purpose that is incompatible with the reason it was originally collected unless we have an appropriate lawful reason for doing so.

Respecting your choices

We believe that being open about how we use your information is an important part of building trust.

Wherever possible, we will explain:

  • why we are asking for information;

  • how it will be used;

  • whether providing it is required or optional; and

  • who it may be shared with, where relevant.

We will respect your choices where there is a genuine choice about how your information is used. For example, some equality monitoring questions may be optional, and we may ask for your consent before using photographs, sharing a personal story or sending certain communications.

There are other situations where ABF needs to use personal information in order to provide or manage a service, meet a legal or contractual responsibility, respond to a safeguarding concern or for another lawful purpose. In these circumstances, we will explain why the information is needed and the legal reason we rely on.

Agreeing to receive support or take part in a service is not necessarily the same as ABF relying on your consent as its legal basis for processing your personal information.

We encourage you to tell us if information we hold about you is inaccurate or has changed.

If you are unsure why we are asking for particular information, please ask us and we will explain.

The legal reasons we use your information

Data protection law requires ABF to have a lawful reason for using personal information. The lawful basis we rely on depends on why we are using the information.

Legitimate interests

We may use personal information where it is necessary for the legitimate interests of ABF or another person, provided those interests are not overridden by your rights and interests.

This may include using information to:

  • respond to enquiries and referrals;

  • assess whether our services are suitable;

  • provide and manage appropriate support;

  • maintain appropriate records;

  • monitor and improve our services;

  • manage our organisation effectively; and

  • protect the rights and safety of the people we support, our staff, volunteers and others.

Where we rely on legitimate interests, we consider the purpose of the processing, whether it is necessary and the potential impact on the people whose information is involved.

Recognised legitimate interest

Data protection law identifies certain recognised legitimate interests where personal information may be used for specified purposes in the public interest. These include certain safeguarding, emergency, crime-prevention and public-task information-sharing situations.

ABF will only rely on this lawful basis where the particular processing meets the conditions set out in data protection law.

Contract

We may use personal information where it is necessary to enter into or carry out a contract with you.

This may apply, for example, to some employment, training, booking or other contractual arrangements.

Legal obligation

We may use personal information where we need to comply with a legal obligation.

This may include employment, taxation, financial, safeguarding or regulatory requirements and responding to legally binding requests.

Vital interests

In exceptional circumstances, we may use or share personal information where this is necessary to protect someone's life and the person concerned is unable to give consent.

Public task

In some circumstances, processing may be necessary for a task carried out in the public interest or in the exercise of official authority.

We will only rely on this basis where it applies to the particular activity and ABF has an appropriate basis in law for doing so.

Consent

Where you have a genuine choice about whether particular processing takes place, we may ask for your consent.

This may include:

  • using identifiable photographs or videos;

  • publishing an identifiable personal story or case study;

  • sending certain marketing or fundraising communications; or

  • other optional uses of information where consent is the appropriate lawful basis.

Where we rely on consent, you can withdraw it at any time. Withdrawing consent will not affect processing that took place lawfully before it was withdrawn.

Sensitive or special category information

Some personal information receives additional protection under data protection law. This is known as special category data and includes information about matters such as health, ethnicity, religious or philosophical beliefs, sexual orientation and some other particularly sensitive information.

Because ABF provides mental health and wellbeing services, we may need to process health information and other special category information where it is relevant to the support we provide.

Where we process special category information, we must have both a lawful basis for using the information and an additional legal condition that allows us to process this type of information.

Depending on the purpose and the circumstances, data protection law provides a number of possible conditions. These can include processing necessary for health or social care, employment and social protection obligations, substantial public interest reasons, legal claims, protecting someone's vital interests, or processing based on explicit consent where appropriate. ABF will identify and document the appropriate condition before relying on it.

We only process special category information where it is necessary and there is an appropriate legal basis for doing so.

When we may share your information

We know that trusting someone with personal information can feel difficult, particularly when you are asking for support. We will always aim to be open with you about how your information is used and shared.

We do not sell your personal information.

We only share personal information where there is an appropriate and lawful reason to do so, and we aim to share only the information that is necessary for the particular purpose.

Depending on the circumstances, we may share relevant information with:

  • your GP or another healthcare professional;

  • NHS Wales services, including Betsi Cadwaladr University Health Board;

  • Wrexham County Borough Council or another local authority;

  • schools, colleges or other education providers;

  • charities, community organisations or other services involved in your support;

  • organisations that fund or commission our services;

  • safeguarding services or agencies;

  • emergency services or the police;

  • regulators, auditors, professional advisers or other organisations where disclosure is required or appropriate;

  • organisations that provide systems or services to ABF, such as our database, website, communications and other IT providers; and

  • other people or organisations where you have asked us, or given appropriate consent, to share information.

We consider what information needs to be shared, why it needs to be shared and whether there is an appropriate legal basis before making a disclosure.

Where another organisation processes personal information on ABF's behalf, we take appropriate steps to ensure that the information is protected and that suitable data-protection arrangements are in place.

Some of our services are funded or commissioned by other organisations. We provide anonymised or aggregated information for monitoring and reporting wherever this will meet the purpose.

In some commissioned services, however, we may be required to provide limited identifiable information about people using the service. Where this applies, we will explain the relevant sharing through the service information or an additional privacy notice.

Confidentiality and safeguarding

We understand that people may share sensitive and personal information with us when receiving support. We treat this information confidentially and explain the limits of confidentiality where appropriate.

We will not routinely share information about your support with family members, friends or other people simply because they ask us for it.

There are circumstances where we may need to share relevant information without first obtaining your consent. This may include where:

  • we are concerned that a child or young person may be at risk of harm;

  • we are concerned that an adult may be at risk of abuse or neglect;

  • there is a serious risk of harm to you or another person;

  • we are required to disclose information by law or by a court;

  • information is needed in connection with the prevention or detection of serious crime; or

  • another lawful safeguarding or protective reason applies.

Where we are considering sharing information because of a safeguarding or safety concern, we will consider the circumstances carefully and share only information that is relevant and necessary.

Wherever it is appropriate and safe to do so, we will explain the proposed sharing to you. There may be circumstances where we cannot tell you beforehand, for example if doing so could increase a risk of harm, prejudice an investigation or otherwise be inappropriate or unlawful.

We record significant safeguarding decisions and the reasons for them in accordance with our safeguarding and information-governance procedures.

Supporting children and young people

ABF provides some services specifically for children and young people. We recognise that children and young people have their own rights in relation to their personal information and that information about mental health and wellbeing can be particularly sensitive.

We aim to explain how we use personal information in a way that is appropriate to the young person’s age and understanding. We may provide additional, child-friendly privacy information for services involving children and young people.

Consent, understanding and involvement

When a child or young person accesses one of our services, we will consider their age, understanding and ability to make informed decisions about their support and personal information.

Depending on the service and the circumstances, we may also need to involve a parent, carer or person with parental responsibility.

Where parental consent is required for a particular service, we will explain this as part of the referral or registration process.

We will also seek to involve the child or young person in decisions about their support and information in a way that is appropriate to their age and understanding.

Parents and carers

We recognise the important role that parents and carers can have in supporting a child or young person.

However, being a parent, carer or person with parental responsibility does not necessarily mean that all information a young person shares with ABF will automatically be disclosed to them.

What information can be shared will depend on the young person’s age and understanding, the nature of the service, confidentiality, parental responsibility, safeguarding considerations and the particular circumstances.

We will explain how confidentiality works as clearly as possible when support begins.

Safeguarding

The safety and welfare of children and young people is very important to us.

If we are concerned that a child or young person, or another person, may be at risk of harm, we may need to use or share relevant information to respond to that concern.

Wherever it is appropriate and safe to do so, we will explain this to the child or young person and, where appropriate, their parent or carer.

More information about how we use personal information when supporting children and young people is available in our Young Person’s Privacy Notice and, where relevant, our Parent/Carer Privacy Notice.

Keeping your information secure

ABF takes the security of your personal information seriously.

We take appropriate steps to protect personal information against loss, misuse, unauthorised access, alteration or disclosure.

The measures we use depend on the nature of the information, the systems involved and the risks associated with the processing. These include, where appropriate:

  • restricting access to personal information to people who need it for their role;

  • using passwords, access controls and additional authentication measures to protect systems and accounts;

  • securely storing electronic records and maintaining appropriate backup arrangements;

  • requiring staff, volunteers and others working on behalf of ABF to respect confidentiality;

  • providing appropriate data protection and information-security training;

  • maintaining policies and procedures for handling personal information securely;

  • taking appropriate steps when using organisations that process personal information on our behalf; and

  • reviewing our security arrangements and responding to identified risks or incidents.

Staff and volunteers are expected to report suspected loss, unauthorised disclosure or other personal-data security incidents promptly so that ABF can investigate and take appropriate action.

Although no system can be guaranteed to be completely secure, we take reasonable and appropriate measures to reduce the risk of personal information being lost, misused or accessed without authorisation.

How long we keep your information

We keep personal information only for as long as it is reasonably necessary for the purpose for which it was collected, and to meet any relevant legal, safeguarding, contractual, financial, regulatory or other legitimate requirements.

Different types of information need to be kept for different periods. ABF maintains a retention schedule which sets out how long different categories of records should normally be kept and what should happen to them at the end of that period.

When deciding an appropriate retention period, we consider the purpose for which the information is held, the nature and sensitivity of the information, relevant legal or regulatory requirements, safeguarding considerations and whether there is a continuing need to retain an identifiable record.

At the end of the relevant retention period, information will normally be securely deleted, destroyed or anonymised unless there is an appropriate reason for keeping it for longer.

If you would like information about the retention period that applies to a particular type of record, please contact us.

Your data protection rights

Data protection law gives you a number of rights over your personal information. Which rights apply will depend on the circumstances and the legal reason ABF is relying on to use your information.

Depending on the circumstances, you may have the right to:

  • access your personal information – ask us for a copy of the personal information we hold about you;

  • correct your personal information – ask us to correct information you believe is inaccurate or complete information you believe is incomplete;

  • delete your personal information – ask us to erase your personal information in certain circumstances;

  • restrict how we use your personal information – ask us to limit the way we use it in certain circumstances;

  • object to how we use your personal information – object to certain types of processing, including processing based on legitimate interests;

  • data portability – ask us to provide certain information to you, or another organisation, in a suitable electronic format where this right applies; and

  • withdraw consent – where we rely on your consent, you can withdraw it at any time. This will not affect processing that took place lawfully before consent was withdrawn.

There are exemptions and limitations to some of these rights. This means that we may sometimes have a lawful reason to continue holding or using information even where you have asked us to delete it, restrict its use or stop processing it.

If we cannot fully comply with a request, we will explain the reason unless the law prevents us from doing so.

How to exercise your rights

You do not normally need to complete a particular form to exercise your data protection rights.

You can contact us by:

Email: info@abfwxm.co.uk
Telephone: 01978 364777
Post: Advance Brighter Futures, 3 Belmont Road, Wrexham, LL13 7PW

Please provide enough information for us to understand your request and identify the information concerned.

We may need to ask for information to confirm your identity, particularly where this is necessary to protect personal information from being disclosed to the wrong person.

We will respond without undue delay and normally within one month of receiving your request. In some circumstances the law allows us to extend this period. If this applies, we will let you know.

You will not normally have to pay a fee to exercise your rights. However, data protection law allows a reasonable fee to be charged, or a request to be refused, in certain limited circumstances.

If you have a question or concern

If you have a question or concern about how ABF has used your personal information, please contact us. We would welcome the opportunity to understand your concern and try to resolve it.

You can contact:

Chief Officer
Advance Brighter Futures
3 Belmont Road
Wrexham
LL13 7PW

Email: info@abfwxm.co.uk
Telephone: 01978 364777

Please provide as much information as you reasonably can about your concern, such as what has happened, relevant dates and what you would like us to consider. You do not have to use a particular form to make a data protection complaint.

We will acknowledge your complaint, investigate it appropriately and keep you informed about its progress.

If your complaint concerns the Chief Officer, it will be referred to the Chair of Trustees or another appropriately nominated trustee rather than being investigated by the Chief Officer.

You also have the right to raise a concern with the Information Commissioner's Office (ICO), the UK's independent regulator for data protection.

External websites

Our website may contain links to websites operated by other organisations.

When you follow a link to another organisation's website or service, that organisation may collect and use personal information in accordance with its own privacy information. ABF is not responsible for the privacy practices or content of external websites that we do not control.

We encourage you to read the privacy information provided by the relevant organisation before providing personal information to them.

Social media

ABF uses social media to communicate about our work, services, events and activities.

If you interact with ABF through a social media platform, for example by following our account, commenting on or sharing a post, or sending us a direct message, both ABF and the operator of the social media platform may process information about that interaction.

The social media provider will process personal information in accordance with its own privacy information and settings.

Please remember that information you post publicly on social media may be visible to other people.

If you contact us through social media about a personal, sensitive or confidential matter, we may ask you to continue the conversation through a more appropriate communication method.

We will not normally use information obtained through social media for an unrelated purpose without an appropriate lawful reason.

Cookies

This section will be completed following ABF's website and cookie-consent audit.

Contact us

If you have any questions about this policy, how ABF uses your personal information or your data protection rights, please contact:

Chief Officer
Advance Brighter Futures
3 Belmont Road
Wrexham
LL13 7PW

Telephone: 01978 364777
Email: info@abfwxm.co.uk

Advance Brighter Futures is the data controller for the personal information described in this policy, except where we specifically explain that another organisation is responsible for particular processing.

Our commitment to privacy

We know that people trust ABF with personal and sometimes very sensitive information.

We are committed to treating that information with care and respect, being open about how we use it, keeping it appropriately secure and continually reviewing how we protect people's privacy.

We will review this policy periodically and update it where our services, practices or legal requirements change.

Last reviewed: 16 September 2026
Next review due: September 2027

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