Learning and mentoring programmes privacy policy
Neuro Diverse Self Advocacy Partnership C.I.C. (“we”, “our”, “us, “the Company”) is a not-for-profit community interest company that runs learning and mentoring programmes.
The mission of our organisation is:
“The support and enablement of Neurodivergent People to lead healthy and fulfilling lives, achieve their life goals and realise their potential in order to achieve equality and fully contribute to society.”
The online learning programmes and the Tool Up mentoring into employment programme are an important part of achieving our mission.
We recognise our duty of care with regards to your data and will always endeavour to do the right thing with the personal data you choose to share with us, including protecting your privacy and storing your data securely.
Our website address is:
Registration data and questionnaires.
To provide you with a good experience and to maximize chances of success we need to ask you a few questions about your circumstances and your preferences. We also need participants’ information to administer and conduct the evaluation of the success of the learning programme and the Tool Up pilot project to make such projects available for more people.
We ask you your name, contact details, your circumstances and interests.
To evaluate the success of the programmes we ask participants to fill out the pre-programme and post-programme questionnaires respectively before, after, 6 and 12 months after the programme. Filling these out is a condition of participating in the programme. At the end of the programme we may also ask you to voluntarily participate in an evaluation interview with our research partners.
The registration and pre-programme and post-programme questionnaires data are processed to administer, manage, evaluate, and improve the programme.
We will also contact you from time to time to inform you of our programmes and events.
Your information will be treated confidentially for the purpose of the programme as described above on the basis of legitimate interest. The data controller is Neurodiverse Self Advocacy Partnership CIC.
Anonymized data will be processed by us and our research partners for the evaluation of results based on legitimate interest.
Your data will not be made available to anyone else except your mentor, if relevant, and in cases of an obvious safeguarding risk, or in cases defined in law with a court order.
Your data will be stored only for so long as is necessary as long as we have a legitimate interest in processing it. You have the right to the copy of your personal data.
The online course.
You have chosen to enrol into one of our online courses or mentoring programmes. The course is an integral part of the mentoring programme. We have a legitimate interest in processing data necessary to enrol you in the relevant course and follow your progress. You will be registered on our Learning Management System to gain access to the relevant online course based on your registration information.
Forum support group
Please note that participation in the forum support group and forum private conversations is the condition of enrolment in the courses or the mentoring programme and we have a legitimate interest in being able to communicate with you through the forum throughout the programme for the purpose of administering the learning or mentoring programme and to inform you of our ongoing activities during and after the programme. Only your username will be publicly visible on the forum and we explicitly ask you not to use your name as a username. The forum allows you to enter more data and display more profile information, but this is entirely based on your explicit choice and consent. You can also delete and modify your additional forum profile information. Your posts on the open forum will be visible to anyone, your posts on the Mentee Café closed forum will only be visible to other mentees and the moderators. We process your forum registration indefinitely unless you request to deregister.
More detail on the general forum GDPR policy that is here: https://ndsa.uk/content/privacy-policy-gdpr/
Public events
We hold video conference events from time to time, which we record for future use on our course or website. If you do not wish to be identified on the video you need to turn off your camera at the event, so that your name and picture will not be visible on the recording. We will store the video as long as it is necessary.
Mentoring programmes
Mentor DBS checks
For safeguarding purposes the mentors will be checked with the Disclosure and Barring Service (DBS) and information about their identity (3 ID documents as described here as a legal requirement https://www.gov.uk/guidance/documents-the-applicant-must-provide) will be processed by us as a legal requirement to input into the DBS system. These data will be destroyed by us once the information has been entered into the DBS system. We will retain the information about the DBS check outcome as long as necessary.
Mentors’ employment.
The mentors will enter onto the payroll of NDSA. We have to collect data about the mentors to administer and manage their employment and payroll. These data are processed based on legitimate interest for as long as necessary.
Mentoring
We will share the mentee’s interests, industry interests, gender and pre programme questionnaires information with their mentor to help them understand mentee’s circumstances and devise most helpful mentoring plans. We will not share the mentee’s surname, email and street address with the mentor. We will not share the same data about the mentor with the mentee
The mentors may be making notes, and will be writing structured reflective reports on their mentoring about the progress, what works and what could be improved. These reports are anonymised, they do not relate to the mentee but are helping the mentor to reflect and plan their sessions. These reports are shared with us based on legitimate interest for the purpose of managing the programme and will be retained for as long as necessary. Report data are confidential and will not be shared with the mentee or anyone else as they do not relate to them and are about mentoring, reflection and planning.
The mentors will receive supervision. Mentor supervisors may be making notes.
The mentors and mentor supervisor’s notes shall be anonymised and stored in password protected files stored securely, and if there no safeguarding concerns will be destroyed by mentor/ supervisors when the mentoring process for a particular mentoring pair ends.
Email communications
We will be entering into email correspondence in the process of application and throughout your learning or mentoring programme. We have a legitimate interest in processing this correspondence that will be retained as long as necessary.
During the programme you will be receiving emails from us (including from the forum) with updates concerning live events and training sessions of the programme you are participating in.
Information security
We are committed to ensuring that any information you provide to us is secure (that doesn’t include the information you disclose in your posts on the open forum, which is public). We use industry standard software and apply security updates. In order to prevent unauthorized access or disclosure, we have put in place suitable measures and procedures to safeguard and secure the information that we collect.
Cookie policy
Cookies are small text files which are set by us on your computer which allow us to provide certain functionality on our site, such as being able to log in, or remembering certain preferences.
We have a detailed cookie policy for the forum and more information about the cookies that we set on this page https://ndsa.uk/forum/help/cookies/.
The cookies policy for the Learning Management Tool UP site are as follows:
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
Cookies are used to improve yours and other users’ experience on our site. They are not collated with the registration information. They enable us to see which aspects of the site and forum are working well and which need improvement, meaning we can improve the site for everyone.
Analytics
Some anonymised, aggregated browsing data is stored by google analytics for the purpose of improving the users experience on our site.
Embedded content from other websites
Articles on our site and forum may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Media
Images you may wish to upload may contain embedded data such as the location of the photo (EXIF GPS). If you do not wish to share this information it is your responsibility to remove it prior to uploading.
Information breach procedure
If our security is breached, our data is compromised, we will tell affected users as soon as we become aware of the failure. If appropriate we will report any data breach to the Information Commissioner and, if appropriate, the police, in a timely fashion.
Where is the data located?
The data is stored on servers in the UK.
Where we send your data
Upon registration your email addresses may be checked by sign up form against a database of known spammers.
Gravatar
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. When you post on the forum, your profile picture is visible to the public in the context of your comment.
Your Rights
You have a right to a copy of the personal data we hold about you. We have up to 30 days in which to respond to your request, however we will endeavour to get back to you as soon as possible. We will notify you within this 30-day period if this time frame will be exceeded.
Please note that the first copy will be free, however, repeat requests in any 12 month period will incur a fee of £25.
If you believe that the information we hold for you is incomplete or inaccurate, you have a right to contact us to ask us to complete or correct that information.
You have the right to ask us to restrict or stop processing your personal data. This would put an end to your participation in any of the programmes you may currently be involved in. For example, if you wish to stop being a member of the forum, you can ask us to stop your registered user status after the completion of the learning or mentoring programme. However, participation on the forum is an integral part of your participation in the programme and deregistering from the forum will put an end to your mentoring. This also applies to the participation in the online course.
You may opt out of us using your email to send you forum newsletters and updates by unclicking the relevant choice on your forum account.
You can also request that we erase any personal data we hold about you. This does not include any data we process based on legitimate interest or are obliged to keep for administrative, legal, or security purposes.
To exercise any of your rights regarding your personal data, please contact us at Toolup@ndsa.uk
Complaints
If you are concerned about how we collect and process your personal data, please contact us in the first instance. We will do our best to address your concerns and resolve any problems. You can contact us on gdpr@ndsa.uk.
Acceptance of this policy
Registration and participation in the learning or mentoring programme and continued use of our site signifies your agreement to this policy. If you do not agree with the policy, then please do not register for the learning or mentoring programmes.
Changes to this policy
We may make changes to this policy at any time without notice. In that case you will be asked to review the information in this policy if it changes in the future. Continued use of the site and participation in the programme will constitute acceptance of new terms.
This policy has been approved on 14/01/2021