Our Privacy Policy
We are committed to protecting your personal data and privacy.
This Privacy Notice sets out how Team Sunflower Limited (TS) collects and handles personal information in accordance with the Data Protection Act 2018 including the General Data Protection Regulation (UK GDPR). It has been prepared with reference to the list of requirements for privacy notices published by the Information Commissioner’s Office at:
1. Personal data that we process
Personal data, or personal information, means any information that relates to an individual from which that person can be identified. For example, a name, an email address or IP address.
The following list sets out the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed.
a) Purpose: Enquiring about our business and its work by telephone or electronic message
Data collection: Name, email, message
Basis for data processing: Consent - it is necessary for us to read and store your message and personal details so that we can respond in the way that you would expect. By contacting us and providing your information you are consenting for that data to be processed by us.
b) Purpose: Applying for funding on your behalf and fulfilling the requirements set out in that request for funding
Data collection: data provided by you in relation to your employment, capabilities and health (physical or mental), in person or via phone or electronic message.
Basis for data processing: Contract – it is necessary for us to collect and process this data in order to fulfil our obligations as agreed with you, including applying for funding on your behalf, matching support workers/mentors or employers with clients or sourcing mental health support.
c) Purpose: Recruiting freelance support workers/mentors or employers and matching them to clients
Data collection: data provided by potential support workers/mentors/employers in relation to your education, experience, employment and suitability for the role; self-employment data (eg Unique Tax References) and bank details.
Basis for data processing: Contract – it is necessary for us to collect and process this data in order to fulfil our obligations as agreed with you, including matching support workers/mentors/employers with clients and processing payment for work you invoice us for.
d) Purpose: Website functionality
Data collection: Website contact form
Basis for data processing: Consent - the only data we collect via our website is what you actively provide when you use the contact form to email us. See point a) above.
e) Purpose: Website usage
Data collection: Website activity collected through cookies
Basis for data processing: The statistical information we collect about use of our website is anonymous. We do not collect personally identifiable data of website users. See section 6 below for more information about cookies.
f) Purpose: Progress monitoring and reporting
Data collection: Meeting notes and reports
Basis for data processing: Contract – we use this data to deliver and improve our service as agreed with you.
2. How we use and store your data
We will only use your data in a manner that is appropriate, considering the basis on which that data was collected, as set out in section 1 of this notice.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis upon which we are doing so. We may process your personal data without your knowledge or consent, in compliance with legislation, where this is required or permitted by law or where we judge that an individual’s safety may be at risk.
We will store your data securely so that it cannot be accessed by anyone who does not have a right to access it. For data stored electronically we will use encryption and password-protected files and for data stored physically we will ensure it is held in a lockable store when not in use.
3. When we share your data
We will only pass your data to third parties in the following circumstances:
● where you have provided your explicit consent for us to pass data to a named third party (for example Access to Work, a support worker, counsellor or supplier working on our behalf);
● where we are using a third party purely for the purposes of processing data on our behalf and we have in place a data processing agreement with that third party that fulfils our legal obligations in relation to the use of third party data processors; or
● we are required by law to share your data.
Under the GDPR and Data Protection Act 2018 we may share information without consent if, in our judgement, there is a lawful basis to do so, such as where safety may be at risk.
In addition, we will only pass data to third parties outside of the EU where appropriate safeguards are in place as defined by Article 46 of the General Data Protection Regulation.
Any commercially sensitive business data that is shared with us will be treated in the strictest confidence.
We will not share data or images relating to you and your business on our website or social channels without first obtaining your consent.
4. How long we keep your data
We take the principles of data minimisation and removal seriously we will only ever ask for the minimum amount of data for the associated purpose, be that a legal, reporting or accounting requirement. We will delete that data promptly once it is no longer required.
Where data is collected on the basis of consent, we will seek renewal of consent at least every three years. eg. for email marketing purposes
Where data relating to a client has been collected in order for us to apply for and fulfil support for them, we will retain that data as long as the individual remains our client.
Where data relating to a support worker/mentor/employer has been collected in order for us match them to a client, we will retain that data as long as the individual continues working for us.
5. Rights you have over your data
The data we collect is your personal data and you have rights, subject to lawful data requirements, including:
● Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example by putting ‘unsubscribe’ links at the bottom of any marketing emails).
● You have the right to ask for rectification and/or deletion of your information.
● You have the right of access to your information.
● You have the right to object or ask us to restrict the processing of your data in certain circumstances
● You have the right to lodge a complaint with the Information Commissioner if you feel your rights have been infringed.
A full summary of your legal rights over your data can be found on the Information Commissioner’s website here: https://ico.org.uk/
If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us – contact details are in section 7 below.
Please note that relying on some of these rights, such as the right to deleting your data, will make it impossible for us to continue to deliver some services to you. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible.
6. Website cookies & usage tracking
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, eg counting the number of people looking at a website.
Where cookies are used to collect personal data, we will list these purposes in section 1 above, along with other personal data that we collect. However, we currently only use cookies that do not collect personal information but that do help us collect anonymous information about how people use our website. We use Google Analytics for this purpose. Google Analytics generates statistical and other information about website usage by means of cookies, which are stored on users' computers. The information collected by Google Analytics about usage of our website is not personally identifiable. The data is collected anonymously, stored by Google and used by us to create reports about website usage. Google's privacy policy is available at http://www.google.com/privacypolicy.html.
7. Modifications
We may modify this Privacy Policy from time to time and will publish the most current version on our website. If a modification meaningfully reduces your rights, we'll notify people whose personal data we hold and is affected.
8. Complaints and queries
For any queries relating to your data please email jane@team-sunflower.co.uk
If you want to make a complaint about the way we have processed your personal data please contact us in writing at Team Sunflower Limited, 3 High Bank Cottages, Bywell, Stocksfield, Northumberland NE43 7AG.
Last updated: 1 April 2023
