The Brave Project C.I.C (“The Brave Project”, “we”, “us”) collect data in order to provide our services and fulfil our responsibilities in accordance with data protection legislation. This privacy notice will give you more information about how and why we collect your personal information and the purposes for which we use it.

We may update this notice from time to time to reflect changes to applicable laws or to the ways that we handle your personal data. We will let you know if we make any material changes to this notice.

If you are under 18, please read our section “What happens if I’m a minor?” which has further details of how we use and safeguard your personal information.

This policy was last updated on 29th August 2023.

Contents

Who is responsible for processing your personal data?. 1

What type of personal data do we process?. 2

Where do we collect your personal data from?. 3

Why do we process your personal data and what are our lawful bases to do so?. 3

Who do we share your personal data with?. 4

Is your data transferred to other countries?. 4

How long do we store your data?. 4

What rights do you have?. 4

What happens if you do not wish to provide us with your personal data?. 5

Do you carry out automated decision making?. 5

Questions and complaints. 6

What happens if I am a minor?. 6

Who is responsible for processing your personal data?

We act as data controllers of your personal data, that means that we determine the purposes for and the manner in which your personal data will be processed. Our contact details are:

The Brave Project Community Interest Company

Office 292

182-184 High Street North 

London E6 2JA

[email protected]

07862003544

If you have any questions about how your personal data is processed by The Brave Project, or if you want to exercise any of your rights, please contact us for more details.

What type of personal data do we process?

In connection with the provision of our services, we will collect and process personal data of the following groups:

Service Users

If you decide to use our services, we will process your personal data, including:

• your full name, date of birth and contact details (including postal address, telephone number and email address);
• details of your gender identity;
• details of your employment status;
• details of your living arrangements and whether you have any dependents or carers.
• details of your marital status; and
• any other personal information you provide to us during the provision of our services, including case details and interview notes.

We will also process special categories of personal data about you, which we do in order to provide you with our services. These may include:

• details of your racial identity or ethnic group;
• health details such as whether you are registered with a GP and if you have accessed mental health/wellbeing support services before; and
• any additional health details that you choose to share with us so we can accommodate any special requirements (e.g., ensuring that the venue we use is wheelchair accessible).

Freelancers

If you collaborate with us to organise activities and/or workshops for our service users, we will process your personal data, including:

• your full name, title, and contact details (including postal address, telephone number and email address);
• name of the organisation you work for;
• details necessary to carry out or verify a DBS check, including ID documents; and
• information included in your CV.

We may also process special categories of personal data and/or criminal record data about you. These may include:

• DBS check results; and
• any health details that you choose to share with us so we can accommodate any special requirements (e.g., ensuring that the venue we use is wheelchair accessible).

Volunteers

If you volunteer with us, we will process your personal data, including:

• your full name, title, and contact details (including postal address, telephone number and email address);
• information included in your CV;
• details necessary to carry out a DBS check, including ID documents; and
• any health details that you choose to share with us so we can accommodate any special requirements (e.g., ensuring that the venue we use is wheelchair accessible).

We may also process special categories of personal data [and/or criminal record data] about you. These may include:

• DBS check results; and
• any health details that you choose to share with us so we can accommodate any special requirements (e.g., ensuring that the venue we use is wheelchair accessible).

When we collect any special category data (such as race and ethnicity details, gender identity or any data concerning health) and criminal record data, these require higher levels of protection under data protection laws. For further information please see the section below.

Where do we collect your personal data from?

We collect your personal data directly from you when necessary, including when:

• you visit our website;
• you engage with us through our social media channels (TikTok, Instagram, Twitter, Facebook);
• you complete one of our surveys;
• you provide us with feedback on our services;
• if you are a service user, when you complete one of our self-referral forms;
• if you collaborate with us as a freelancer, when we engage your services; and
• if you volunteer with us, when you complete the application form as well as any additional personal data you share with us during your time with The Brave Project.

We may also receive the personal data detailed above from third parties such as family members and third party organisations (such as partner organisations and related charities).

Why do we process your personal data and what are our lawful bases to do so?

We will only process your personal data where we have a lawful basis to do so. We will usually rely on one of the following lawful bases for our processing:

1. For the performance of a contract we have with you, for example if you are a freelancer for us, to enable us to pay you.

1. For ensuring compliance with our legal obligations, for example to allow us to check that you have the right to work in the UK.

1. For our legitimate interests (or those of a third party), provided your interests and fundamental rights do not override those interests, for example:
   • in order to provide you with our services and help you as best we can;
   • to enable us to manage our services effectively; and
   • to advertise and make our services known to those who may benefit from it;
   • to determine whether potential volunteers have the required skills and experience to assist us.

1. With your consent, for example, if we decided to engage in direct marketing.

In the case of special categories of personal data (such as information about your health, race and ethnicity data) and criminal convictions data extra protections apply under data protection legislation. We therefore only process special category personal data in the following circumstances:

• where it is necessary for the purposes of performing or exercising obligations or rights under applicable law;
• where it is necessary in order to establish, exercise or defend legal claims (or potential legal claims);
• where it is necessary for the assessment of the working capacity of a freelancer or volunteer; and/or
• where we have your explicit written consent.

Where you are a user of our services, we will be processing your health, racial and ethnicity personal data on the basis of your explicit consent. As we set out in this notice, you are under no obligation to provide us with this data. It is completely optional and you can withdraw your consent to your processing of it at any time. If you have any questions or if you want to discuss this further with us, please get in touch.

Who do we share your personal data with?

We may transfer your personal data to the following parties for the specific purposes set out below:

• with third party service providers, such as IT service providers;
• our advisers, including accountants, auditors and lawyers;
• with partner organisations, such as fight for peace, taking shape association;
• with charities that offer related or complementary services; and/or
• with emergency, police and NHS services if you ask us to, or if we need to in order to protect your safety or that of others.

Is your data transferred to other countries?

We do not intend to transfer your data to any country outside the UK. If such transfers occur in the future, The Brave Project C.I.C will put in place the appropriate transfer mechanism as required under the relevant data protection legislation, to ensure the safety of the personal data transferred. We will also update this privacy notice to reflect this change.

How long do we store your data?

We will only keep your personal data as long as it is necessary for the purpose for which it was collected and for a maximum period of 2 years, unless there is another purpose for retaining or legal requirement to retain your data.

In order to determine the appropriate retention period for your personal data, we will consider:

• The purpose for which we process your personal data;
• The amount of personal data;
• The nature of the personal data;
• The sensitivity of the personal data;
• The potential risk of harm from its unauthorised use or disclosure;
• Whether we can achieve our purposes through other means; and
• Any applicable legal requirements concerning the retention of the data in question.

What rights do you have?

• Access:you may have the right to obtain from us confirmation if your personal data is being processed by us in addition to certain related information, as well as the right to obtain a copy of your personal data undergoing the processing. 

• Rectification: you may have the right to request the rectification of inaccurate personal data and to have incomplete data completed.

• Erasure: you may have the right to request that we erase your personal data if (i) it is no longer necessary for the purposes for which we have collected it, (ii) you have withdrawn your consent and no other legal ground for the processing exists, (iii) you objected and no overriding legitimate grounds for the processing exist, or (iv) the processing is unlawful, or erasure is required to comply with a legal obligation.

• Restriction: you may request that we restrict the processing of your personal data in certain cases, (so that we must suspend the processing, except for storage, with your consent or for legal claims) including for example where you object to us processing your personal data on the basis of our legitimate interests or where you want to establish the accuracy or the reason we are processing your personal data

• Objection: where we process your personal data on the basis of our legitimate interests, you may have the right to object to this processing for reasons relating to your particular situation. If this is the case, we will stop this processing of your personal data unless we can demonstrate compelling reasons why we need to process it which override your rights and freedoms, or where we need to process it for the purposes of legal claims.

• Portability: you may have the right to receive your personal data that you have provided to us, in a structured, commonly used and machine-readable format and to transmit it to other data controllers. This right only exists if the processing is based on your consent or a contract and the processing is carried out by automated means.

• Right to refuse to provide information: you have the right to refuse to provide information when requested, however please note that where the processing of that information is necessary for the purposes of entering into or performing contractual obligations, or to comply with our legal obligations, then your failure to provide certain information when requested could mean that we are unable to comply with those obligations.
• Right to refuse or withdraw consent: in cases where we ask for your consent to processing, you are free to refuse to give consent and you can withdraw your consent at any time. The lawfulness of any processing of your personal data that occurred prior to the withdrawal of your consent will not be affected.

What happens if you do not wish to provide us with your personal data?

Some of the personal data that we ask from you is necessary in order for us to provide our services. We may also need to process certain information in order to comply with our legal obligations.

If you choose not to provide certain information when requested, this could mean that we are unable to comply with our obligations or to provide you with the services you requested or engaging your services for collaboration and volunteering opportunities.

Do you carry out automated decision making?

We do not make any decisions about you exclusively using automated processing.

Questions and complaints

If you have any questions about the content of this privacy notice or how we process your personal data, please contact us at: [email protected]

If you have any concerns about how we handle your personal data, we would welcome the opportunity to deal with your concerns in the first instance. However, you also have the right to make a complaint to the UK Information Commissioner’s Office (“ICO”) if you feel that we have dealt with your data improperly. You can contact the ICO at https://ico.org.uk.

What happens if I am a minor?

Our services are available to individuals aged 15 and up. This document explains how we use and protect your personal information so that we comply with the law.

Personal information is anything that can be used to identify you, and above you have a list of all the different things we collect under the section “What type of personal data do we process?”. When we mention service users, we are talking about the people that come or are sent to us to access our support services. 

This document also includes the legal reasons we have to keep and use your personal information. When your information is especially sensitive (for example, information about your gender or racial/ethnic identity), we will take extra measures to ensure that it is protected. We will only keep your information for the time necessary to support you, unless we have a legal reason to keep it for longer.

You have rights over your personal information, included in the section “What rights do you have?”. If you wish to exercise any of these rights or have any questions about how we use your personal information, please contact us at: [email protected]

One of your rights is to refuse to give us your personal information, although in some cases this can mean that we are not able to provide you with the services you need. We will let you know when this is the case. If you decide to give us your consent to use your personal information, you can always take it away or exercise the rights mentioned in the paragraph above.