Our promise to keep your information safe
At Upstream Outcomes, we’re committed to protecting your privacy. We promise to respect any personal information you share with us (or that we receive from other organisations) at all times, and we promise to keep it safe.
This data processing statement applies to Bridgit Care and Upstream Health which are both trading names of Upstream Outcomes Ltd.
How we process your data
This policy sets out how we process your data. It also explains your rights and options around how we use your personal information.
We collect information about you:
…when you give it to us directly
This might be when you:
- interact with us online
- register with us
- communicate with us
- take part in an event
- when authorised through a 3rd party application
- buy something from our store
- apply to work or volunteer for us
- give us your personal information in any other way, for example, if you’re receiving products
- for online consultations, or other video conversations.
…when you give it to us indirectly
This is when your personal information is given to us by third parties. These might be:
- business partners
- sub-contractors in technical, payment and delivery services
- event organisers
- advertising networks
- analytics providers and search information providers.
You’ll always hear from them when this happens, and you’ll be told how and why we intend to use that information.
…when others give it to us
If you’re receiving care or support as a patient, we’re given personal information about you from your NHS healthcare team only when you are referred to us by your district nurse, GP or hospital consultant for use of our products within your healthcare journey.
…when it’s available publicly
Some information about you may be in the public domain, using public registers such as Companies House, the electoral roll and press reports. For example:
- whether you have charitable interests.
- to establish possible common connections between Upstream Outcomes network and yours.
- depending on your privacy settings for professional services such as LinkedIn.
- We may collect personal information to conduct supporter research and this is on occasion through our existing network. We may also analyse information you provide to us with other freely available public information to create a profile of interests, preferences and level of interaction so that we can contact you in the most appropriate way and with the most relevant information (for more information about this use, see How will you combine and analyse the information we collect about you?)
…when you visit this website or use our applications
When you visit this website, we automatically collect the following personal information:
- technical information, including:
- the internet protocol (IP) address used to connect your computer to the internet
- your browser type and version
- your time zone setting
- browser plug-in types and versions
- your operating systems and platforms
- information about your visit to our website, including:
- the uniform resource locator (URL) clickstream to, through and from this site (including date and time)
- products/services you viewed and searched for
- page response times
- download errors
- length of visits to certain pages
- referral sources (how you arrived at the website)
- page interaction information (such as scrolling and clicks)
- methods used to browse away from the page.
What is personal information?
We collect, store and use the following kinds of personal information:
- Your name and contact details, including postal address, telephone number, email address and, where applicable, social media profile URL
- Your date of birth
- Financial information, such as bank details or credit/debit card details, where you provide them to make a payment. We don’t store credit or debit card details, but we’re required to store bank details in some circumstances, including when they’re used for direct debit payments.
- Information about your computer/mobile device and your visits to and use of this website, including for example your IP address and geographical location
- Information about our services which you use/which we consider of interest to you
- Information as to whether you are a taxpayer so that we can claim Gift Aid.
- Information you’ve populated through our carer assessment process. Including things like your care needs, care goals and progress.
- Information relating to your family members that interact with you through our services, either through the carer service or through our home support devices or watch.
What is sensitive personal information (special category data)?
The General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (DPA18) recognises certain categories of personal information as sensitive and therefore requiring more protection.
For example, this includes information about your health, religious beliefs, ethnicity and political opinions.
In other limited cases, we may collect and/or use your sensitive personal information.
In each case, we will only do so if we have a valid reason and the GDPR/DPA18 permits it, as described in how and why we will we use your personal information.
How do we use your personal information?
We use your personal information to:
- provide you with services, products or information you’ve asked us for
- provide further information about our work, services, activities or products
- allow you to purchase goods
- use your data to support our learning products (such as machine learning) to identify trends and areas we can support you
- further our social enterprise aims, including for fundraising and procurement
- research the impact and effectiveness of our work and services
- register, administer and personalise online accounts
- register and administer your participation in events you’ve registered for
- administer and keep our website safe and secure and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- improve your interactions with our website, for example by making sure that content is presented in the most relevant and effective manner for you and for your computer/mobile device
- report on the results and impact of our work, services and events
- analyse and improve our work, services, activities, products or information (including our website) or for our internal records
- use IP addresses and monitor website use to identify locations, block disruptive use, record website traffic or personalise the way information is presented to you
- to process your application for a job or volunteer role with us
- training and/or quality control
- audit and/or administer our accounts
- satisfy legal obligations which are binding on us, for example, arising from contracts entered into between you and us or in relation to regulatory, government and/or law enforcement bodies with whom we may work
- prevent fraud, misuse of services or money laundering
- reduce credit risk
- communicate with you in any other way
- for the establishment, defence and/or enforcement of legal claims; and/or
If you are in communication with our Carers Support Service, you should note that :
- Our Carers Support Service has a duty of care to all of its clients. Where all communication with our service is confidential, we hold the right to notify public services should you disclose something we feel highlights serious risk or harm to you or a 3rd party individual.
How creating a record for you helps us to be more relevant
We may use your personal information to create a record of your interests and preferences.
This means we can make our contact with you more relevant, timely and appropriate.
It also helps us understand the background of our customers to help us make sure that what we’re asking is appropriate.
How we combine and analyse the information we collect about you
Before contacting you, we may use data analysis to interpret your data and predict how likely you are to be interested in or responsive to a particular campaign or message. Where we have identified that you have the capacity and/or affinity to support Upstream Outcomes at a higher level, we may collect additional information about you (see ‘How we use your information’) and combine, analyse and compile that information into a profile of you in order to assist us in engaging with you in a more personalised way.
We typically look at and combine information published in the media but other commonly used publicly available sources including company resources, the Electoral Register and any data you choose to make public on LinkedIn such as your professional memberships and networks. We may also use any publicly available data that you share on social media. We may use additional information such as geographical information for measures of affluence where available. In order to do this efficiently, we may use trusted third-party specialist companies that collate and analyse information from public registers alongside statistical social-economic data to automate some of this work. This helps us to understand more about your interests and level of potential engagement.
You can opt-out of your data being combined and analysed for marketing purposes by contacting Upstream Outcomes.
Marketing to you and talking about our products and services
We use your details to give you information about our work, events, services and/or products which we think might interest you.
For example, we might contact you about goods or services you’ve purchased or used in the past, or send you updates about our volunteering opportunities and latest campaigns.
Where we do this via email, SMS or phone (if you are registered with the telephone preference service), we’ll only do this with your prior consent.
Where we capture children’s data online, we’ll seek parental consent for any children under 13. We won’t actively market to under 18s.
How long do we keep your personal information?
In general, if we no longer need your information for the reasons you gave it to us, we remove your personal information from our records six years after the date it was collected.
But we’ll remove it sooner if:
- your personal information is no longer required for the purpose you shared it with us
- we’re no longer lawfully entitled to process it
- you ask us to remove it.
What happens if you ask for your data to be removed?
If you ask to receive no further contact from us, we’ll keep some basic information about you to make sure we don’t send you unwanted materials in the future.
Please note that special rules apply to health records, which may often be kept for longer than six years.
Where your personal information is used to support research, it is usually kept for longer and may be used in the future to help with further research as medical science advances.
Our lawful grounds for processing your information
The GDPR/DPA18 requires us to rely on one or more lawful grounds to process your personal information. These are the grounds we think are relevant.
- Where you’ve given your consent for us to use your personal information in a certain way.
- For example, we’ll ask for your consent to use your personal information to send you electronic direct marketing/fundraising, and we may ask for your explicit consent to share sensitive personal information with us.
- Where necessary so that we can comply with a legal obligation (for example, where we need to share your personal information with regulatory bodies which govern our work and services).
- Where necessary for the performance of a contract which we have with you or to take steps before entering a contract (for example, if you purchase something from our online shop or apply to work for/volunteer with us).
- Where it is in your/someone else’s vital interests (for example, in case of a medical emergency).
What do we mean by ‘legitimate interests’?
The GDPR/DPA18 allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests, as long as that processing is fair, balanced and does not unduly impact your rights.
Upstream Outcomes legitimate interests
In broad terms, our “legitimate interests” means running Upstream Outcomes as a Social Enterprise in pursuit of our aims and ideals. For example, by:
- providing information about health
- administering events
- taking applications for staff and volunteers.
Your legitimate interests
“Legitimate interests” can also include your interests, such as when you have requested information or certain goods or services from us, and those of third parties.
How do we balance these interests?
When we legitimately process your personal information in this way, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws.
We won’t use your personal information for activities where our interests are overridden by the impact on you. For example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
Processing sensitive personal data
The GDPR/DPA18 prohibits the processing of sensitive personal data (special category data) unless additional conditions are met.
We think the following conditions are relevant, in each case in accordance with the relevant safeguards:
- where the processing is necessary for the provision of health or social care
- where the processing is necessary for scientific research.
Will we share your personal information?
We never share, sell or rent your information to third parties for marketing purposes.
However, in general, we may disclose your personal information to selected third parties in order to achieve the other purposes set out in this policy.
These may include (among others):
- healthcare professionals, medical researchers and organisations involved in the provision of care and/or medical research
- business partners, suppliers and sub-contractors
- advertisers and advertising networks
- analytics and search engine providers
- IT service providers
- other beneficiaries, executors and legal advisers, when administering a legacy.
In particular, we reserve the right to disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets;
- if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;
- if we are under any legal or regulatory duty to do so; and/or
- to protect the rights, property or safety of Upstream Outcomes, its personnel, users, visitors or others.
Security, storage and access to your personal information
We promise to keep your personal information safe and secure.
We have an appropriate and proportionate security policy and organisational and technical measures in place to help us do this. For example, we require specialist suppliers who process secure payments to comply with the Payment Card Industry Data Security Standard (PCI DSS) standards.
Who can see my personal information?
Only appropriately trained staff, volunteers and contractors can access your information. It is stored on secure servers with features to prevent unauthorised access.
Where is my personal information stored?
In general, the personal information that we collect from you will be stored at a destination within the UK.
However, we use agencies and suppliers to process personal information on our behalf.
Your personal information may therefore be transferred or stored outside, and/or otherwise processed by contractors operating outside, the UK who work for us or for one of our suppliers.
Please note that some countries outside of the UK have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals.
Where your personal information is transferred, stored and/or otherwise processed outside the UK, we’ll take all reasonable steps necessary to make sure the recipient implements appropriate safeguards (such as by entering into standard contractual clauses) designed to protect your personal information and to ensure that your personal information is treated securely and in accordance with this Policy.
Unfortunately, no transmission of your personal information over the internet can be guaranteed to be 100% secure.
These are your rights in relation to how we process your personal information:
Right to be informed
You have the right to be told how your personal information will be used. This policy and other policies and statements used on this website and in our communications provide you with a clear and transparent description of how your personal information may be used.
Right of access
You can write to us to ask for confirmation of what information we hold on you and to request a copy of that information.
Provided we are satisfied that you are entitled to see the information requested and we’ve successfully confirmed your identity, we’ll give you your personal information (subject to any exceptions that apply).
Right of erasure
You have the right to ask us to delete your personal information, and we’ll do this when you ask us to. In many cases, we’ll check to see if you’re happy for us to make it anonymous first, rather than delete it completely.
Right of rectification
If you believe our records of your personal information are inaccurate, you have the right to ask us to update those records.
You can also ask us to check the personal information that we hold about you if you are unsure whether it is up to date.
Right to restrict processing
You have the right to ask us to restrict the processing of your personal information if there is disagreement about its accuracy or legitimate usage.
Right to object
You have the right to object to processing where we are:
- processing your personal information on the grounds of legitimate interest.
- using your personal information for direct marketing or
- using your personal information statistical purposes.
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time.
This includes the right to ask us to stop using your personal information for marketing or fundraising by electronic means (for example to be unsubscribed from our email newsletter list).
Right to data portability
Where we are processing your personal information:
- because you gave us your consent
- because such processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract, and the processing is carried out by automated means
you may ask us to provide it to you – or another service provider – in a machine-readable format.
Rights related to automated decision-making
Where we take automated decisions (ie with no human involvement) in relation to your personal information, you have the right to ask us for human intervention or to challenge any such decision.
How to exercise your rights
- To exercise any of these rights, please send a description of the personal information in question using the contact details below. We reserve the right to ask for:
- personal identification
- further information.
- Please note that you may only use/benefit from some of these rights in limited circumstances. For more information, we suggest that you consult guidance from the Information Commissioner’s Office (ICO) or please contact us.
- You have the right to make a complaint to the ICO about us or the way we have processed your personal information. Find further information on how to exercise this right, or contact them.
Changes to this Notice
We may update this Policy from time to time so please check back periodically. We will notify you of significant changes by placing a notice on our website. This Policy was last updated in November 2020.
Links and third parties
We link our website directly to other sites. This Policy does not cover external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit via links on our website.
How to contact us
If you would like more information about this policy, your privacy or the way that Upstream Outcomes processes your personal information, please contact us at email@example.com or firstname.lastname@example.org