We’re Khulisa (which means ‘to nurture’ in Zulu), a national youth and rehabilitation charity dedicated to helping young people and adults with complex needs to live healthier, crime-free lives. Khulisa is a registered charity (no. 1120562) and company limited by guarantee (no. 6210432). We deliver emotional and social wellbeing programmes, therapeutic support and mentoring to young people and adults with complex needs in schools, prisons and the community. We also deliver training on the effects of trauma to professionals working with these young people and adults, such as teachers, prison officers and social workers.
- when and why we collect personal data and other information about you;
- how we use that information;
- the conditions under which we may disclose this to others;
- how we keep the information secure; and
- the rights you have over the personal data we collect.
This privacy notice is made under Articles 13 and/or 14 of the General Data Protection Regulation (GDPR).
Your letter should be addressed to our registered office address:
The Data Protection Officer
32 Cubitt Street
Why and how do we collect information about you?
As a delegate of Khulisa’s training on the effects of trauma or recipient of other services, such as reflective practice, Khulisa may collect and process information about you for the purpose of organising the training and for completing monitoring and evaluation activity.
We either collect this information directly from you when you interact with us or complete our monitoring and evaluation surveys, or from the organisation partnering with us to organise the training or other services. This may be your employer, or an organisation known to your employer.
What information do we collect?
We may collect and process the following personal data about you from the organisation partnering with us to organise the training or other services:
- Your name, job title and organisation you work for; and
- In certain circumstances, your business contact details, including office address, telephone numbers and email addresses.
We collect and process the following personal data from you directly when completing our monitoring and evaluation surveys:
- Your name, job title and organisation you work for; and
- Your responses to our evaluation processes, such as whether you felt the training improved your knowledge of the impact of trauma.
The data is collected by us and stored in our secure data processing system as explained below.
How do we use the information we collect?
We may use the information collected about you to:
- Tailor the content of our training and organise any necessary logistics;
- Provide you with resources relevant to the services and provide links to our monitoring and evaluation surveys;
- Measure the impact of our training and other services;
- Track the number of professionals we have worked with over a given period and in a given location;
- Report to the organisations which fund our work or work with us in other ways on our progress in delivering training and other services;
- Give a progress report and recommendations to the organisation partnering with us to organise the training and other services.
However, we will always treat your data confidentially and will not disclose your identity in our reporting or sharing with third parties other than the organisation partnering with us to organise the training and/or other services in some circumstances. Third parties providing a service to Khulisa may also be able to access the information we collect about you under certain circumstances, detailed below.
We take steps to ensure that all personal information we collect is treated securely. Access to our email, document management and storage services is limited to members of Khulisa’s staff, secured via two-step verification or via encrypted and password protected databases.
Who has access to the information we collect?
Third parties providing a service to Khulisa may be able to access the information we collect about you e.g. the company we use to provide our secure data processing system, Salesforce. This includes our suppliers, subcontractors, agents and other associated organisations we parties providing a service to Khulisa may be able to access the information we collect about you e.g. the company we use to provide our secure data processing system, Salesforce. This includes our suppliers, subcontractors, agents and other associated organisations we use to complete tasks and provide services to you on our behalf. However, no information will be shared unless there is a contract in place that requires the third party to keep the information secure and prevents use for any other purpose than delivering the service. We only disclose the personal information that is necessary to deliver the service.use to complete tasks and provide services to you on our behalf. However, no information will be shared unless there is a contract in place that requires the third party to keep the information secure and prevents use for any other purpose than delivering the service. We only disclose the personal information that is necessary to deliver the service.
We will not sell or rent the information about you to third parties, nor will we share this information with third parties for marketing purposes.
Please be reassured that we will not share your information with third parties beyond this network, unless:
- it is necessary to organise the training or other services, such as to arrange access to an external training venue;
- you have requested us to do so;
- we are required to do so to protect the rights, property or safety of our supporters and customers; or
- we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
In the event of a sale, business restructure or reorganisation of some or all of our business and assets to any third party, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
How long will we keep the information?
We review our retention periods for personal information on a regular basis. We will hold the personal information we collect about you for as long as is necessary for the relevant activity. We keep data for 5 years and then anonymise this data.
Some of the personal information we collect may be transferred and stored securely outside of the UK and European Union by the suppliers of our online surveys and email, document management and storage services. Where that is the case, safeguards are in place to ensure legal protection under the GDPR. This includes supplier certification under the Privacy Shield Scheme if based in the United States of America, or reliance on Model Contract Clauses.
Legal basis of processing
Under the GDPR, we process your personal data under the legal basis that this falls within our legitimate interests as an organisation providing training and other services to organise our services effectively, and take steps to measure the impact of our services.
You have the right to ask for a copy of the information Khulisa hold about you. To do this, please make a request in writing (via our contact form on our website, by email or by post) to the Data Protection Officer and we will provide a response within 30 days.
Your rights under the GDPR also include the following:
- Right to rectification: This means you may ask us to rectify any of the personal data we hold about you.
- Right to object: You have the right to object to us processing the data we hold for you. In this event, we will stop processing any more information unless we can show legitimate grounds for the processing of this information.
- Right to restrict processing: You have the right in certain circumstances (for example, where accuracy is contested) to request that the processing of the personal data we hold about you is restricted.
- Right to erasure (sometimes known as the right to be forgotten): If you object to us processing the data we hold for you, and Khulisa cannot show legitimate grounds for processing this data, you have the right to request us to delete the personal data we hold for you.
If you consider that the personal data we hold for you has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator.
Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.
The Information Commissioner can be contacted at:
By email: firstname.lastname@example.org
By phone: 0303 123 1113
By post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow. Cheshire. SK9 5AF