Safeguarding, Confidentiality, Privacy and Cookies

Our service is confidential. This means that whatever you speak to us about is private and stays between you and us (the Is This OK? Team). You don't have to tell us anything you don't want to share - we want you to feel safe talking.

Safeguarding Policy

Sometimes, if the team is worried you're in danger, they may need to share this information with other people who can help to make you safe.

They’ll only do this if:

  • you ask them to
  • they believe your life or someone else’s is in danger
  • you’re being hurt by someone in a position of trust who has access to other children, like a teacher or police officer
  • you tell them that you’re seriously harming another person

We would always talk to you about why we would need to share those serious concerns and who we were sharing them with.

Privacy

Is This OK? is a service managed by the charity Missing People and operated by Missing People and NSPCC/Childline (together these charities are the “team”).  Missing People and NSPCC/Childline take your privacy very seriously and are committed to protecting any personal information they might hold about you.  This Privacy Policy tells you what they do with any personal information you provide to the “Is This OK” chat system.

Under data protection law, Missing People (“We”) needs to tell you certain things about how “Is This OK” uses your data.  First of all, Missing People is the “data controller” which means we are responsible for how your data is used on the “Is This OK” chat system.   Missing People has a data protection officer who is responsible for ensuring that the charity protects your data and abides by data protection law.  His contact details are at the bottom of this page.  (Missing People is registered with the Information Commissioner under reference no. Z4558221.)

By the way, where we refer to data protection law we mean the Data Protection Act 2018 which incorporates the General Data Protection Regulation (GDPR), the Privacy and Electronic Communications  Regulations 2003 (PECR) and any legislation implemented in connection with the GDPR.  This includes any replacement legislation coming into effect from time to time.  For more information on how Missing People and The NSPCC handle your personal data, please see their privacy policies at www.missingpeople.org.uk/policies-and-disclaimer and www.nspcc.org.uk/privacy-policy.

Your data and what we do with it

“Is This OK” aims to provide support and advice to young people, and we will store what you tell us on the “Is This OK” system.  The team will only use the information you give them to help them provide the services you ask for and to keep you safe. The data the “Is it OK” team needs to be able to help you – and which you provide voluntarily to us – is:

  • Nickname or name – so that we can refer to previous chats;
  • Transcript of chat including your responses to the chatbot – so that we can safeguard you and so that you don’t have to repeat yourself;
  • Survey responses – so that we can develop the service to better help you and others in future

If you are directed through to either Missing People or Childline services, the organisation will store what you have told us on the “Is This OK” system as well as any further information you provide us on the organisations’ database.

We may use your data for the purposes of research and analysis so that we can further improve and broaden our services. We will always anonymise this data so that you and your devices cannot be identified.

The legal basis for processing your data depends on the type of processing, and is based on either your specific consent requested through the chat system or there being sufficient substantial public interest in safeguarding you as discerned by our staff  at the point the information was initially provided.  Furthermore, we will not store, process or transfer your data outside the team detailed above unless we have an appropriate lawful reason to do so – as outlined below.

Who we might share your information with

“Is This OK” is a confidential service.  All of the “Is This OK” staff are bound by Missing People’s or NSPCC/Childline’s confidentiality policy, however both organisations will be working within the technical limitations of the ‘Is This Ok’ project which means that chats cannot be traced through the “Is This OK system” to the source device.  This process does differ from the current NSPCC/Childline confidentiality policy. If a team staff member thinks you or someone else is at risk of serious harm, they may need to let someone else know – but they would always try to work with you first to get the help you want.  In such circumstances, they may need to pass your information on to another party that aims to keep you safe, such as the police.  [It is also possible that some other public authority acting under the law says we must share the data.   And we may need to share the data to establish, exercise or defend our legal rights.]

Anonymised data for research might also be shared with others, e.g external researchers.

How long we keep the data

We will retain the chat information including the transcript on the “Is This OK” system for no more than 18 months.  If either Missing People or Childline believe they need to keep your information for longer period in order to better safeguard you then they may do so.  In such circumstances they will retain the information according to their own data retention policies.  Please see the Privacy Statements on their own websites for more information.

If you want to see your data on the “Is This OK” system or want us to delete it please contact us on services@missingpeople.org.uk

Your rights

Right to Access Your Personal Information

You have the right to access the personal information that we hold about you in many circumstances, by making a request. This is sometimes termed ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge and within 30 days from when your identity has been confirmed.

We would ask for sufficient information about your interactions with us that we can locate your personal information.

If you would like to exercise this right, please contact us as set out below.

Right to Correction of Your Personal Information

If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it.

If you would like to exercise this right, please contact us as set out below.

Right to Stop or Limit Our Processing of Your Data

You have the right to object to us processing your personal information if we are not entitled to use it any more, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances.

If you would like to exercise this right, please contact us as set out below.

For more information about your privacy rights

The Information Commissioner’s Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here https://ico.org.uk/for-the-public.

If you have any concerns about the data we hold about you and what we do with it you can e-mail us at services@missingpeople.org.uk  and we will respond quickly, that is, within the period required by law.

Sharing your thoughts

When using our website and chat system you may be able to share information through social networks like Facebook and Twitter. For example, when you ‘like’, ‘share’ or review our Services. When doing this, your personal information may be visible to the providers of those social networks and/or their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts so you are comfortable with how your information is used and shared on them.

Security

Data security is of great importance to Missing People and NSPCC/Childline and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure your collected data.

We take security measures to protect your information including:

• Vetting our staff carefully when recruiting;
• Limiting access to our buildings to those that we believe are entitled to be there (by use of passes, key card access and other related technologies);
• Implementing access controls to our information technology based on need to know;
• We use appropriate procedures and technical security measures to safeguard your information across all our computer systems including, networks, websites and mobile apps;
• We conduct data protection data processor reviews on all relevant suppliers.

How to contact us

If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this policy, the way your personal information is processed, please contact us by one of the following means:

By email: 116000@missingpeople.org.uk fao: Data Protection Officer, James Rowley

By post: [Address]  James Rowley, Data Protection Officer, Missing People, 284 Upper Richmond Road West, London SW14 7JE

Thank you for taking the time to read our Privacy Policy.

This Policy was last updated on 07/08/2019