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Your Privacy and Safety
At Kooth we take the privacy and safety of our users very seriously. We have written this document to tell you: about how we protect your personal data, how we work to keep you safe.
What is Data Protection
There is a law called the Data Protection Law which is in place to ensure that we use your personal data lawfully, in order to protect it. Kooth is known as a data controller, our registered office is at 2 Eastbourne Terrace, London, W2 6LG (Telephone: 0203 984 9337, Email: DPO@kooth.com). We have a Data Protection Officer called Kate Newhouse, who is also our Chief Operating Officer and ensures that we follow the rules on data protection. If you wish to contact us and you are a Service User, please do this by logging in and sending a private message to our staff in order to protect your anonymity.
What information do we need to collect and why?
When you use Kooth we need to collect some personal information from you - this is known as Personal Data. When you sign up to Kooth we ask for The organisation or location that you are affiliated with, along with a sub group within that organisation/location. Your month and year of birth. We need this data to be able to provide a service to you. Our legal basis for processing this data is to to deliver a contractual service to you. We also collect additional data, which is called ‘special category data’ including age, gender and ethnicity. This information helps us to improve our services to you and the wider community. Your gender identity Your ethnicity This data is collected under the legal basis ‘legitimate interest’ as it helps us to measure how we are performing as a service and to improve our service. This data is provided to the organisations who make our services available to you. Any data shared in this way is fully anonymous, non-identifiable data and is used to help inform the organisations about usage of the service, including, but not limited to: Number of registrations Kooth Site usage Issues faced by service users Outcomes achieved. Although this is personal data, it will NOT Identify an individual user or Allow us to trace or find an individual We do not ask you for any information that may identify you when you sign up. Referrals to Kooth from external services or from a third party Sometimes, people are referred into our service by a third party, such as your GP, or another service you may have been working with. If you have been referred to Kooth by someone and they have shared your Personal data with us, we will keep your personal details in a confidential section of your account that can only be seen by Kooth team members. This information would only be used in situations described in the Safeguarding section below.
What other personal data do we hold?
Depending on how you interact with us, you may at times give us some personal information which we have not asked for. If you are interacting using Message Boards, or providing articles for the magazine for example, our moderators will make sure that this is not published on the site and may message you to discuss how you could amend the post or article to protect your privacy. Any personal data which you provide to us will be stored against your profile within our platform. If you do decide to give us your personal data, it may mean you are no longer ‘anonymous’ to us, for example, we may know who you are or where you are.
Do we share your personal data with anyone else?
Safeguarding - We have a Duty of Care to safeguard your wellbeing. If we are really worried about you and think that you are at risk or danger, we will talk to you about the need for somebody outside the Kooth team to know what has happened or what is happening to you. We would only do this if: your life is at risk because of something you are doing, you are at risk from somebody else, you are a risk to somebody else. In these cases, our practitioners will ask you to consent to share your details so that they can refer you to the appropriate services or get the help you need. If you do not consent and our practitioner feels it is a safeguarding issue, then they may refer/share any details which we have. In this case, we will: Let you know who we are passing details to and why, Keep you informed of any actions we intend to take, Where possible, we will work with you to agree every step taken. Sometimes, if the situation is very serious, we may have to take action without talking to you first.
Referral from Kooth to external services
Sometimes getting extra help for you can be really helpful. Depending on where you live you may be given the option of a referral to another service in your area. These services may be operated by Kooth or a partner organisation. If you self-refer, you could provide personal details directly to the organisation. If you wish the Kooth team to make a referral on your behalf you would need to share personal data which we would need to pass on to enable us to complete the referral. This personal data will be stored on the Kooth system and is only accessible to the Kooth Team and the organisation you are being referred to. We will always seek your consent to pass over your details and let you know who we are passing details to. Where do we keep your data and how long for? All information is stored securely within Kooth Platform (XCP) and is only accessible to the Kooth Team. Our systems are encrypted (coded which ensures your data is protected). Kooth uses Google Cloud Platform’s europe-west-2 region for hosting (London, UK). Kooth data is hosted in the europe-west-2 region (London) of the Google Cloud Platform. We only keep your personal data for as long as necessary to provide our services to you and also to ensure we meet our legal obligations. We usually keep your personal data for 7 years after you have stopped using our service. In some cases we may need to keep it for longer, if we legally have to. Your Data - Your Rights As the owner (aka ‘Data Subject’) of your personal data, you have certain rights under the General Data Protection Regulations (GDPR) to find out about our use of your personal data. You have: The Right to be informed - by providing you with this document, we are giving you the information about your data that is collected and held by us,
The Right of access - you can ask about your personal data that we hold - this is called a “data subject access request”,
The Right to rectification - you can tell us if the data we hold is wrong or incomplete and ask us to put it right,
The Right to erasure - you can request erasure of your personal data. This enables you to ask* us to delete or stop processing your data. (*There may be times when we can’t do this though because we are required by law to hold it for a certain time),
The Right to restrict processing - you can object to the processing of your data where the Company is relying on its legitimate interests as the legal ground for processing,
The Right to data portability - you can ask us to securely transfer your personal data to another data controller,
The Right to object - you can ask us to stop the processing of your personal data for a period of time if data is inaccurate or there is a dispute about its accuracy or the reason for processing it.
If you wish to do any of these things, log in to your Kooth account and message a member of the Kooth team and they will help you. By contacting us through your account, rather than by direct email, you are protecting your anonymity. If you think that we have failed to handle your data properly or have not allowed your rights listed above, you have the right to make a complaint to the Information Commissioner’s Office.
Your right to withdraw your consent
You have the right to withdraw consent if you have shared any personal data with us. You can withdraw your consent to share information at any time. You can request to withdraw your consent by sending a message to the Kooth team when you are logged in.
Additional Information on how we improve our services We may use the data we collect to measure how we are performing as a service and to improve our service. This information is always anonymised, therefore it could not be used to identify you. Case studies We are asked by the organisations who pay for the service, to provide them with anonymous monthly case studies of our work with service users. This is so they can see how well Kooth is performing in our role in supporting you. Our team at Kooth also have to take part in ongoing training and development so that they can be best placed and trained to support you. This means that they sometimes also have to write case studies for their courses or training. Whenever a case study is written, we never use any of your personal data. It will never be possible to identify you from these case studies. Research For Kooth to be able to improve its services, we sometimes work with trusted partners, including universities and NHS organisations to help us analyse our data. This includes working with researchers from universities who get ethical approval for their work. The data which we provide to them is a mixture of statistics and information that you have provided to us. The statistics include data such as the age, ethnicity, and gender of service users as well as other information provided to the service such as goals or assessments, and service usage data. Other information includes both public and private information shared within Kooth. Public information refers to any article and discussion board submissions as well as comments which are approved by our moderation team and posted on the site for other users to see. Private information refers to any communication you have with the counselling team either through chat (one-to-one messaging) or messaging the team inbox. It does not contain any personal data which could be used to identify you - it is completely anonymised. No identifiable information will ever be shared outside of our organisation for research purposes without your explicit consent. If you want to find out more information about how we use data for research, you can message the team through the platform.
Posted: 17 July, 2021