Last Updated: February 2019

This privacy notice applies between you, the user of this Website and Action on Addiction, the owner and provider of this Website. Action on Addiction takes the privacy of your information very seriously. This privacy notice applies to our use of any and all data collected by us or provided by you in relation to your use of the Website.  Please read this privacy notice carefully.


Definitions

Personal Information

collectively all personal information that you submit to Action on Addiction via the Website. This definition incorporates, where applicable, the definitions of 'personal data' provided, in UK and EU Data Protection Law;

Cookies

a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies (and other similar technologies) used by this Website are set out in the clause below (Cookies);

Action on Addiction, or us

Action on Addiction, a company incorporated in England and Wales with registered number 05947481 whose registered office is at Head Office, East Knoyle, Wiltshire, SP3 6BE;

UK and EU Data Protection Law

the Data Protection Act 2018, the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

User or you

any individual that accesses the website; and

Website

the website that you are currently using, www.actiononaddiction.org.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions

 

Scope of this privacy notice

This privacy notice applies only to the actions of Action on Addiction and users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

Personal Information collected

We may collect the following Personal Information from you:

Information that you provide voluntarily

  • Certain parts of our Website may ask you to provide Personal Information voluntarily: for example, we may ask you to provide your contact details in order to register interest in treatment, to subscribe to marketing communications from us, and/or to submit enquiries to us. The Personal Information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Information.
  • Some of the Personal Information that you provide may include sensitive information, such as health-related information, which we need when you are applying for treatment for yourself or someone you know through the Website.

Information that we collect automatically

  • When you visit our Website, we may collect certain information automatically from your device.
  • Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.
  • Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
  • Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies” below.
  • In general, we will use the Personal Information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your Personal Information. However, we may also use your Personal Information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

Information that we collect from third parties

  • During admission to (or treatment at) an Action on Addiction centre, we may receive personal information about you from the National Drug Treatment Monitoring System (NDTMS) which is run by Public Health England (see 'Sharing Data' for more information as to how we share your data with Public Health England). NDTMS is a national database that collects trend and activity data from publicly-funded substance use disorder treatment services. The information we collect includes information on treatment received, treatment needs and the outcome of any pre-existing treatment, and has been provided to NDTMS either by you or a medical professional, and includes information about your medical history.

Our use of Personal Information

  • For purposes of the UK and EU Data Protection Law, Action on Addiction is the "data controller".
  • We will retain any data you submit on the Website if we have an ongoing legitimate business need to do so (for example, to provide you with treatment or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
  • If you undertake treatment with Action on Addiction, we will retain your information for as long as we need too to comply with requirements on retention of medical and safeguarding data. We will also retain your information if we have a legitimate need to do so (for example, to follow your progress once you leave our treatment centres, or to invite you to future 'reunion' events).
  • If you submit admissions information to us but decide not undertake treatment with Action on Addiction, we will retain your information for a limited amount of time so that a) we can assess interest in our services; and b) so that you do not have to re-input your information if you decide to undertake treatment at Action on Addiction in that time-frame.
  • Unless we are obliged or permitted by law to do so, and subject to any third party disclosures specifically set out in this policy, your data will not be disclosed to third parties.
  • All Personal Information is stored securely in accordance with the principles of UK and EU Data Protection Law. For more details on security see the clause below (Security).
  • Any or all of the above data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, data may be used by us for the following reasons:
    • internal record keeping;
    • transmission by email of materials that may be of interest to you;
    • information you of fundraising events and appeals;
    • contacting you in relation to treatment options;
    • in each case, in accordance with this privacy notice.

Sharing Data

  • Action on Addiction may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website).
  • We work with Public Health England (PHE). PHE exists to help protect and improve the health and wellbeing of people across England, and to promote equal health outcomes for all. As part of your drug or alcohol treatment you will be asked questions about you, your recovery so far, and whether you agree to some of this information being shared with PHE. The information about your treatment which is shared with PHE is used to help understand more about which treatments work best. It is also used to help improve the way treatment services are provided in your local area. No information about you is ever shared with PHE without your permission and PHE will never share any information which could be used to identify you (for example, we may tell PHE that we are treating a client who is between the age of 25 – 30 with a SW15 postcode). If you would like to know more please visit www.ndtms.org.uk/info or contact us directly.
  • Action on Addiction may also disclose your Personal Information to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person; or to any other person (with your consent to the disclosure).

Links to other websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy notice does not extend to your use of such websites. You are advised to read the privacy notice or statement of other websites prior to using them.

Changes of business ownership and control

  • Action on Addiction may, from time to time, expand or reduce our activities and this may involve the sale and/or the transfer of control of all or part of Action on Addiction. Personal Information provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy notice, be permitted to use the data for the purposes for which it was originally supplied to us.
  • We may also disclose data to a prospective purchaser of our business or any part of it.
  • In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Legal Basis

  • Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
  • However, we will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person e.g. give urgent medical care.
  • If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information).
  • If we collect any sensitive information from you (in particular, any health-related information that you may provide to us if you are applying for treatment for yourself or someone you know through the website), we will always obtain your consent to us processing that information.

Cookies

  • To use all features and functions available on the Website, you may be required to submit certain data.
  • We use Cookies to collect and use Personal Information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Statement.

Data Protection Rights

You have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your Personal Information, you can do so at any time by contacting us using the contact details provided below.
  • In addition, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by contacting us using the contact details provided below.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided below.
  • Similarly, if we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your Personal Information.

Security

  • Data security is of great importance to Action on Addiction and to protect your data we have put in place appropriate technical and organisational measures to safeguard and secure data collected via this website. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information.
  • If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.
  • We endeavour to do our best to protect your personal data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your data transmitted to the Website.

International Data Transfers

  • Your Personal Information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Changes to this privacy notice and contact details

  • Action on Addiction reserves the right to change this privacy notice as we may deem necessary from time to time or as may be required by law. When we update this privacy notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
  • You can see when this privacy notice was last updated by checking the “last updated” date displayed at the top of this privacy notice.
  • If you have any questions or concerns about our use of your Personal Information, please contact us at privacy@actiononaddiction.org.uk.