Privacy Policy

This website www.mentalizinginitiative.org (the “website”) is operated by Mentalizing Initative, a company limited by guarantee registered in California and a registered charity (registered charity no: 1077106) (“we”, “us” or “our”). Its registered office address is: The Kantor Centre of Excellence, 4-8 Rodney Street, London N1 9JH. Our ICO Registration number is Z479393X. Mentalizing Intiative is the data Controller for personal data processed via the website and by the Centre, except where otherwise stated. This privacy policy (together with our website terms and conditions) sets out the basis on which any personal data we collect from or about you, or that you provide to us, will be processed by us. This policy includes our cookies policy for the website. If you have any questions about the content of this policy you can contact us at: Mentalizing Initiative 9777 Wilshire Blvd Suite 909 Los Angeles, CA 90212 mentalizinginfo@gmail.com Or you can contact our Data protection Officer (DPO@annafreud.org, 020 7794 2313). 2. Your rights regarding your personal data Mentalizing Initiative adheres at all times to data protection legislation (currently the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (GDPR)), which provides the following rights for individuals: 3. The right to be informed 2. The right of access 3. The right to rectification 4. The right to erase 5. The right to restrict processing 6. The right to data portability 7. The right to object 8. Rights in relation to automated decision making and profiling. You can read more about data rights on the Information Commissioner’s website. If you have any questions of concerns about how we are processing your data you can contact us, mentalizinginfo@gmail.com. If you do wish to make a complaint about our data processing activity you can contact the Information Commissioner’s Office https://ico.org.uk/global/contact-us/ 3. The data we collect We will process personal data from the following categories of people visiting and using this website: 1. Website visitors and users (cookie data and any personal data you choose to send us in forms on the site) 2. Potential and existing clinical services users (any personal data you send on a referral form, including health details) see the privacy notice for clinical service users 3. Schools Support Service: – See the Privacy Notice for Schools Support Service 4. Donors (any personal data you include when making a donation or setting up a direct debit, including your financial details) 5. Training and conferences applicants and attendees (any data you submit when applying or paying for a training course, including financial details) see the training and conferences privacy notice 6. Job seekers and prospective volunteers (any personal detail you submit in your contact form, including name and email address). We rely upon various lawful bases, as set out in the GDPR, to collect and use your data; 6(1)(a) Consent of the data subject, 6(1)(b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract 6(1)(c) processing is necessary for compliance with a legal obligation to which the controller is subject 6(1)(f ) Necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject. It is in the legitimate interest of Mentalizing Intiative to collect and process data about you and your usage of the website to carry out evaluation, ensure that the information and resources provided are useful, and to identify areas for improvement as we do not believe that this processing will have any adverse effect on your rights as a data subject. It is in the legitimate interest of Mentalizing Intiative to collect and process data from people wishing to join the Alumni Network, submit a job application, submit a referral for use of clinical services or make a donation. We do not believe that this processing will have any adverse effect on your rights as a data subject and is in both our interests. Where we collect Special Category personal data, sensitive or private information such as ethnicity, or health information, we rely on an additional lawful basis. We rely upon your explicit consent (9(2)(a)) to process this information, or the processing is necessary for the purposes of the provision of health or social care or treatment (9(2)(h). 4. How we keep, process and dispose of your personal information We keep your personal information in a secure environment and we do not pass it on to third parties outside of the Mentalizing Intiative unless legally obliged to do so, for example telling HMRC about Gift Aid payments. The information you provide will only be used for the purpose(s) specified when it was collected; such as in association with your on going support as a donor, to supply you with the goods or services you have requested and/or to keep you informed about upcoming Mentalizing Intiative activity. We keep the data for various lengths of time, depending on the purpose it was collected for. Financial data is retained for 6 years. We keep a permanent record of donors for administration purposes. Alumni membership data is retained while you are a member and we keep a permanent record (with minimal data) of all Alumni. If you sign up to a newsletter we will retain your data until you unsubscribe from the list . Training and events data is kept until after the event. Job applications are retained for 6 months or for 6 years after you leave employment if the application is successful. Referrals for clinical services are retained for 6 months, unless you use a service, in which case it will be retained with your case file while you use the service and for a period afterwards. 5. Third party organisations We use third parties to collect and process payments and other data submissions to the website. We have contracts with the organisations to ensure that you data is used appropriately and held securely by them on our behalf. We use Stripe secure payment pages for credit and debit card payments for the purchase of goods and services. Stripe asks for your name, address, phone, email address, and credit/debit card information. Your card details will only be retained by Stripe. You can read their privacy statement on their website. Stripe processes your donations and direct debit information on our behalf. Newsletter sign up and Alumni registration is managed via Mailchimp and Moosend. 6. Access to the information we hold about you (Subject Access Request) You have the right to know what data we hold about you. There is no charge for this service and you can email your request to mentalizinginfo@gmail.com. https://ico.org.uk/your-data-matters/your-right-to-get-copies-of-your-data/ 7. Cookies Policy What are cookies? A “cookie” is a small text file that is placed on a website user’s device/computer hard drive by a website. There are several types of cookie. COOKIE CATEGORIES The type of cookies used on websites or web applications can be put into 1 of 4 categories, based on the International Chamber of Commerce guide to cookie categories. 1. Strictly Necessary Cookies:These cookies are essential, as they enable You to move around a website and use its features, such as accessing secure areas. Without these cookies, the Services You have asked for (such as access to secure areas) cannot be provided. These cannot be restricted or blocked. These cookies do not gather information about You that could be used for marketing or remembering where You have been on the internet. 2. Performance Cookies:These cookies collect information about how You use a website, for example which pages You go to most often and if You get any error messages from certain pages. These cookies do not gather information that identifies You. All information these cookies collect is anonymous and is only used to improve how a website works. These cookies are not used to target You with online advertising. Without these cookies We cannot learn how the RR Platform is performing and make relevant improvements that could better Your browsing experience. These can be restricted or blocked. 3. Functionality & Profile Cookies:These cookies allow a website to remember choices You make (such as Your user name, language or the region You are in) and tailor the website to provide enhanced features and content for You. For instance, they remember Your login details and allow You to watch videos. They also ensure the onsite marketing and experience is relevant to You. These cookies can also be used to remember changes You have made to text size, font and other parts of pages that You can customise. The information these cookies collect may be anonymous and they cannot track Your browsing activity on other websites. Without these cookies, a website cannot remember choices You have previously made or personalise Your browsing experience. These can be restricted or blocked. 4. Targeting Cookies: These cookies gather information about Your browsing habits. They remember that You have visited a website and share this information with other organisations such as advertisers. They do this in order to provide You with adverts that are more relevant to You and Your interests. Although these cookies can track Your visits to other websites, they do not usually know who You are. Without these cookies, online advertisements You encounter will be less relevant to You and Your interests. These can be restricted or blocked. Google Analytics are used widely by websites to collect information about how website visitors use a site. We will use Google Analytics cookies to collect information about how users use the website and to improve the website. Google Analytics collect information in an anonymous form and will not allow us to identify you or collect any personal information about you. Google Analytics does not track your internet activity after leaving the website. Website cookie acceptance We will use a cookie to record if users have accepted the use of cookies on this website. This cookie will be stored on your device/computer if you have consented to our use of cookies by indicating your consent to the pop-up message on the website. Internet browsers Internet browsers normally accept cookies by default. However, it is possible to set an internet browser to reject cookies. By clicking the message about cookies when you visit the website indicating your consent you are consenting to our use of cookies unless you set your internet browser to reject cookies. If you do not accept our use of cookies as set out in this policy, please set your internet browser to reject cookies. Find out how to set your internet browser to reject cookies. More information about cookies The following links provide more information about cookies: About Cookies ICC UK Cookies Guidance Amendment of this policy We regularly review this privacy policy and may amend the content or wording from time to time to ensure it remains relevant and effective. You can see when it was last updated by checking the date at the end of the notice. The published version will be the applicable version. Last Reviewed: 5th May 2021