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Inspira will ensure that all staff abide by the principles set out in the Data Protection Act 2018 (Note: the UK government adopted the EU’s GDPR principles) which require personal information to be:
Confidentiality
Inspira is committed to protecting the privacy of Clients and its employees. Personal information recorded about employees, Clients, contractors and commissioners (past and present) on the Company’s systems will be treated as private and confidential, and as such held within the principles of Data Protection.
Inspira recognises that staff will obtain information about individuals and organisations during their work or activities.
Information that is received by the Company will be shared with identified staff members to enable the best quality delivery of its commissioned services. Access to information will be controlled, unauthorised use of the Company’s Information Systems or Personnel files will be addressed through the Company’s disciplinary procedures.
‘Personal data’ as defined by data protection legislation means any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. This may include any expression of opinion about the individual or people connected to them.
In addition to consent, contractual necessity, and statutory duty, Inspira may process personal data under lawful bases introduced or clarified by the Data Use and Access Act 2025, including legitimate interests and public task, where such processing is necessary, proportionate, and documented.
Examples include:
Special categories of personal data (as defined by the Data Protection Act 2018) is a set of special categories of personal data. The special categories specifically include genetic data, and biometric data processed to uniquely identify an individual. It is defined as information describing, in relation to the data subject:
In most cases such information will not be stated as confidential, and colleagues may have to exercise professional judgement and discretion in identifying whether information is expected to be confidential and as such considered sensitive personal information.
Inspira needs to collect personal information about people with whom it works with to carry out its business and deliver its services, these services maybe delivered on behalf of other organisations that have a statutory duty to carry out. Inspira collect information on include clients, customers, employees (present, past and prospective), suppliers and other business contacts.
Information held by Inspira may include name, address, email address, date of birth, personal and sensitive information (now called special category, such as ethnic origins, sexual life, health issues and privileged information). In addition, the charity may occasionally be required to collect and use certain types of personal information to comply with the requirements of the law or its statutory duty conducted under contract.
Personal information recorded on its systems will be treated as private and confidential, and as such held within the principles of current legislation. Inspira recognises that company employees will obtain information about individuals and organisations as part of their role or activities that are undertaken. Information that is received by Inspira will be shared with identified staff members to enable the best quality delivery of its services. Access to information is controlled, unauthorised use of the Inspira’s information systems is prohibited.
Special Categories; information that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation shall only be recorded with explicit permission from the subject.
Telephone calls maybe be recorded for training and quality purposes. Periodically a selection of calls will be requested for internal quality assessment. We may engage third parties to carry out quality and compliance monitoring on our behalf and customer data including recorded calls is made available to such third parties for this purpose.
All information is securely recorded and stored by Inspira, and takes the appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction, or damage. Inspira will protect client personal information but cannot guarantee the security of client information when it is transmitted over the internet.
Informed consent is when:
Inspira will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person (including third party), or by completing a form (electronic or paper based).
When collecting personal data, Inspira will ensure that the Individual/Client:
It is necessary for Inspira to process information relating to clients and customers who have entered a contractual service delivered by Inspira; for instance UK Shared Prosperity Fund, ESFA and DWP funded contracts. Maintaining contact with the client will be included as part of the contract, this may be through:
Where information (this includes additional information that provides the ability to understand the client’s needs) is recorded to maintain demonstrable proof of the work undertaken as part of said contract; requests to remove this information may be refused if the records are required to be held for a set time determined by or dependent upon the contract being delivered.
A client must give consent to record and process the information required for the contract, if a client refuses or rescinds their consent to process the data, the client will no longer be eligible for the services provided by the contract.
Inspira who delivers services on behalf of a Council’s statutory duty to maintain contact with a client, maintaining contact with clients can be through the following methods.
Where information (this includes additional information that provides the ability to understand the clients’ needs) is recorded under a statutory legal duty then requests to remove this information will be refused under the following legislations:
This act provides a legal power and duty to provision and share information for the purposes of participation in education and training.
Website https://www.legislation.gov.uk/ukpga/2008/25
Inspira, under contract has a statutory duty to ensure that personal information is kept up to date by communicating with Clients (data subjects) or known contacts of the client whether there have been any changes to the data.
The methods employed for communicating to Clients are through the following methods:
Inspira may use sensitive personal data collected in respect of one product or service to market another appropriate product or service to Clients.
Inspira does not use automated decision‑making or profiling that produces legal or similarly significant effects without appropriate safeguards. Where automated processing is introduced, individuals will be informed, meaningful human review will be available, and complaints will be handled in accordance with the Data Use and Access Act 2025.
Clients may be sent information on what Inspira is doing or offers and competitions that are being run,
Clients may also receive additional information regarding a service that they will be entitled to use as part of their existing contract with Inspira, this forms part of contractual or duty for us to remain in contact with them and to enable Inspira to confirm the client’s current situation, as such is not considered to be marketing.
A client has the right to ‘opt out’ of communications (for example text messaging) regarding the company’s services, products or promotions, any requests will be recorded against the Clients record to ensure the company’s compliance.
The Privacy and Electronic Communications Regulations 2003 specifically regulates the use of electronic communications (email, SMS text, cold calls) as a form of marketing and allow individuals to prevent further contact.
Inspira operates several contracts, each of these contracts requires separate information and data, therefore require information sharing agreements to cover any legislative and contractual sharing of data obtained during the contract term. These agreements detail the length that any of the data is required to be archived for auditing and the legitimate interests of the contract. The retention will vary dependent upon the data being archived and what contract it relates to.
Inspira will not sell or transfer personal information regarding clients to other organisations for profit. Personal data will not be repurposed in a manner incompatible with the original collection purpose unless permitted by law under the Data Use and Access Act 2025 and supported by a documented assessment.
All routine data sharing under statutory, contractual, or legitimate interest bases will be documented, risk‑assessed, and reviewed to ensure compliance with the Data Use and Access Act 2025.
Information will sometimes be obtained from third parties, for example, a third-party organisation delivering a service or statutory duty on behalf of Inspira. The principles for sharing such information will be approved and agreed by both parties.
Personal information will not be disclosed to other persons outside Inspira or organisations without the explicit consent of the person unless there is a requirement in law or statutory duty to do so.
Inspira websites use cookies to allow a richer visitor experience. Where an applicable website uses a cookie control system which will enable the user on their first visit to the website to allow or disallow the use of cookies on their device. All websites hosted and owned by Inspira comply with legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user's device.
Cookies are small files saved to the user's device that track and store information about the user's interactions and usage of the website. This allows the website, to provide visitors with a tailored and richer experience within the website.
Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive, they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.
Inspira uses tracking software provided by Google Analytics and other providers that uses cookies to track visitor usage. The application will save a cookie to the device to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google's privacy policy here for further information.
When a client interacts with Inspira on social media platforms, (for example, by clicking ‘Like’ on our Facebook page, posting messages to the Company’s Facebook timeline, by following Inspira or mentioning the company in a tweet on Twitter) Inspira can then subsequently interact with the client including sending messages via these platforms.
Any Personal Data Inspira may have access to through social media platforms depends upon the Clients configured personal settings on these platforms. However configured Inspira will have access to all public information regarding the client on these platforms. Inspira may also be able to access personal data that others share about Clients (because they control how that is shared, not the client).
Inspira may collect data that is accessible about a client through social media platforms, including but not limited to Facebook and/or Twitter profile picture, gender, and status.
Any interactions that Inspira conducts through social media platforms will be in-accordance with each platform’s rules. Inspira are not responsible for how the platform owners collect and handle personal data. Inspira are not responsible for what third parties post on our social media timelines.
In line with the Data Use and Access Act 2025, Inspira operates a formal internal data protection complaints procedure. Complaints will be acknowledged promptly and responded to without undue delay before escalation to the Information Commissioner’s Office.
Every person or, in cases where it is appropriate, a person with parental responsibility, has the right to see all personal information held about them or the person they are responsible for on Inspira’s records.
Furthermore, you have the right to:
If you or a client has a concern about the way Inspira are collecting or using personal data, you can contact us at DPO@Inspira.org.uk you can also request a copy of your information by completing the Data Subject Access Request form. It may be helpful to review the Data Access Requests - Do's and Don'ts web page at www.inspira.org.uk/data-access-requests-dos-and-donts
If you are still not satisfied with our responses, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/
Inspira is a data controller and processor as defined by the Data Protection Act 2018, and is committed to obtaining, processing, storing and using all personal information held about its clients, customers, employees (present, past and prospective), suppliers and other business contacts in accordance with the principles set out in the Act. Any personal information provided to or collected by Inspira is controlled by:
Mr David Emerson (Data Controller)
Inspira Cumbria Ltd
Gillan Way
Penrith 40 Business Park
Penrith
CA11 9BP