Privacy Policy

As the data controller, Unseen UK (“we”) promises to respect any personal data that you share with us or that other organisations share with us and to keep it safe. We want to be clear when we collect your data and not do anything you wouldn’t reasonably expect.

Unseen UK wants to ensure that we fundraise in an engaging and efficient way and understanding our supporters through their personal data is important to doing this. Fundraising is essential to ensure that we can continue to carry out our work and ultimately reach our goal of a world where slavery no longer exists.

We are committed to ensuring that our supporters are receiving the communications you want, in the way that you want. From September 2017, we will be asking each new supporter to let us know what information you would like to hear about and how you would like to receive this. Where appropriate, we will also be asking our current supporters to confirm this information, to make sure that you are completely happy.

Unseen keeps its supporters up to date with news on modern slavery, our life changing work with survivors, appeals and campaigns. To ensure you receive the information you would like, if you haven’t already done so, please contact 0303 040 2888 or [email protected].

For fundraising and marketing purposes we do not share your information with third parties. In general, for any other purposes, information is only shared when you have given us your explicit permission to do so, or we have a legal requirement to do so.

We also have a mobile app or a webform accessible via www.modernslaveryhelpline.org/report that can be used to tell us about a suspected situation of modern day slavery or request more information about modern slavery and the services provided by Unseen. This policy will clearly set out the data that we collect, our reasons for collecting it and your options around how that data is used.

Data Protection Officer

Our Data Protection Officer can be contacted via email [email protected].

Where we collect information about you:

We collect information in the following ways:

• When you give it to us DIRECTLY

You may give us your information in order to sign up for one of our events, tell us your story, make a donation, purchase our products or communicate with us.

• When you give it to us INDIRECTLY

Your information may be shared with us by independent event organisers, for example the London Marathon or fundraising sites like Just Giving or Virgin Money Giving. These independent third parties will only do so when you have indicated that you wish to support Unseen UK and with your consent. You should check their Privacy Policy when you provide your information to understand fully how they will process your data.

Our websites or apps

Like most websites, we use “cookies” to help us make our site – and the way you use it – better. Cookies mean that a website will remember you. They’re small text files that sites transfer to your computer (or phone or tablet). They make interacting with a website faster and easier – for example by automatically filling your name and address in text fields. There are more details in our Cookies Policy.

In addition, the type of device you’re using to access our website or apps and the settings on that device may provide us with information about your device, including what type of device it is, what specific device you have, what operating system you’re using, what your device settings are, and why a crash has happened. Your device manufacturer or operating system provider will have more details about what information your device makes available to us.

What personal data we collect, how we use it and the legal basis for processing

Your consent preferences and our mutual legitimate interests will determine the type of information we will collect and how we process it

Supporters: individuals

If you choose to support Unseen, for example through signing up for an event, donating, or volunteering for us, with your consent we will usually collect:

• Your name
• Contact details
• Date of birth
• Bank or credit card details (if you are making a payment)

Where it is appropriate we may also ask:

• If you would like us to stay in touch with you and, if so, what you would like to hear about and in what way (e.g. via email or post)
• Why you have decided to support us
• How you heard about Unseen

We will mainly use your data to:

• Provide you with the services, information or products you have asked for
• Administering your donation or support your fundraising, including processing gift aid
• Keep a record of your relationship with us
• Ensure we know how you prefer to be contacted
• Understand how we can improve our services, products, information

We may also use your information to detect and reduce fraud and credit risk.

Legal basis for processing individual supporter information

Unseen will always use consent as the legal basis for processing data when a supporter has shared their preferences with us. We pro-actively collect consent through the website, in letters, verbally and in person where appropriate. Unseen always aims to ask for your consent, including how you would like to be communicated with and what you would like to hear about. We will always respect your consent decisions.

Sometimes, we may not have explicit consent to contact you. This may happen if you give us a surprise donation in the post for example. When we do not have your explicit consent, we will use legitimate interests as the legal basis in which to contact you. We will only do so by post or telephone. Unseen uses legitimate interest as it’s legal basis to communicate with its active supporters, which is defined as any individual who has donated in the current and last two financial years. Using legitimate interests, we will tell our supporters about the charities news, impact, appeals, campaigns and events, unless they tell us not to. We believe it is in the interests of the charity and its supporters to stay connected about the impact their support is having.

Unseen will only communicate with donors who have supported us through a third party when we have your explicit consent to do so. We will only send you communications that you have decided you would like to receive.

How Unseen will collect information about you and what we will do with it.

We use data you provide, sometimes together with data obtained elsewhere, to manage our fundraising efficiently and effectively so we can raise more to spend on fighting human trafficking and modern slavery. This will include data which helps us effectively target and tailor our communications so that we can make appropriate requests to individuals who may be able to support us at a higher level.

We use publicly available information to find new potential supporters and invite them to get involved in supporting our cause. We do this by using the data to provide insight so we can tailor specific communications which may be of interest to them. External data sources may include publicly available information such as from Companies House, Charity Commission and other charity registers, Who’s Who and Debrett’s guides, Electoral Roll, reputable newspaper articles, publications, company websites and biographies on professional networking sites as well as geographic and demographic information based on your postcode.

This approach gives us a better understanding of our supporters and enables us to segment our database so we can provide the most efficient and effective information to our existing and potential new supporters.

If you would prefer us not to use your data in this way please let us know by emailing [email protected] or calling us on 0303 040 2888.

Supporters: organisations

If an organisation you belong to decides to support Unseen, for example through signing up for an event, donating, or volunteering for us, we will usually collect:

• Organisation name
• Contact details of the organisation
• Contact details of a key contact
• Bank or credit card details (if you are making a payment)

Where it is appropriate we may also ask:

• If you would like us to stay in touch with you and, if so, what you would like to hear about and in what way (eg via email or post)
• Why you have decided to support us
• How you heard about Unseen

We will mainly use your data to:

• Provide you with the services, charity information, products or partnership activities that you have asked for
• Administering your donation or support your fundraising
• Keep a record of your relationship with us
• Ensure we know how you prefer to be contacted

Legal basis for processing an organisation’s data

Unseen will always use consent as the legal basis for processing data when an organisation has shared their preferences with us. We pro-actively collect consent through the website, in letters, verbally and in person where appropriate. Unseen always aims to ask for your consent, including how you would like to be communicated with and what you would like to hear about. We will always respect your consent decisions.

Sometimes, we may not have explicit consent to contact you. This may happen if give us a surprise donation in the post for example. As a ‘corporate subscriber’, we will use legitimate interests as the legal basis in which to contact you, via post, telephone, email or text. Unseen uses legitimate interests as it’s legal basis to communicate with its active supporters, which is defined as any organisation who has donated in the current and last two financial years. Under legitimate interests, we will tell our supporters about the charities news, impact, appeals, campaigns and events, unless they tell us not to.

Building partnerships is vitally important to tackling modern slavery. We may get in touch with organisations using the legal basis of legitimate interests to discuss building a fundraising or strategic partnership.

App or webform users

When you submit a report via the mobile app or the webform you may give us the following information:

• name or a pseudonym
• Email address
• Telephone number

However, the app or webform will also allow you to submit your form without any of these details being included.

We will use this information to record a suspected incidence of modern day slavery or prepare a response to a question or a request you have raised.

The app or webform asks whether or not we can contact you. This is to allow us the opportunity to gather further information and determine how best we can help you. We will only contact you if you have given us permission to do so.

The app or webform asks whether you are happy for the information you have shared with us to be shared with a third party. Third parties who we may wish to pass your information to include police and other law enforcement agencies and local authorities.

We will only pass your information onto a third party if you have given us permission to do so, subject to the following exceptions:

• to comply with the law (eg the police, Inland Revenue and Council Tax Registration Officer) or a court order, or a request from a regulatory body (Housing Corporation, Social Services, Inspection Unit)
• where there is a clear risk or risk of harm to an individual
• anonymously for bona fide statistical or research purposes, provided it is not possible to identify the individuals to whom the information relates;

In these cases, the client/potential victim will be informed of the need to breach confidentiality prior to this happening or in all instances, as soon as possible afterwards if prior notification is not possible.

Sharing your story

Some people choose to tell us about their experiences of modern slavery to raise awareness about the crime. They may take on a role as an Ambassador or volunteer or patron and may choose to share sensitive information related to their experiences in addition to their biographical and contact information.

Unseen always ensures that we have the explicit and informed consent from individuals, to share their story publicly at events, in materials promoting our campaigning and fundraising work, or in documents such as our annual report.

Children’s data

Unseen sometimes collects and manages information from children. Information may be collected when children attend our events or fundraise for us. Unseen always secures parental/a guardian’s consent before collecting information about children under the age of 13 and makes reasonable efforts to verify that a parent or guardian has provided the appropriate consent. Our events have specific rules about whether children can participate, and we will make sure advertising for those events is age appropriate. Unseen will never proactively contact a child whose information has been collected through an event or fundraising.

How we keep your data safe and who has access

We ensure that there are appropriate technical controls in place to protect your personal details. For example, our online forms are always encrypted, and our network is protected and routinely monitored. All data is retained within the EEA.

We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors.

Occasionally we use external companies to collect or process personal data on our behalf. We do comprehensive checks on these companies before we work with them and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal data they have collect or have access to.

We may need to disclose your details if required to the police, regulatory bodies or legal advisors.

We will only ever share your data in other circumstances if we have your explicit and informed consent

Your rights

Right to be informed

Unseen wants to ensure that you know how we collect and use your data. This Privacy Policy details our purposes in doing so. We will proactively promote our Privacy Policy to our supporters at the time they give us their data. The Privacy Policy is accessible on the homepage of Unseen’s website, will be promoted on donation acknowledgements, email signatures and all fundraising communications where appropriate.

Retention period- how long will we keep your information for?

Unseen actively asks for consent to use your information. We will ask for your consent at least every three years to ensure you are still happy for us to communicate with you, and to give you a chance to update what you would like to hear about. If you do not consent to us continuing to communicate with you and you have not donated to Unseen in the last 7 years, your information will be deleted within 28 days.

If you have donated to Unseen we will retain your:

• Name
• Contact details
• Donation amount and date

for seven years, which is in line with HMRC recommendations on accounting for financial records. After this period, if you do not consent to us communicating with you further, your information will be deleted.

Right to be forgotten

You have the right to request that your information is deleted. You can request to have your information deleted by calling: 0303 040 2888 or emailing [email protected].

Your information will be deleted within 28 days if we do not need to adhere to the financial records policy as detailed above. We will cease communicating with you within 28 days of the request.

Right to rectification- keeping your information correct and up to date

We depend on you letting us know if there are any changes to your information. Unseen will not use any third parties to update your personal information. We would really appreciate it if you let us know if your contact details change, so we can continue to keep in touch. Please email [email protected] if you need to rectify any personal information we have.

Right to access- your right to know what information we know about you

You have the right to request the data that we hold on you. This is called a Subject Access Request. You can make a request verbally or in writing by calling 0303 040 2888, emailing [email protected] or writing to Unseen, 7 Hide Market, West Street, Bristol BS2 0BH. We will respond to Subject Access Requests within 28 days of receipt. There is no charge for this request.

Right to portability- transferring your data

Your right to data portability allows you to obtain and re-use your personal data with other organisations. Unseen will ensure that your data is able to be moved, copied and transferred easily from one IT environment to another in a secure way. We will ensure that the information is structured, commonly used and in a machine-readable format, for example in a clearly labelled spreadsheet. Contact us on 0303 040 2888 or [email protected] to exercise your right to portability. We will respond within 28 days.

Right to restrict processing- ask us to stop using your data

You have a right to ask us to change or stop processing your personal data and, if it’s not necessary for the purpose you provided it to us for (eg processing your donation or registering you for an event), we will do so. Upon receipt of a restriction request, we will not process your data whilst we are implementing your request. Contact us on 0303 040 2888 or [email protected] to exercise your right to restriction.

Rights related to automated decision making including profiling

We may build a profile on our supporters to ensure that our communications are relevant and timely, and to provide an improved experience for our supporters therefore legitimate interests is our legal basis for processing data in this way. Profiling also allows us to target our resources effectively, which donors consistently tell us is a key priority for them. For example, if we are running an event in Bristol, we may use our supporters’ profiles to understand which of our supporters are in Bristol and then we will send invites to those people. Importantly, understanding our supporters through profiling, enables us to raise more funds, sooner, and more cost-effectively to continue our mission of tackling modern day slavery. When building a profile, we may analyse geographic, demographic and other information relating to you to better understand your interests and preferences and contact you with the most relevant communications. In doing this, we may use additional information such as other publicly available data about you, for example addresses, listed Directorships or typical earnings in a given area.

Right to object

If you wish to change any of your preferences around how we use your personal data or how we communication with you please contact us on 0303 040 2880 or [email protected]. Such changes might include how frequently you wish to be contacted by us, the types of subjects you wish to receive information on from us and the format of these communications.

Complaints process

Unseen is committed to providing an excellent service to all stakeholders working in an open and accountable way that builds trust and respect. We have developed a Fundraising Complaints Policy and Procedure that explains our approach to receiving complaints.

Our aim

Unseen’s Fundraising Complaint Procedure is intended to ensure that all complaints are handled fairly, consistently and wherever possible resolved to the complainant’s satisfaction.

Unseen’s responsibility will be to:

• acknowledge the formal complaint in writing
• respond within 10 working days
• deal reasonably and sensitively with the complaint
• take appropriate action if required

If you wish to make a complaint, in the first instance, please contact the person or email address that you usually interact with at Unseen. If this informal approach does not resolve your concerns, then please request a copy of Unseen’s formal Complaints Policy and Procedure via [email protected]. This will be sent to you on the day of request. If we hear nothing further from you within 28 calendar days from this date, we will regard the complaint to be closed.

Upon receipt of Unseen’s Complaints Policy and Procedure, you should write a formal letter of complaint to the line manager of the member of staff concerned that sets out the details of your complaint, the consequences for you as a result, and the remedy you are seeking.

You can expect the complaint (stage 1) to be acknowledged within four working days of receipt. You should get a response and an explanation within 10 working days. Following receipt of this letter you will have 28 days in which to ask for the complaint and response to be reviewed if you are dissatisfied with the response they have received.

If you are unsure which member of Unseen staff to write to, your complaint should be addressed to Unseen’s Data Controller. Our contact details are Unseen, 7 Hide Market, West Street, Bristol BS2 0BH. Telephone number 0303 040 2888. Website address www.unseenuk.org.

If you are dissatisfied with the response to your complaint, then two further levels of escalation are available. Stage 2 will be dealt with by a member of the Senior Management Team and Stage 3 by the Chief Executive and the Chair of the Trustees. The detailed steps and timescales for these stages are contained in the Fundraising Complaint Procedure.

If you have any questions please send these to [email protected].

For further information see the Information Commissioner’s guidance here: https://ico.org.uk/your-data-matters/.

The Modern Slavery & Exploitation Helpline Privacy Policy

The Modern Slavery & Exploitation Helpline (MSEH), is operated by Unseen (UK) and follows Unseen’s privacy policy. The following policy should be read in conjunction with Unseen’s Privacy Policy.

The MSEH is committed to hosting a helpline that is victim-centred and prioritises the wellbeing, safety and recovery of potential victims. The MSEH strives to protect the confidentiality of personal data provided by individuals contacting the Modern Slavery & Exploitation Helpline (MSEH). All communication with the MSEH will be treated as confidential to the extent permitted by applicable law. The policies outlined below have been designed to ensure the privacy and safety of the individual contacting the MSEH, victims and survivors, and the Modern Slavery & Exploitation Helpline staff.

As the data controller, Unseen (UK) (“we”) promises to respect any personal data that you share with us or that other organisations share with us and to keep it safe. We want to be clear when we collect your data and be transparent about how we use your data.

The Modern Slavery & Exploitation Helpline can be contacted by calling 08000 121700 or by using Unseen’s mobile app or a webform accessible via www.modernslaveryhelpline.org/report. You may wish to tell us about a suspected situation of modern slavery or request more information about modern slavery or relevant services. This policy will clearly set out the data that we collect, our reasons for collecting it and your options around how that data is used.

Data Protection Officer
Our Data Protection Officer  can be contacted via email [email protected].

Our websites or apps
Like most websites, we use “cookies” to help us make our site – and the way you use it – better. Cookies mean that a website will remember you. They’re small text files that sites transfer to your computer (or phone or tablet). They make interacting with a website faster and easier – for example by automatically filling your name and address in text fields. There are more details in our Cookies Policy.

In addition, the type of device you’re using to access our website or apps and the settings on that device may provide us with information about your device, including what type of device it is, what specific device you have, what operating system you’re using, what your device settings are, and why a crash has happened. Your device manufacturer or operating system provider will have more details about what information your device makes available to us.

What personal data we collect, how we use it and the legal basis for processing
The objective of the MSEH is to provide a tool for victims of modern slavery to safely seek the help and information they urgently need, enable members of the public to report potential and suspected incidences of modern slavery and frontline professionals to call for support and advice. The Helpline significantly increases the UK’s effective capability of dealing with modern slavery and therefore the lawful basis for processing personal information is that of carrying out a task in the public interest. Additionally, some of the data the Helpline collects rests on the consent of the caller, while all of the data the Helpline collects furthers the legitimate interests and mission of Unseen to end modern slavery.

Case studies from the Modern Slavery & Exploitation Helpline are anonymised to protect the identities of individuals involved.

Contacting the Helpline
The MSEH treats communications with the Helpline as confidential while also prioritising the sharing of information relating to suspected instances of modern slavery with local authorities, police, relevant government entities, or other NGOs. Any sharing of information is limited by an overarching policy of ‘Do No Harm.’ As such, the Helpline will make every effort to ensure that the information shared by the MSEH will not increase risk of harm to any individual. This means that if the MSEH’s staff have a reasonable basis to suspect that the sharing of information about any particular instance or victim of modern slavery or trafficking would place suspected victims or survivors in greater danger or lead to greater harm suffered by suspected victims or survivors, then the MSEH may refrain from referring the information concerned.

Contact by phone call
When you contact the Helpline by phone one of our trained advisors will answer your call. If you wish you may contact the Helpline without giving any personal details such as your name or contact details; please note section below on Caller ID. We will record any details that you share with us.

The Helpline advisor will ask you whether or not we can contact you. This is to allow us the opportunity to gather further information and determine how best we can help you. We will only contact you if you have given us permission to do so.

The Helpline advisor will ask you whether you are happy for your personal data, such as your name and contact details, that you have shared with us to be shared with a third party. Third parties who we may wish to pass your information to include police and other law enforcement agencies, local authorities and other NGOs.

Where contact information is required, and the sharing of contact details is a condition for requested action, such as application to the National Referral Mechanism, the MSEH staff will inform the individual of the conditions to share contact information associated with the action requested by the individual and proceed in collecting and sharing that contact information with the understanding and consent of the caller.

Where the MSEH determines that it may be beneficial to have a third party contact the caller directly, the caller’s consent to share the individual’s contact information with that third party will be confirmed before any contact information is shared. Individuals can withdraw their consent to be contacted or to have their contact information shared subsequently, according to the processes outlined above, in part or in full at anytime.

We will only pass your personal data or contact information onto a third party if you have given us permission to do so or one of the following exceptions applies:

• to comply with the law (eg the police, Inland Revenue and Council Tax Registration Officer) or a court order, or a lawful request from a regulatory body (Housing Corporation, Social Services, Inspection Unit)
• where there is a clear risk of imminent harm to an individual
• a call references the suspected abuse or neglect of a minor who remains at risk
• anonymously for bona fide statistical or research purposes, provided it is not possible to identify the individuals to whom the information relates.

In cases a-c above, we will inform the caller or potential victim of the need to breach confidentiality prior to this happening or in all instances, as soon as possible afterwards, where possible, if prior notification is not possible.

For specific cases in which a referral to a third party, such as police, local authorities or an NGO is needed, the MSEH will make reasonable efforts to protect the identity of callers who wish to remain anonymous. The MSEH will not confirm that a specific individual has or has not contacted the Helpline, unless the individual has provided the MSEH with explicit consent to do so.

App or webform users
When you submit a report via the mobile app or the webform you may give us the following information:

• name or a pseudonym
• Email address
• Telephone number

However, the app or webform will also allow you to submit your form without any of these details being included.

We will use this information to record a suspected incidence of modern day slavery or prepare a response to a question, concern, or a request you have raised.

The app or webform asks whether or not we can contact you. This is to allow us the opportunity to gather further information and determine how best we can help you. We will only contact you if you have given us permission to do so.

The app or webform asks whether you are happy for the information you have shared with us to be shared with a third party. Third parties who we may wish to pass your information to include police and other law enforcement agencies, local authorities and other NGOs.

We will only pass your information onto a third party if you have given us permission to do so, subject to the following exceptions:

• to comply with the law (e.g. the police, Inland Revenue and Council Tax Registration Officer) or a court order, or a request from a regulatory body (Housing Corporation, Social Services, Inspection Unit)
• where there is a clear risk of imminent harm to an individual
• a call references the suspected abuse or neglect of a minor who remains at risk
• anonymously for bona fide statistical or research purposes, provided it is not possible to identify the individuals to whom the information relates.

In cases a-c, the caller or potential victim will be informed of the need to breach confidentiality prior to this happening or in all instances, as soon as possible afterwards, where possible, if prior notification is not possible.

Call backs

In certain cases, the MSEH may deem it necessary or advisable to place outgoing calls (“Call Backs”) to follow up on matters brought to the MSEH’s attention.  The MSEH will place such Call Backs only to individuals who have provided their contact information directly to the MSEH and have provided prior consent to such a Call Back.   

A caller may provide such consent orally during a call or when submitting on an online webform or submission via the app.   A caller may limit the scope of his or her consent to permit the use of Contact Information to facilitate a Call Back by the MSEH only, in which case the MSEH will not disclose the Contact Information to any third party, unless one of the above exceptions apply.  A caller also may specify whether a message may be left at the telephone number provided (whether with a person or on an answering machine/voicemail system), and how the relevant the MSEH should refer to itself and to the individual when leaving any such message.

Caller ID

The Helpline uses a phone system that displays incoming phone numbers.  The MSEH may record information about incoming helpline calls made available through the Caller ID function (“Caller ID Information”).  This enables Helpline advisors to identify if a caller has called before from that number and therefore speed our ability to respond to a potential victim of modern slavery or to be used in the exceptions listed above. 

The MSEH will not use Caller ID information to facilitate Call Backs except in rare circumstances, for example when it is believed that the caller has knowledge of a child or vulnerable adult at risk and this information is necessary to ensure immediate safety.

Call recordings

Callers are informed at the start of a call by a recorded message before speaking with a Helpline Advisor, that calls to the Helpline may be recorded for training and quality purposes. Unless specifically saved, call recordings are automatically deleted after 30 days. Call recordings may be used by the Helpline Advisor immediately in order to aid the input of notes, after which point it would be deleted.  Call recordings may be used confidentially, within the Helpline only for training purposes.  Call recordings are not routinely included with referrals to third parties and recordings would only be shared externally in accordance with this privacy policy.

Children’s data

From time to time the Helpline receives personal information relating to children, some who are older than 13 years old and some who are younger than 13 years old.  For the latter category we do not seek to verify the age of the child or to seek consent for holding their personal information.  The lawful basis for the processing of the personal information of children is that of carrying out a task in the public interest and may be necessary to protect vital interests of the child. 

Referring to Third Parties

When a caller provides information about a potential case of modern slavery, the MSEH conducts a comprehensive and formal review of all such cases.  The MSEH respects an individual’s right to make the decision regarding whether or not to report information about his/her identity to police or other parties. For suspected instances of modern slavery and for other suspected crimes, the MSEH may report information about specific situations to one or more specialised government agencies, police units, potentially involved businesses, or NGOs with expertise in addressing modern slavery or vulnerable individuals.  

If the caller consents to share his/her contact information with police, the MSEH will include this information in the police referral, and police may contact the individual for additional information. The MSEH will not disclose identifying information about the caller to third parties, or confirm that information shared resulted from any specific helpline call or caller, without the caller’s prior consent, except in circumstances outlined in the following section entitled ‘exceptions to caller confidentiality’. If any individual who has contacted the MSEH wishes to remain anonymous, the MSEH will take reasonable measures to protect the contact’s anonymity.  Additionally, the MSEH reserves the right to share selected information in a redacted form with the public authorities regarding suspected instances of modern slavery/trafficking or other crimes to facilitate crime prevention and data collection while protecting the identity of any given contact.

In accordance with the MSEH’s adoption of a ‘Do No Harm’ approach, if the MSEH Staff have a reasonable basis to suspect that the sharing of information about any particular instance or victim of modern slavery may lead to greater harm suffered by suspected victims or any other person involved, then the MSEH will refrain from reporting the information.

Once a case is reported to police, The MSEH is not responsible for how this information is used. 

Exceptions to caller confidentiality

As noted above, the MSEH seeks to preserve the anonymity of any given caller in accordance with their wishes.  Nevertheless, the MSEH reserves the right to disclose Caller Contact Information, Caller ID Information, or any other information collected in connection with a given form of communication to the MSEH to an appropriate authority or police, without the caller’s consent, where:

• a call references the suspected abuse or neglect of a child or vulnerable adult who remains at risk;
• the caller has indicated that he/she has or may harm him/herself or others;
• the caller is in imminent harm; or
• the MSEH is required by law to disclose such information.

As appropriate, the MSEH will attempt to notify a caller that such report has been or is likely to be made. 

What information is stored from calls?

The MSEH Helpline Advisers enter notes onto a secure database, including the details provided by the caller or gathered from an online submission through the website or app. The MSEH does not investigate or attempt to corroborate the reports given; the information is stored according to what is reported. Information recorded may include any details shared by the caller regarding the situation and people who may potentially be involved, including minors or individuals unaware of the report to the MSRHC. Relevant information may be kept about without the respective individuals’ knowledge, for example information around a suspected perpetrator, to the extent that it is reasonable and necessary to do so, according to the Helpline’s carrying out of a public interest and to further the legitimate interests of the Helpline to end modern slavery, abuse and exploitation and facilitate safeguarding of vulnerable people. As noted above, referenced individuals will not be contacted by the Helpline unless they call themselves to provide consent.

How we keep your data safe and who has access?

We ensure that there are appropriate technical controls in place to protect your personal details. For example, our online forms are always encrypted, and our network is protected and routinely monitored.  All data is retained within the EEA.

We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors.

Occasionally we use external companies to collect or process personal data on our behalf. We do comprehensive checks on these companies before we work with them and put a contract or confidentiality agreement in place that sets out our expectations and requirements, especially regarding how they manage the personal data they have collected or have access to.

Receiving one’s own data

In circumstances where a victim of modern slavery or individual has contacted the helpline, he/she may request that the MSEH provide a summary of his/her call to the victim/victim’s lawyer or to himself/herself.  In circumstances where identifiable information about multiple victims is referenced in the case, information may be redacted to preserve the confidentiality of any and all victims or other individuals who have not provided consent to release their information. The MSEH reserves the right to refuse access to information about a victim’s call if there is legitimate reason to believe access will have a negative impact on victims or callers involved in the case or where the identity of the requesting victim cannot be verified as such.

An individual may have the right to receive information that the MSEH holds about them. If you would like to exercise these rights, then contact the MSRHC. The MSEH will honour lawful exemptions applying to Subject Access Requests.

Such requests to receive one’s one information or that information be sent to a third party, should be made in writing and submitted to the MSEH at [email protected] or [email protected], and should include the subject’s signature, scope and date of request.  If the individual wishes to have such notes released to a lawyer, adviser, or other third party, the individual must include in this request a signed statement authorizing the MSEH to release such notes to a specified third party.  

Information retention

Data will be kept for as long as necessary to fulfil the purposes for which they were collected.

Right To erasure

An individual about whom the MSEH holds information may have the right to have the information about them erased. If you would like to exercise these rights, then contact the MSEH via email to [email protected] or [email protected], or call 08000 121 700.

Right to rectification

An individual about whom the MSEH holds inaccurate personal data has the right to request that it be corrected. If you would like to request that information held about you be corrected or more fully completed, please contact the MSEH via email to [email protected] or [email protected], or call 08000 121 700.

Right to portability- transferring your data

Your right to data portability allows you to obtain and re-use your personal data with other organisations. Unseen will ensure that your data is able to be moved, copied and transferred easily from one IT environment to another in a secure way. We will ensure that the information is structured, commonly used and in a machine-readable format, for example in a clearly labelled spreadsheet.  Contact us via email to [email protected] or [email protected], or call 08000 121 700. to exercise your right to portability. We will respond within 28 days.

Right to restrict processing- ask us to stop using your data

Individuals about whom the MSEH holds personal data have the right to request that the use of their data be restricted or supressed. For such requests, please contact the MSEH via email to [email protected] or [email protected], or call 08000 121 700.

Complaints process

If you wish to make a complaint, in the first instance, please contact the person or email address that you usually interact with at the Helpline.  If this informal approach does not resolve your concerns, then please request a copy of Unseen’s formal Complaints Policy and Procedure via [email protected].  This will be sent to you on the day of request.  If we hear nothing further from you within 28 calendar days from this date, we will regard the complaint to be closed.

Upon receipt of Unseen’s Complaints Policy and Procedure, you should write a formal letter of complaint to the line manager of the member of staff concerned that sets out the details of your complaint, the consequences for you as a result, and the remedy you are seeking.

You can expect the complaint (stage1) to be acknowledged within 4 working days of receipt. You should get a response and an explanation within 10 working days. Following receipt of this letter you will have 28 days in which to ask for the complaint and response to be reviewed if you are dissatisfied with the response they have received.

If you are unsure which member of Unseen staff to write to, your complaint should be addressed to Unseen’s Data Controller.  Our contact details are Unseen, 7 Hide Market, West Street, St. Philips, Bristol, BS2 0BH.  Telephone number 0303 040 2888. Website address www.unseenuk.org.

If you are dissatisfied with the response to your complaint, then two further levels of escalation are available.  Stage 2 will be dealt with by a member of the Senior Management Team and Stage 3 by the Chief Executive and the Chair of the Trustees. 

If you have any questions please send these to [email protected], and for further information see the Information Commissioner’s guidance here: https://ico.org.uk/your-data-matters/