Website Privacy and Cookies Policy and Procedure

Section 1 - Policy

1.1 Team Brain Injury Support understands that if it operates a website, it may need to update its Privacy Policy to ensure that it is compliant with GDPR. Team Brain Injury Support will use this Privacy Policy as a template for its updated version. Team Brain Injury Support understands that this Privacy Policy only needs to be uploaded by Team Brain Injury Support to its website if it collects personal data via its website. Team Brain Injury Support will use the template Fair Processing Notice to inform all other Data Subjects, including Clients, about how Team Brain Injury Support processes personal data other than personal data collected via the website.

1.2 Team Brain Injury Support understands that the form found within the forms section of the GDPR suite of policies in the QCS management system constitutes the template Privacy Policy. Team Brain Injury Support understands that terms in square brackets are optional (depending on whether they apply to Team Brain Injury Support or not) or require completion by Team Brain Injury Support. Team Brain Injury Support will review the Privacy Policy in its entirety to determine which elements are applicable to its website, and which are not relevant.

For example:

• If the template Privacy Policy refers to personal data that is not collected by Team Brain Injury Support via its website, Team Brain Injury Support will delete references to such personal data

• If the website of Team Brain Injury Support does not use cookies, Team Brain Injury Support will delete references to cookies and the Cookie Policy at Team Brain Injury Support

• If Team Brain Injury Support does not transfer personal data outside of the EEA, Team Brain Injury Support will delete the section entitled "Where we store your personal data"

• If Team Brain Injury Support is not required to appoint a Data Protection Officer, Team Brain Injury Support will delete references to the Data Protection Officer or will consider replacing references to the Data Protection Officer with references to the Privacy Officer at Team Brain Injury Support or other person nominated to have day-to-day responsibility for data protection and GDPR

• If Team Brain Injury Support uses personal data collected via its website in a way that is not described in the Privacy Policy, it will consider incorporating additional sections.

• This Privacy Policy directs users to a webpage with a contact form or contact details if they wish to contact Team Brain Injury Support. Team Brain Injury Support will consider whether to provide an alternative contact method instead, such as an email address and/or phone number.

• If Team Brain Injury Support has any concerns or queries in respect of the template Privacy Policy, it will seek legal advice.

1.3 GDPR has changed the way cookies should be incorporated into websites which means that Team Brain Injury Support must explain what cookies will be set and what the cookies will do to the users of its website. Team Brain Injury Support must obtain consent from individuals to store certain cookies on devices. Cookies that are not strictly necessary need consent which is GDPR compliant which means that Team Brain Injury Supportp can no longer rely on implied consent. Team Brain Injury Support will ensure that it uses a cookie banner on its website to obtain consent to the use of cookies in line with this policy and that if no consent is obtained, no cookies will be set.

1.4 Team Brain Injury Support must, therefore, update its processes for collecting consent for cookies. In practice, this means:

• Users must take a clear and positive action to consent to non-essential cookies

• The websites and apps of Team Brain Injury Support must tell users clearly what cookies will be set and what they do, including any third-party cookies

• Pre-ticked boxes or any equivalents, such as sliders defaulted to “on”, cannot be used for non- essential cookies

• The users at Team Brain Injury Support must have control over any non-essential cookies

• Non-essential cookies must not be set on landing pages before you gain the user’s consent Consent is not required for cookies that are defined as “strictly necessary” or that fall within the communication exemption. “Strictly necessary” cookies are those that are essential to providing the service requested by the user. Such cookies must be essential to fulfil their request. Those that are simply helpful or convenient, but not essential, or that are essential for the purposes of Team Brain Injury Support, will still require consent. The communication exemption is about the transmission of a communication over an electronic communications network. For the exemption to apply, the transmission of the communication must be impossible without the use of the cookie. Simply using a cookie to assist the communication is insufficient for the exemption to apply.

Team Brain Injury Support must note, in particular, that cookies used for analytical purposes or those used for marketing and advertising will always need consent as they are considered to be non-essential.

This guidance may change as the latest draft legislation is subject to some challenges on this point. Team Brain Injury Support must read the ICO’s cookie guidance available at: https://ico.org.uk/for- organisations/guide-to-pecr/cookies-and-similar-technologies/

for further information on the types of cookie that require consent.

Section 2 – Procedure

2.1 Team Brain Injury Support will consider whether or not it collects personal data via its website (for example, via enquiry forms, requests to be sent newsletters, requests for provision of services) and whether it needs a Privacy Policy. Team Brain Injury Support acknowledges that the use of cookies constitutes processing of personal data via the website.

2.2 Team Brain Injury Support will review the template Privacy Policy. Team Brain Injury Support will adapt the Privacy Policy before uploading it to its website to ensure that all aspects of the Privacy Policy are relevant and reflect the ways in which Team Brain Injury Support processes personal data collected via its website. Where Team Brain Injury Support has any concerns or queries in relation to its own Privacy Statement, Team Brain Injury Support will seek legal advice.

2.3 Team Brain Injury Support will use the template Fair Processing Notice to inform all other Data Subjects, including Clients, about how Team Brain Injury Support processes personal data other than personal data collected via the website.

Contact Us
VAT Number: GB 377 4847 43
Registered number: 06251793
Registered office: Surety House, Old Redbridge Road, Southampton, Hampshire, SO15 0NE
Team Brain Injury Support, registered in England
Tel: 02380 783 775
e-mail: info@teambi.co.uk
Team Brain Injury Support
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