Privacy Policy for The Moving On Project

Last updated: 29th June 2025

Privacy Overview

Your privacy and confidentiality are fundamental to our work. As a registered charity providing mental health support to vulnerable young people, we are committed to protecting your personal information and maintaining the highest standards of data protection.

This privacy policy explains how we collect, use, store, and protect your personal information in accordance with UK GDPR, the Data Protection Act 2018, and guidance from the Charity Commission, Fundraising Regulator, and professional mental health standards.

If you have any questions about this policy, please contact our Data Protection Officer at dpo@the-mop.org or info@the-mop.org.

Who We Are

The Moving On Project is a registered charity (Charity No. [Registration Number]) providing mental health support, counselling, and wellbeing services primarily to young people aged 11-25 in Hampshire, particularly the Fareham and Gosport areas.

Our Registration Details

  • Charity Name: The Moving On Project
  • Registered Address: The Xperience Youth Centre, Trinity Street, Fareham, PO16 7SJ
  • ICO Registration: [ICO Registration Number]
  • Professional Registrations: Registered with professional counselling bodies including BACP

We are the data controller for the personal information we process about you.

Information We Collect

We collect different types of information depending on how you interact with us:

Basic Contact Information

  • Name and contact details (phone, email, address)
  • Emergency contact information (for service users)
  • Referral source information (GP, school, self-referral)
  • Correspondence records when you contact us

Service-Related Information

  • Assessment and referral information to understand your needs
  • Session attendance records and basic progress notes
  • Risk assessment information for safeguarding purposes
  • Outcome measurement data to evaluate service effectiveness

Website and Digital Information

  • Website usage data (anonymised analytics)
  • Form submissions through our website
  • Email engagement data (open rates, click-through rates)
  • Technical data (IP address, browser type, for security purposes)

What We Do NOT Collect

  • Detailed personal browsing history outside our website
  • Social media profile information (unless you specifically provide it)
  • Financial information (beyond what's necessary for service funding)
  • Unnecessary personal characteristics or lifestyle information

Lawful Basis for Processing Your Data

We process your personal data under the following lawful bases:

For Service Delivery

  • Legitimate Interest: Providing mental health support and counselling services
  • Consent: Where you have explicitly agreed to us processing your data
  • Public Task: Delivering public health and wellbeing services

For Safeguarding

  • Vital Interests: Protecting you or others from serious harm
  • Legal Obligation: Compliance with safeguarding duties

For Fundraising and Communications

  • Legitimate Interest: Promoting our charitable objectives and fundraising
  • Consent: Where you have opted in to receive communications

Special Category (Sensitive) Data

Mental health information is considered "special category" data under GDPR and receives enhanced protection.

Types of Special Category Data We Process

  • Health data: Mental health assessments, treatment notes, progress records
  • Biometric data: None (we do not collect fingerprints, facial recognition, etc.)
  • Racial or ethnic origin: Only if relevant to providing culturally appropriate support

Legal Basis for Processing Special Category Data

  • Health and social care: Providing health and social care services
  • Explicit consent: Where you have given clear, specific consent
  • Vital interests: Protecting life in emergency situations
  • Public health: Contributing to public mental health initiatives

Extra Protections

  • Enhanced security measures for all mental health data
  • Access restricted to authorised staff only
  • Regular security training for all team members
  • Encrypted storage and transmission of sensitive data

Protection of Young People's Data

We take extra care when processing data about young people in line with the ICO's Age Appropriate Design Code and children's rights.

Age and Consent

  • Under 13: We require parental/guardian consent for all data processing
  • 13-16 years: We assess the young person's capacity to consent, involving parents/guardians where appropriate
  • 16+ years: Young people can generally consent for themselves, though we may involve parents/guardians for safeguarding

Special Protections for Young People

  • Privacy-by-design approach in all our systems
  • Minimal data collection - only what's necessary
  • Enhanced security for all data involving minors
  • Regular review of consent and data processing
  • Clear, age-appropriate privacy information
  • Right to have data deleted when they reach adulthood (subject to legal obligations)

When We Involve Parents/Guardians

  • If the young person lacks capacity to consent
  • For safeguarding concerns
  • When required by our insurance or professional bodies
  • If explicitly requested by the young person

Disclosure of Your Information

We may disclose your personal information to third parties if:

  • The Moving On Project is acquired by a third party, in which case personal data held will be transferred.
  • We are under a legal duty to disclose or share your personal data.
  • We need to protect the rights, property, or safety of The Moving On Project and its users.

Your Rights

You have the right to:

  • Access and verify the personal information we hold.
  • Request correction or deletion of your personal information.
  • Withdraw consent for data processing.
  • Restrict processing in certain circumstances.
  • Object to automated decision-making and data processing.
  • Request that we do not send you marketing communications.
  • Complain to the ICO if your rights have been violated.

Subject Access Request

You may request a copy of the personal information we hold. To do so, you may need to provide proof of identity (e.g., passport, driving license). We will respond within one month of receiving a valid request.

Data Processing & Security

Fair Processing Notice

We collect and store minimal personal data to provide our services effectively. This includes:

  • Contact details (e.g., name, email, phone).
  • Information required to support you, including your sessions with a counselor.

Are My Details Shared?

We maintain strict confidentiality. However, we may share information if:

  • We believe you or someone else is in danger of significant harm.
  • We are required to provide anonymized statistics to NHS Digital.

What Information Is Shared with NHS?

Some counseling sessions are funded by the NHS. Because of this, we share:

  • Date of birth, postcode, gender (if provided).
  • GP practice details.
  • Referral and session attendance data.

Contact Us

If you have any concerns or questions, reach out to us:

Email: info@the-mop.org
Phone: 01329 822331
Address: The Xperience Youth Centre, Trinity Street, Fareham, PO16 7SJ