Privacy Policy

Our Heartbeats 

1. Introduction

Our HeartBeats CIC is a community interest company delivering DJ workshops, music education, creative mentoring, and cultural events for young adults, with a particular focus on refugees and people seeking asylum.

This Privacy Policy explains how we collect, use, store, and protect your personal information, and your rights in relation to that information.

We recognise that many people we work with may come from vulnerable backgrounds and may face specific safety or privacy risks. For this reason, we take particular care to protect personal data, apply safeguarding-informed data practices, and respect individual boundaries at all times.

You may choose to engage with Our HeartBeats CIC using a pseudonym if you prefer. Choosing not to share certain personal information will not affect your ability to take part in our activities.

Contact details:
Email: kensaye@ourheartbeats.org.uk
Website: (insert website URL)

2. Information We Collect and Why

We only collect personal information that is necessary to deliver our activities safely, effectively, and responsibly.

Participants

When you take part in our programmes, workshops, or events, we may collect:

  • Your name (or chosen pseudonym)

  • Contact details (such as email or phone number)

  • Age or age range (to ensure activities are appropriate)

  • Preferred language

  • Emergency contact details

  • Attendance and participation records

  • Any access, wellbeing, or support needs you choose to share

We may also collect photographs, videos, audio recordings, or quotes only with your explicit consent, as set out in our Photo, Video & Media Consent Form.

You are never required to share information about your immigration status, country of origin, or personal history. Any such information is provided voluntarily and handled with additional care.

Supporters, Partners, and Communications

When you contact us, sign up for updates, or support our work, we may collect:

  • Name and contact details

  • Communication preferences

  • Correspondence records

Donations and Fundraising

If you make a donation, we may collect:

  • Name and contact details

  • Payment or banking information (processed securely via third-party providers)

  • Donation history (for accounting and reporting purposes)

Recruitment

For staff, freelancers, or volunteers, we may collect:

  • Contact details and employment history

  • Right to work documentation

  • References

  • DBS or other disclosure information where required

  • Equality monitoring data (where provided voluntarily)

Website Use

When you visit our website, we may automatically collect:

  • IP address

  • Browser and device information

  • Pages visited and usage data

This information helps us understand how our website is used and improve its functionality.

3. Special Protections for Vulnerable Participants

We understand that some participants may face increased risks if their personal information is shared.

To protect you:

  • You may use a pseudonym

  • Consent for media use is always explicit and optional

  • We anonymise information used in reports and evaluations

  • We never share immigration status information unless legally required

  • Access to personal data is restricted to authorised staff only

Our team is trained in safeguarding, confidentiality, and data protection, and all data handling is informed by our Safeguarding Policy & Procedures.

4. Legal Basis for Processing Personal Data

Under UK GDPR, we rely on the following legal bases to process personal data:

  • Legitimate interests – to deliver our charitable activities, support participants, and manage our organisation

  • Consent – for media, marketing, storytelling, and sensitive personal data

  • Legal obligation – for financial, employment, or regulatory requirements

  • Contract – where processing is necessary for employment or service agreements

  • Vital interests – where processing is necessary to protect someone’s life or safety

You may withdraw consent at any time.

5. Your Rights

You have the right to:

  • Access your personal data

  • Request corrections to inaccurate data

  • Request deletion of your data (subject to legal limits)

  • Restrict or object to certain processing

  • Request data portability

  • Withdraw consent at any time

Exercising your rights will not affect your participation in Our HeartBeats CIC activities.

We will respond to requests within one month.

6. Where We Get Your Information

Most information is provided directly by you.

In some cases, we may receive information from:

  • Partner organisations (with appropriate consent)

  • Family members or carers supporting your participation

  • Referees during recruitment

  • Publicly available sources (where relevant)

7. Data Retention

We retain personal data only for as long as necessary:

  • Participant records: for the duration of involvement and up to 7 years afterward

  • Media content: until consent is withdrawn

  • Donation records: 7 years

  • Recruitment records: 6 months for unsuccessful applicants; duration of engagement plus 6 years for staff

  • Safeguarding records: in line with safeguarding and legal requirements

Data is securely deleted when no longer required.

8. Information Sharing

We only share personal data when necessary and appropriate, including:

  • Safeguarding referrals to relevant authorities

  • Regulatory or legal obligations

  • Audits or inspections

  • Partner organisations (with consent)

We will never:

  • Sell your personal data

  • Share immigration information without legal obligation

  • Share participant lists with authorities

  • Use your data in a way that puts you at risk

9. International Data Transfers

We primarily store data within the UK.

Where international services are used (e.g. cloud platforms), we ensure appropriate safeguards are in place to comply with UK GDPR.

10. Children and Young People

Our HeartBeats CIC primarily works with adults aged 18–25.

If activities involve anyone under 18, we apply enhanced safeguarding and data protection procedures, including parental or guardian consent where required.

11. Cookies and Website Analytics

Our website uses cookies and analytics to:

  • Ensure proper functionality

  • Understand website usage

  • Improve user experience

You can control cookies through your browser settings.

12. Changes to This Policy

We may update this policy from time to time. The latest version will always be published on our website, with the date of the most recent update.

13. Complaints

If you have concerns about how we handle your personal data, please contact us first.

If you are not satisfied, you may complain to the Information Commissioner’s Office (ICO):

  • Website: https://www.ico.org.uk/make-a-complaint/

  • Helpline: 0303 123 1113

14. Your Safety and Privacy

Your privacy, dignity, and safety are central to our work.

If your circumstances change or you have concerns about how your data is used, please contact us. We will always work with you to find a safe and respectful solution.

Our HeartBeats CIC