Privacy Notice

The Wellbeing Circle CIC customer privacy notice 

Registered name: The Wellbeing Circle CIC

We are the controller of your personal data. For more information on controllers and their responsibilities please see our guidance on data protection principles, definitions, and key terms. 

This privacy notice tells you what to expect us to do with your personal information. 

• Contact details 

• What information we collect, use, and why 

• Lawful bases and data protection rights 

• Where we get personal information from 

• How long we keep information 

• Who we share information with 

• How to complain 

Contact details 

Email: info@thewellbeingcircle.co.uk 

What information we collect, use, and why 

We collect or use the following information to provide services and goods, including delivery and third party referrals: 

• Names and contact details including email address. 

• Emergency contact details 

• Photographs or video recordings 

• Service use history 

• Health information (including medical conditions, test results, allergies, medical requirements and medical history) 

• Dietary information (including allergies and health conditions) 

• Information about support requirements 

• Information about lifestyle, interests or personal history 

• Payment details (including card or bank information for transfers and direct debits) 

• Information relating to compliments or complaints 

We also collect or use the following special category information to provide services and goods, including delivery and third party referrals. This information is subject to additional protection due to its sensitive nature: 

• Health information 

We collect or use the following information to receive donations or funding and organise fundraising activities: 

• Names and contact details 

• Payment or banking details 

We also collect or use the following special category information to receive donations or funding and organise fundraising activities. This information is subject to additional protection due to its sensitive nature: 

• Health information 

We collect or use the following personal information for service updates or marketing purposes: 

• Names and contact details 

• Addresses 

• Marketing preferences 

• Recorded images, such as photos or videos 

• Records of consent, where appropriate 

We also collect or use the following special category information for service updates or marketing purposes. This information is subject to additional protection due to its sensitive nature: 

• Health information 

We collect or use the following personal information to comply with legal requirements: 

• Name 

• Contact information 

• Health and safety information 

• Safeguarding information 

We also collect or use the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature: 

• Health information 

Lawful bases and data protection rights 

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website. 

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website: 

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access. 

• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification. 

• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure. 

• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing. 

• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing. 

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability. 

• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent. 

If you make a request, we must respond to you without undue delay and in any event within one month. 

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice. 

Our lawful bases for the collection and use of your data 

Our lawful bases for collecting or using personal information to provide services and goods, including delivery and third party referrals are: 

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time. 

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object. 

• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability. 

Our lawful bases for collecting or using personal information to receive donations or funding and organise fundraising activities are: 

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: 

• For funding applications we may include examples of how our work has helped the communities we serve. The information gathered through surveys and interviews with service users is invaluable to our work and securing funding. 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above. 

Our lawful bases for collecting or using personal information for service updates or marketing purposes are: 

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time. 

Our lawful bases for collecting or using personal information to comply with legal requirements are: 

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time. 

Where we get personal information from 

• Directly from you 

• Councils and other public sector organisations 

How long we keep information 

To comply with the principles of the Data Protection Act, The Wellbeing Circle - Community Interest Company will endeavour to ensure that strict confidentiality of clients’ personal data is maintained in all of its work, whether the information is stored on a computer or a manual filing system. 

Files and records must be retained for 3 years after the person has ceased to receive services from The Wellbeing Circle - Community Interest Company. After this period of inactivity, the file must be destroyed in a manner that ensures confidentiality. Historic employment data for staff and Volunteers must be held for 6 years. 

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.  

Who we share information with 

Others we share personal information with 

• Other health providers (eg GPs and consultants) 

• Organisations we need to share information with for safeguarding reasons 

• Emergency services 

• Legal bodies or authorities 

• Organisations we’re legally obliged to share personal information with 

• Publicly on our website, social media or other marketing and information media 

How to complain 

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. 

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO. 

The ICO’s address:            

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF 

Helpline number: 0303 123 1113 

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

Last updated 25/06/2025