Headway Adolescent Resources, Part of the Polaris Community
Welcome to the Polaris Community.
We are a community of fostering, residential, education and children’s services companies. This Privacy Notice applies to all companies within the Polaris Community.
We respect your privacy and are committed to protecting your personal data. Individuals who we hold personal information about are known as ‘Data Subjects’ and have a legal right and expectation to be informed about how we process their personal information, for what purpose, for how long and what their rights are in connection with this processing. We are required to process all personal data lawfully, fairly and in a transparent manner in accordance with data protection law (UK General Data Protection Regulation and the Data Protection Act 2018). It is important that you read this notice carefully so that you understand your privacy rights.
The services that we provide manage personal data relating to, but not limited to, children, foster parents/carers, adopters, applicants, service users, care receivers, pupils, workforce, visitors, stakeholders and other connected people. Therefore we act as a Data Controller in terms of the records we control in some instances we also act as a Data Processor, where the information is controlled by another person or organisation eg. (Local Authorities, Health Professionals) and we process this information on their behalf and instruction. We and all of the other Polaris companies are registered as a Data Controller with the ICO.
2. Contact Information
We have a designated Data Protection Officer who is responsible for overseeing our Data Protection practices. If you have any questions or concerns about the Privacy Notice or how we process your information please contact the Data Protection Officer using the contact details set out below.
Saxon Business Park,
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) which is the UK supervisory authority for data protection issues ( www.ico.org.uk). We would however, appreciate the chance to deal with any concerns before you approach the ICO so please do contact us in the first instance.
3. Your rights in connection with personal information
Below is a list of the rights that all individuals have under data protection laws. They do not apply in all circumstances and we will explain whether or not they do, at the time you wish to exercise any of these rights.
- Right to be informed about the processing of your personal information. This is covered by our Privacy Notices.
- Right to request access to your personal data(commonly known as a “Subject Access Request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Right to request correction of the personal datathat we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, however we may need to verify the accuracy of the new data you provide to us.
- Right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where we no longer have a reason to process it or it is different to the purposes for which we originally collected it. However, we may not always be able to comply with your request of erasure for specific legal reasons.
- Right to object to processing of your personal datawhere we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which you believe impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to request the transfer of your personal data. This enables you or your nominated third party to receive personal data that you have provided to us in a structured, commonly used and machine readable format.
- Withdraw consent at any timewhere we are relying on consent only to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. This will not apply where there is another legal basis or legitimate interest that overrides this consent.
If you wish to exercise any of these rights, please contact us.
4. The data we may collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We obtain personal data from numerous sources dependent on the category of Data Subject and the relationship we have with you. Categories of data we may collect, use and store are highlighted below but is not exhaustive:
- Identity Data – which can include name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Details – which can include address, email address and telephone numbers.
- Special Category or Sensitive data – which can include race or ethnicity, religious or philosophical beliefs, sexual orientation, background, financial data, health and medical records, DBS and social services checks, criminal convictions or cautions, family and education data.
- Profile Data – which can include job title, interests, preferences, messages, enquires, feedback.
- Technical Data – which can include internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other information about the technology on the devices you use to access our websites.
The Polaris community websites log IP addresses and browser types to provide you with the best possible user experience and allow us insight into consumer behaviour. You can browse our website without entering any personal information, and therefore remain anonymous during your visit.
- Usage Data – which can include information about how you use our website and services.
- Marketing and Communications Data – which can include your preferences and responses related to any marketing you may receive from us and your communication preferences.
- Aggregated Data – which may include statistical and demographic data. This may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. We do not knowingly collect any Special Categories of Personal Data about you such as details about your race or ethnicity, religious beliefs or your health.
However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
While the majority of personal information we collect from you may be mandatory, there is some information that you can choose whether or not to provide to us. Whenever we seek to collect information from you we will make it clear whether you must provide this information (and if so, what the possible consequences are of not complying) or whether you have a choice. Where you have provided us with consent to use your data, you may withdraw this consent at any time.
5. How your personal data is collected
We use different methods to collect data from and about you which can include, but is not limited to:
Direct interactions – you may provide us with your identity, contact and financial data by filling in a form through our website or by corresponding with us by post, email, phone, social media and otherwise.This may also include other personal data which you provide when you carry out the following
- Make an enquiry about fostering or adoption or some other service use;
- Proceed with an assessment for fostering or adoption or where you are part of the support network or a referee
- You have registered an interest in our organisation and then through the management of this relationship we have with you which may be as an employed member of staff, an independent worker commissioned by the organisation, a foster parent/carer, adopter, service user, care receiver, applicant, stakeholder, visitor and other connected people
- Create an account on our website
- Request marketing to be sent to you, or subscribe to our blogs
- Enter a competition, promotion or survey
- Providing feedback to us
Automated technologies or interactions – as you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies.
Third party and public sources such as:
- Analytic and search engine providers such as Google, Bing etc
- Social media channels such as Facebook, Twitter, LinkedIn, YouTube, Instagram and TikTok
- Email marketing software
- Companies House and the Electoral Register
6. How we use your personal information and the purposes for which we will use this information
We will only collect and use your personal data when the law permits it. These is known as the legal basis for processing. Most commonly we will use your personal data in the following circumstances:
- Consent – you have provided us with your consent to use your personal information, e.g. in the course of subscribing to our newsletters, completing a survey of ours, signing-up to an event or creating an online account via our website
- Contract – to fulfil a contract or relationship we have entered into with you or to take steps at your request before entering into a contract
- Legitimate Interest – where we, or a third party, have a legitimate interest in processing your information. A legitimate interest is where the processing of your personal information is necessary to pursue our legal or commercial interests in a way which is reasonably expected as part of running our business, but which is not detrimental to you and would have a minimal impact on your privacy
- Public Interest – to carry out a task or exercise a duty in the public interest
- Legal Obligation – where we need to comply with legal or regulatory obligations.
- Vital Interest – processing is necessary in order to protect the vital interests of a data subject or another natural person and generally applies to matters of life and death
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information.
Where it is necessary for our legitimate interests to use your personal data, we have listed below what some of these are:
- To register your enquiry and interest, and arrange a response to you.
- To manage our relationship with you.
- To deliver relevant website content.
- To administer and protect our business and this website (including troubleshooting,
data analysis, testing, system maintenance, support, reporting and hosting of data).
- To improve our website, products/services, marketing, customer relationships and
- Internal record keeping.
- For running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise.
- To define types of customers for our products and services.
- To develop our products and services and to inform our marketing strategy
Change of purpose:
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. Disclosures of your personal data
We may need to share your personal data with certain parties. We have listed some of these third parties below:
- IT – such as other companies in our group and other service providers who support our website, IT and system administration services and reporting activities.
- Advisors – such as professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Authorities: – such as HM Customs & Excise, regulators, police and government bodies or to otherwise comply with the law and other authorities who require reporting of processing activities.
- Partnering organisations – who assist us to provide or improve our services (for example, by analysing and modelling statistics/data). These include but are not limited to Google Ireland Limited, Meta Platforms, Inc., TikTok Information Technologies UK Limited, LinkedIn Ireland Unlimited Company, Microsoft Ireland Operations Limited and WildJar UK Ltd.
We also have specific service level privacy policies which provide further detail on how we collect and manage data for specific data subject categories. These are provided directly to data subjects and service users and include the following services:
- Fostering (foster parents/carers and applicants)
- Fostering (associated support networks)
- Residential Services
- Workforce (employees, applicants, independent workers, agency workers and contractors)
- Adoption (adopters and applicants)
- Leaving Care Services
- Polaris Children Services
- British Forces Social Work
8. Data security
We have appropriate security measures in place to prevent your personal data from being accidently lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We require all third party service providers and other entities in the group to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have in place processes to deal with any suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so
9. Data Retention
Personal information is retained in accordance with applicable law and regulation. Retention periods vary depending on the nature and context of the personal information. We hold your personal information based on the following criteria:
- For as long as we have reasonable business needs, such as managing our relationship with you. This will only be as long as necessary to fulfil the purposes we collected it for
- For as long as someone could bring a claim against us
- Retention periods in line with legal and regulatory requirements or guidance.
10. Other Information
Third Party Links:
Please note that this website may include links to other third party websites. Once you click on these links and leave our website, you should be aware that we no longer have any control of these other websites and cannot be responsible for the protection and privacy of any information that you share whilst visiting these sites. We encourage you to exercise caution and read the privacy notice of every website you visit.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
You will receive marketing communications from us if you have requested such information from us and you have not opted out of receiving that marketing. You can ask us to stop sending you marketing communications at any time by contacting us or following the opt-out links on any marketing message sent to you. Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a service we are providing to you.
Generally, cookies are used to retain user preferences, store information for things like shopping baskets, and provide anonymised tracking data to third party applications like Google Analytics. Therefore as a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.
We may need to update this Privacy Notice periodically and reserve the right to do so without giving notice. We recommend that you revisit this information from time to time