PeerChat Support User Privacy Notice

The PeerChat service is operated by Mental Health Innovations (“MHI”, “we”, or “us”). MHI is a registered charity in England and Wales, PO Box 78319, London, W10 9FE. MHI’s registered charity number is 1175670. MHI is the entity responsible for the processing of your personal information.

The PeerChat service is intended to connect service users aged 16-25 with a peer (a trained member staff aged 18-30) to discuss topics that are on the service user’s mind.

It is available by booking an appointment in advance with an allocated member of staff (i.e., your peer).

Staff acting as Peers are trained to help service users discuss and explore the issue that is on their mind and, if necessary, help them decide on next steps. Our staff are supervised in their conversations with service users and are trained to escalate any concerns that arise with the supervisor (e.g.,  if they think a user is at risk of harm).

Personal information is any information that can identify you in some way. It can include things like your name, address, date of birth and device’s IP address. This information is considered to be ‘normal’ or ‘non-sensitive’ information.

Some personal information needs more protection because it is sensitive. This is known as ‘sensitive information’ or ‘special category data or information’. Sensitive information includes information relating to your health, sexuality, sex life, religious beliefs, ethnicity, or any criminal convictions you might have or offences you may have committed.

When you book an appointment with the PeerChat service, you will need to provide us with certain information so we can confirm and arrange your appointment for the service. Once you book an appointment with the PeerChat service, we will provide you with a booking reference. We may link that booking reference to personal information you provide us in order to provide you with the PeerChat service. You may also share certain personal information with us during the course of using the PeerChat service. We process personal information in order to be able to provide you with the PeerChat service. The types of personal information we may obtain include:

personal and contact details, such as your name, age, date of birth, telephone number, and email address;

sensitive information, including health or medical information, diversity-related personal information (such as gender, race, ethnicity, sexual orientation, and information relating to disabilities), information relating to your sex life, and information relating to criminal convictions and offences

any other information you choose to provide during your conversation using the PeerChat service; and

any information contained in notes that a Peer might take during your conversation, which may include details of the issues you raise and the Peer’s observations in relation to the same.

When you have the conversation with us we keep the content of the things you say, including any personal information you may have included in your conversation. We also keep the notes that our staff might take during your conversation.

Before your first PeerChat conversation, and once you have finished a PeerChat conversation, we will send you an e-mail and you will have the option to complete a survey. We send you a survey before and after you use the PeerChat service, as the surveys are intended to help understand how the PeerChat service makes a difference over time and how we may improve the service.  Should you choose to complete a survey, we will retain a record of your responses and any personal information you provide. While your survey responses are linked to you, any personal information included in your survey responses will be removed before they are shared with any third-party or used for internal purposes (e.g., analytics or training).

We require certain personal information to provide you with the PeerChat service, such as your name and contact information.  If you choose not to provide certain information, this will affect our ability to provide you with the PeerChat service.

In order to use your personal information, we need to establish a legal reason for doing so. This is known as our ‘legal basis’ for using your personal information.

Our legal basis for providing the PeerChat service is primarily consent. We rely on your consent where possible to process your personal information (including sensitive information) so we can provide, maintain and improve the PeerChat service. At the start of your conversation with us you will be asked to consent to the processing of your personal information. 

We also rely on your consent to use any personal information (including sensitive information) you provide when you complete our surveys. Where we rely on consent to process your personal information (including sensitive information), we will tell you when we collect your personal information and the reason why we need it.

Where you provide your consent, you can change your mind and withdraw your consent at any time by contacting us using the information provided in the contact section below.

There are times where we may use your information under a different legal basis. These include:

Legitimate Interests: We may rely on ‘legitimate interests’ as our legal basis for using your non-sensitive personal information;

Vital Interests: We may share your personal information (including your sensitive data) with third parties, such as emergency services (for example the police or ambulance services), where we think there is an imminent risk of harm to you or someone else. The lawful basis for this is ‘vital interests’ - that is, to protect your life and keep you or others safe;

Substantial public interest (provision of confidential advice and support): In certain cases where due to your particular situation you are unable to provide appropriate consent, we rely on the ‘substantial public interest’ legal basis to use your sensitive information to provide the PeerChat service. The PeerChat service is a confidential service that provides advice, support and similar services to its users. This represents a ‘substantial public interest’ (see Paragraph 17, Schedule 1, Data Protection Act 2018); and

Substantial public interest (safeguarding): In certain cases where due to your particular situation you are unable to provide appropriate consent, we may also need to share your sensitive information with emergency services or with local authorities where necessary for safeguarding purposes. The lawful basis for this is, again, ‘substantial public interest’ (see Paragraphs 18 and 19, Schedule 1, Data Protection Act 2018).

For more information, please see ‘What do we use your personal information for’, below.

We respect and seek to preserve the confidentiality of people who use the PeerChat service. However, in certain circumstances, we may share your personal information with third parties, including with:

Police, social and ambulance/medical services to keep you safe and protect you from harm;

Researchers at universities and other institutions to help us understand the mental health needs of our service users and to improve the service. We will only share anonymised information with research partners;

Service providers that perform services on our behalf, such as IT service providers, hosting providers and our advisers. For example, we have engaged with TechMatters who provide certain IT services; and

Other third parties, as necessary, to comply with the law or in response to a court order, government request, coroner’s request or other legal process, including police investigations, and to protect the interests, rights, safety, or property of MHI, its affiliates, employees, or agents, including but not limited to the PeerChat staff.

Your personal information is securely stored. We will keep personal information such as your e-mail address, telephone number and the record of your conversation with us for up to seven years after you last use the PeerChat service. Then we will permanently delete this information from our records.

We anonymise and aggregate certain information, including from your conversation with us.  Such anonymised and aggregated information no longer constitutes personal information (as it no longer identifies you) and will be retained indefinitely.

Always be careful and responsible regarding your personal information and sensitive information. You might want to delete conversations with the PeerChat service from your phone or computer. You might even want to clear us from your browser or message history and make sure we are not saved in your contact list.

UK data protection law provides you with certain rights in relation to your personal information. These include the right to:

In some cases, your ability to exercise these rights may be limited. For example, we may not always be able to delete your personal information where we are required by law to retain it.If you wish to exercise any of your rights, please write to us at [email protected] or the address provided below in the ‘How to contact us’ section.If you make a request relating to any of the rights listed above, we will consider each request in accordance with UK data protection law. No fee will be charged for considering and/or complying with your request to exercise your rights. However, we may charge a ’reasonable fee’ for the administrative costs (such as photocopying, printing, postage and any other costs involved in transferring the information to you) of complying with a request if it is clearly unjustified or excessive, or if you request additional copies of your personal information.If you would like us to delete any personal information that we may hold about you, please write to us at [email protected] with details of the conversation and your request. You will be asked to confirm your identity and, once you do so, we will delete your personal information within 30 days, unless we are required to keep it (for example, to comply with our safeguarding obligations or another applicable law).

We may update this Privacy Notice at any time. If we make any significant changes to the way we use your personal information, we will bring these to your attention when you consent at each stage of your journey with us. The date this Privacy Notice was last updated is indicated at the top of the Privacy Notice.

If you have any questions or concerns about this Privacy Notice and our privacy practices or if you wish to file a complaint, please contact us by emailing [email protected] or by writing to Mental Health Innovations’ Data Protection Officer at the address below.If we fail to satisfactorily resolve your concerns or complaint, or you otherwise consider it necessary, you have the right to lodge a complaint with the Information Commissioner’s Office (which is the UK data protection regulator that has responsibility for overseeing compliance with UK data protection law). You can do so by calling the ICO helpline on 0303 123 1113 or via http://www.ico.org.uk/. We would, however, appreciate it if you gave us the chance to resolve any issues before you do so.

If you have any questions about our policies you can contact us by email at [email protected] or write to us at: Data Protection Officer, Mental Health Innovations, PO Box 78319, London W10 9FE.