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Privacy Policy

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Privacy Notice 

Kairos Arts Limited (known as 'Kairos Arts') is the data controller responsible for your personal information. We are committed to protecting your privacy and being transparent about how we collect, use, and manage your data in accordance with the Data Protection (Jersey) Law 2018. 

This privacy notice explains what information we hold about you, how we collect it, why we use it, and what rights you have. If you have any questions about how we handle your information, please contact us using the details provided in this notice. 

The Data Protection Officer ("DPO") 

We have appointed an external Data Protection Officer to oversee our compliance with data protection law and to act as your point of contact for any data protection concerns. You can contact our DPO at any time: 

  • Name: Pippa Coleshill 

  • Email: finance@kairosarts.org 

The Kind of Information We Hold About You 

Kairos Arts provides therapeutic arts services to children, young people, and adults. We collect and process personal information about the individuals we work with, including clients, service users, parents or guardians, and other contacts. The information we hold ranges from basic contact details to sensitive health and safeguarding information collected while delivering our therapeutic services. 

We only collect information that is necessary for us to deliver our services safely, effectively, and in accordance with legal and safeguarding requirements. 

How Is Your Personal Information Collected? 

We collect your personal information in a number of ways: 

  • Information you provide directly to us through application forms, registration forms, or when you contact us by telephone, email, or in writing. 

  • Information we gather during the course of our therapeutic sessions and interactions with you, including detailed notes about your progress and wellbeing. 

  • Information provided by parents, guardians, teachers, schools, healthcare professionals, or other professionals involved in your care or referral. 

  • Photographs and video recordings, where you have given us consent to take and use these materials for therapeutic, monitoring, or safeguarding purposes. 

  • Information from third parties such as the Disclosure and Barring Service (for staff and volunteer vetting purposes) and from financial institutions (for payment processing). 

What Information Do We Collect About You? 

Category of Information 

Examples and Details 

Identity Information 

Your full name, date of birth, gender, and any aliases or former names. 

Contact Information 

Your home address, telephone number, email address, and the contact details of parents, guardians, or emergency contacts. 

Health and Medical Information 

Details of any physical or mental health conditions, disabilities, allergies, medications, medical history, and health-related needs relevant to our service delivery and your safety. 

Safeguarding Information 

Records of any safeguarding concerns, child protection matters, domestic violence, abuse, neglect, or other risks to your welfare. This may include information about criminal convictions or alleged offences where these are relevant to your safety or the safety of others. 

Therapeutic and Session Notes 

Detailed records of your therapeutic sessions, progress notes, observations about your behaviour and emotional state, treatment plans, and outcomes of our interventions. 

Demographic Information 

Your racial or ethnic origin, religious or philosophical beliefs, sexual orientation, and any other equality and diversity information you choose to share. 

Photographs and Video Recordings 

Images and recordings captured during sessions or at Kairos Arts events, where consent has been obtained. 

Financial Information 

Bank details and payment information where you make a donation or pay for our services; invoice and receipt records. 

Special Category Data 

Some of the information we collect is classed as 'special category data' under data protection law because it reveals sensitive information about you. This includes: 

  • Health and medical information, including mental health records and information about disabilities. 

  • Racial or ethnic origin. 

  • Religious or philosophical beliefs. 

  • Sexual orientation. 

  • Information about criminal convictions or offences. 

We only collect and use this sensitive information where we have a lawful basis to do so, and where it is necessary for the provision of our therapeutic services, safeguarding, or compliance with legal obligations. For example, we collect health information to tailor our therapeutic approach to your needs, and we may collect safeguarding information to keep you and others safe. We have strict controls in place to protect this information and only share it with those who need to know it for a legitimate purpose. 

How We Will Use Information About You 

We use your personal information for a number of purposes, depending on the nature of your relationship with us and the legal basis that allows us to process that information. Below, we explain each lawful basis we rely on and provide examples of how we use your data under that basis. 

Performance of a Contract 

Where we have entered into an agreement to provide therapeutic services to you or your child, we process your personal information to deliver those services. This includes collecting your contact details, health information, and session notes so that we can arrange appointments, deliver therapy, monitor progress, and communicate with you and any referring professionals. For example, we will use your address to send appointment letters, your health history to tailor our therapeutic approach, and session notes to track your wellbeing and outcomes. 

Legal Obligation 

We are required by law to process certain personal information to comply with legal duties. This includes safeguarding responsibilities under child protection law, the duty to report suspected abuse or neglect to local authorities or social services, and the requirement to maintain certain records for inspection by regulatory bodies. We also process financial information to comply with tax and charity law obligations. For example, we must keep safeguarding records and may be required to share information with the police, social services, or the Jersey Office of the Information Commissioner. 

Vital Interests 

In emergencies or where someone's health or safety is at immediate risk, we may process personal information without consent to protect vital interests. For example, if you become unwell during a session, we will share your medical information with emergency services to ensure you receive appropriate care. 

Legitimate Interests 

We process personal information where it is necessary for our legitimate interests as a charitable therapeutic organisation, provided that this does not override your rights and interests. These legitimate interests include delivering high-quality therapeutic services, training and supervising our staff and volunteers, improving our service, managing our finances and administration, preventing fraud or misuse of our services, and fulfilling our safeguarding and duty of care obligations. For example, we use session notes to supervise and train our therapists, we use contact information to send you newsletters or service updates, and we use financial information to administer donations and process payments. 

Consent 

Where appropriate, we ask for your explicit consent to process personal information. For example, we will ask for your consent before taking photographs or videos, before using your information for research or evaluation purposes, or before contacting you for feedback or marketing communications. If you have given consent, you are free to withdraw it at any time by contacting us. 

Change of Purpose 

We will only use your personal information for the purposes set out in this privacy notice. If we intend to use your information for a new purpose that was not previously disclosed, we will provide you with information about that new purpose and the legal basis for it, and we will ask for your consent if required by data protection law. 

If we collect personal information about you from a third party (such as a referrer, parent, or other professional), and we intend to use that information for a purpose that would not reasonably be expected by you or the person who provided it, we will inform you of that purpose within a reasonable period, and we will give you the opportunity to object if you wish. 

Data Sharing 

Kairos Arts shares your personal data with carefully selected third-party organisations (known as "processors") who help us deliver our services. These organisations process data only on our instructions and are bound by confidentiality obligations. 

The table below sets out who we share your data with, what they do with it, and where you can find their own privacy information. 

Processor 

Description of processing 

Link to Privacy Notice 

Payroll Plus 

Payroll processing, ITIS and Social Security returns, handling employee salary and name data 

Focused IT 

IT support and technical services 

All Sorted 

Accounting, bookkeeping and company secretarial services 

ThirtyOne: Eight. DBS Checking Service 

Disclosure and Barring Service checks for employees and volunteers 

Microsoft SharePoint 

Primary cloud storage platform for organisational and HR data with restricted access controls 

All processors listed above are located within Jersey, the UK, or the European Economic Area. Your personal data is not transferred outside these jurisdictions. 

Data Security 

Kairos Arts takes the security of your personal data seriously. We implement appropriate technical and organisational measures to protect your information against unauthorised access, alteration, disclosure, or destruction. 

Our security measures include: 

  • restricted access to personal data, limited to staff and volunteers who need it to perform their roles 

  • secure cloud storage via Microsoft SharePoint with access controls in place 

  • secure disposal of physical documents through G4S shredding services 

  • secure digital erasure and deletion of electronic records 

  • IT support and monitoring provided by Focused IT 

Whilst we take reasonable steps to protect your data, no security measure is completely foolproof. If you have concerns about a possible data breach, please contact our Data Protection Officer immediately. 

Data Retention 

Kairos Arts retains your personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by law. 

When your data is no longer needed, we dispose of it securely. Physical documents are shredded using G4S secure disposal services. Digital records are permanently deleted or anonymised. 

If you would like to know the specific retention period for your data, or if you believe we are holding information about you longer than necessary, please contact us or our Data Protection Officer. 

Rights of Access, Correction, Erasure and Restriction 

Under the Data Protection (Jersey) Law 2018, you have the following rights in relation to your personal data: 

  • Right of access: You have the right to obtain confirmation as to whether we hold your personal data, and if we do, to receive a copy of that data in a clear and accessible format. You can make a data access request free of charge, though we may charge a reasonable fee if your request is manifestly unfounded or excessive. 

  • Right to rectification: You have the right to correct any personal data we hold about you that is inaccurate or incomplete. 

  • Right to erasure: In certain circumstances, you have the right to request the deletion of your personal data. This right is not absolute and applies only where, for example, the data is no longer necessary for the original purpose, you withdraw consent, or you object to processing. We may continue to hold your data where we have a legal obligation to do so, or where there is a compelling legitimate reason. 

  • Right to restrict processing: You have the right to ask us to limit how we use your personal data in certain circumstances, for example whilst you dispute its accuracy or whilst we verify a lawful reason for processing. 

  • Right to data portability: In certain circumstances, you have the right to receive your personal data in a structured, commonly-used, and machine-readable format, and to transmit that data to another organisation. 

  • Right to object: You have the right to object to certain types of processing, including processing for direct marketing purposes. 

  • Rights relating to automated decision-making: You have rights in relation to automated decision-making and profiling. However, we do not carry out automated decision-making in relation to your personal data (see the Automated Decision-Making section below). 

To exercise any of these rights, please contact us using the details provided in the "How to Request Your Information" section below. 

How to Request Your Information 

If you wish to exercise any of your rights described above, please submit your request in writing to Kairos Arts using the contact details below. We accept requests by email or by post. 

Kairos Arts 
Ruby Ferguson House 
22 Vauxhall Street 
St Helier 
Jersey JE2 4TJ 
 
Email: finance@kairosarts.org 
Website: https://www.kairosarts.org 

When you submit a request, please provide as much detail as possible to help us locate and verify your information. We may ask you for additional information to confirm your identity and to locate the data you are requesting. 

Response timescale: We aim to respond to all requests within four weeks of receipt. If your request is complex or if you have made multiple requests, we may extend this period by a further eight weeks. If we need to extend the deadline, we will inform you of this within the original four-week period and explain the reason for the extension. 

If you have any difficulty submitting a request, please contact our Data Protection Officer, Marian Ursua, at dpo8@propelfwd.com. 

Right to Withdraw Consent 

Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. 

If you wish to withdraw your consent, please contact us using the details provided in the "How to Request Your Information" section above. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal, and we may continue to process your data where we have another lawful basis for doing so. 

Automated Decision-Making 

We do not use automated decision-making or profiling in relation to your personal information. 

Changes to this Privacy Notice 

Kairos Arts may update this privacy notice from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Any changes will be effective immediately upon publication on our website or upon written notice to you. 

We encourage you to review this notice periodically so that you remain informed about how we protect your personal data. If we make any material changes that affect your rights or how we use your information, we will notify you in advance where practicable. 

The date of the most recent update to this notice is shown at the top of the document. 

Complaints 

If you have any concerns about how Kairos Arts handles your personal data, or if you believe we have breached your rights under the Data Protection (Jersey) Law 2018, you have the right to lodge a complaint with us and with the supervisory authority. 

How to complain to Kairos Arts: 

Kairos Arts 
Ruby Ferguson House 
22 Vauxhall Street 
St Helier 
Jersey JE2 4TJ 
 
Email: finance@kairosarts.org 
Website: https://www.kairosarts.org 
 
Data Protection Officer: Pippa Coleshill 
Email: dpo8@propelfwd.com 

We will acknowledge your complaint as soon as possible and aim to resolve the matter promptly. 

How to complain to the supervisory authority: 

If you are not satisfied with our response, or if you prefer to lodge a complaint directly with the supervisory authority, you can contact the Jersey Office of the Information Commissioner (JOIC): 

Jersey Office of the Information Commissioner 
2nd Floor 
5 Castle Street 
St Helier 
Jersey JE2 3BT 
 
Telephone: +44 (0) 1534 716530 
Email: enquiries@jerseyoic.je 
Website: jerseyoic.org 
 
Kairos Arts registration number: 65011 

You have the right to lodge a complaint with the JOIC at any time, regardless of whether you have already raised the matter with Kairos Arts. 

Last updated: 26 May 2026. 

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