This privacy notice tells you how and why The Forward Trust app processes your personal information. It also explains what rights (such as the right of access) you have in relation to your data, and we listed other information you may find useful.
As a service provider, The Forward Trust must meet our contractual, statutory, and administrative obligations. We are committed to ensuring that personal data is handled in accordance with the principles set out in the Information Commissioner’s Office (ICO) Guide to Data Protection.
Forward uses several third-party services to make the app work, these are listed below. However, Forward is the ‘controller’ for the information stored in the app. Forward remains responsible to ensure that your data is only used in ways you would reasonably expect. For more information on how we handle your data, you can contact us at dataprotection@forwardtrust.org.uk.
We get information about you from the following sources:
Directly from you.
Forward client databases.
What personal data we process
We process the following categories of personal data:
Basic details such as your name, date of birth, username and personal email address.
Your relationship with The Forward Trust – e.g. Forward Connect membership, referral route, programme.
Engagement data around the use of The Forward Trust app; the time, frequency and duration of your activities on our app.
The ‘activity’ data of our app’s members, this type of data is often referred to as “user generated data” and includes for instance the content you create such as post, comments, ‘likes’, uploads, and the messages you send.
Lawful bases for processing your personal data
The Forward Trust relies on multiple lawful bases for processing your personal data, such as:
Your consent: UK GDPR Article 6(1)(a).
Under the responsibility of a public authority: UK GDPR Article 6(1)(e).
Legitimate Interest: UK GDPR Article 6(1)(f).
For the app itself we normally only process your personal data on the basis of your consent, this means that your information will only be added to the app after you consented to it, and that your data will be removed if you ask us to do so.
However, we may record on your client file if you choose to use the app, and we may record some of the information from the app onto our client databases based on another lawful basis. For instance, if a user of the app said something that makes us believe they may be at risk to themselves or another person.
Users of the app might choose to share information on the app about their beliefs, sexual orientation, health (including their recovery journey), racial or ethnic origin, or lived experiences. Such types of information may be considered sensitive and will generally have special protections under UK data protection laws. You may choose to share your confidential information, but not the confidential information of others. Crucially, The Forward Trust itself will never add the confidential information of its clients to the app, and we will never ask you to do so.
Where we store your data
We use Discourse CDCK as a community platform to host this service. The Forward Trust is the Forum administrator and operates as the data controller, but CDCK collects and processes data every time you provide information, read or use the Forward app. Just like Forward, CDCK is subject to the UK’s data protection laws. For more information about CDCK please see Discourse’s Privacy Notice.
For The Forward Trust Community App, besides Discourse, we use the following (sub)processors, which are bound by the same data protection obligations as Discourse themselves as detailed in the signed Data Protection Agreement / Addendum. Forward may from time to time, and without notice, change its processors, but we will always do our due diligence and ensure that all appropriate steps to secure your data have been taken.
Amazon Web Services, One Burlington Plaza, Burlington Rd, Dublin 4, Hosting Services – processed in EU West (Dublin, Ireland).
SendGrid , (Twilio) 375 Beale St suite 300 San Francisco CA 94105 USA , SMTP Relay email notifications – this may include very limited data transfers through servers located in the USA, these are covered under the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses issued by the UK Information Commissioner, Version B1.0, in force 21 March 2022.
Heroku, Inc. , The Landmark @ One Market, Suite 300, San Francisco, CA 94105, USA., Hosting Services- processed in EU West (Ireland).
Sentry.io , Functional Software, Inc.45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA., Error Tracking Services – EU (Frankfurt, Germany).
How long we keep your personal data
For information about how long we hold your personal data please contact us at info@forwardtrust.org.uk and request a copy of our Records Management Policy.
Your rights in relation to this processing
As an individual you have certain rights regarding our processing of your personal data, these include:
Your right of access: you have the right to ask us for copies of your personal information.
Your right to rectification: you have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure: you have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing: you have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing: you have the right to object to processing if we are able to process your information because the process in our legitimate interests.
Your right to data portability: this only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you.
Data sharing
We don’t normally share your personal data except where this has been agreed with you. However, in some circumstances, such as under a court order, there is a legal obligation or overriding legitimate interest for us to do so. We also have a duty to share information with or without your permission if we believe you may be at risk of self-harm or risk of harm to any person.
When it’s reasonable to do so we will always inform you when we have to share your personal data.
More information
If you would like more information, or if you have any questions, suggestions or concerns about how The Forward Trust and its service suppliers process your personal information please contact dataprotection@forwardtrust.org.uk.
We will always try to resolve any problem or query, and we learn from the feedback we receive.
You have the right to contact the UK’s data protection regulator, the Information Commissioner’s Office (ICO). For further information on your rights and how to complain to the ICO, please refer to the ICO website.
The Forward Trust app is designed for you to help yourself and others to move in a positive life direction, and we expect everyone to conduct themselves with this spirit in mind while using it.
However, any messages, content, or comments which are found to break the below rules will be removed. Depending on severity and frequency, Forward staff may use measures including (but not limited to) face-to-face discussions with Forward staff, formal warnings, or account suspension or deactivation for anyone who breaks the below rules.
1. No abuse
The Forward Trust app aims to harness the power of positive peer support – insulting, abusive or generally negative comments or posts won’t be tolerated. Please always be respectful, polite and supportive of others.
2. No offensive material
Posts or comments which include explicit or obscene content (including language, imagery, video etc.) are strictly prohibited. ‘Jokes’ are not excluded from this rule.
3. Respect diversity
The Forward Trust app should be a welcoming space for everyone who wishes to participate. Please refrain from using language that is – or that could be construed to be – racist, sexist, homophobic or otherwise offensive towards different religious beliefs, disabilities, nationalities or age.
4. No illegal behaviour
Using the platform to organise illegal behaviour – including soliciting drugs – is not only strictly prohibited but will be reported to the police if discovered. Do not use this app if you are legally restricted from accessing the internet.
5. No self-promotion or spam
Please do not use The Forward Trust app to advertise or promote your own business or work. If you are able to provide a product or service that you feel will be genuinely beneficial to the community, please contact a member of the Forward staff to advise on whether it could be appropriate to share on the platform.
6. Don’t give out personal details
Please avoid sharing personal information about yourself such as your phone number, home address or personal social media profiles on The Forward Trust app. If you have a specific reason for needing to share any such information with another platform user, speak to a moderator before doing so.
7. Try not to duplicate content
Before you post something, remember to use the search bar to see if someone else has already began a discussion on the subject which you could contribute to with a comment instead. This will make it easier for everyone to find the answers or content they’re looking for.
8. Look after each other and report bad behaviour
As well as obeying the rules, we hope you’ll help us keep the platform safe by acting responsibly if you see anything that may cause offense or upset. Forward staff will do their best to monitor the platform and remove content or comments which contravene the above rules – but if you spot something before we do, please report it using the ‘report’ function. We can then act to have it removed.
9. If you need urgent help, speak to staff or the emergency services
The Forward Trust app is designed to be an online space in which you can benefit from support from others – but it isn’t a crisis service. If you need help urgently, please instead speak directly to a member of Forward staff, call 999, or speak to the Samaritans on 116 123.
