Privacy Policy
1. Introduction
LWDW Training Ltd (‘we’, ‘us’, ‘our’) is committed to protecting your personal information and respecting your privacy.
This Privacy Policy explains how we collect, use, store and protect your personal data when you interact with us, whether through our website, training programmes, events, enquiries, fundraising activities or other services.
We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable data protection legislation.
2. Who We Are
LWDW Training Ltd is a training provider, providing training in end of life companionship and doula roles. We are the Data Controller responsible for the personal information we collect and process, registered with the ICO under registration number Z3358016
LWDW Training is a registered company, limited by guarantee, company registration number 09589055
If you have any questions about this Privacy Policy or how we handle your personal data, please contact:
Data Protection Contact: Nikki Newman
Email: info@livingwelldyingwell.net
Telephone: 01273 102511
Address: Office 2, 139 High Street, Lewes, BN7 1XS
3. How We Collect Your Information
We collect personal information when you:
- Visit our website
- Complete an enquiry form
- Register for training
- Attend an event
- Contact us by email or telephone
- Subscribe to our newsletter
- Apply to work or volunteer with us
- Make a donation
- Apply for a bursary
- Participate in surveys or feedback
- Interact with us through our social media channels
We may also receive information from trusted third parties where appropriate, such as membership organisations or end of life doula service providers.
4. How We Use Your Information
We use your personal data to:
- Deliver our training and educational services
- Manage learner registrations
- Process payments
- Communicate with you about your courses
- Issue certificates
- Provide learner support
- Respond to enquiries
- Improve our services
- Administer events
- Meet legal and regulatory obligations
- Maintain organisational records
- Send newsletters or marketing communications where you have agreed to receive them
- Arrange Learning Plans
- Make Bursary Award decisions
5. Our Lawful Bases for Processing
| Purpose | Personal Data We May Collect | Lawful Bases |
| Making an enquiry or contacting us | Name, contact details, organisation (where applicable), details of your enquiry and correspondence and any information you choose to share when interacting with us, including via social media. | Legitimate Interests – To respond to enquiries, communicate with you, engage with our community and provide information about our work. |
| Using our website | IP address, browser type, device information, pages visited, cookies and website usage information. | Legitimate Interests – To ensure our website functions correctly, improve user experience and maintain security. Consent is relied upon where non-essential cookies are used. |
| Registering for and participating in our training, events or other services | Contact details, emergency contact information, booking details, payment information, attendance records, assessment submissions, learner progress, certification records, disabilities and learning needs, learner support information and correspondence, gender, date of birth, dietary needs, occupation, professional qualifications. | Contract – Processing is necessary to administer your booking, deliver our services, assess your learning, provide support and issue certificates. |
| Making a payment | Name, contact details, billing information, payment reference, transaction details and payment status. Where you pay by card, your payment details are processed securely by our third-party payment providers. Where you pay by bank transfer (BACS), we receive the information necessary to identify and reconcile your payment or provide a refund. | Contract – Processing is necessary to receive payment for our services and maintain accurate financial records. Legal Obligation – To comply with accounting and taxation requirements. |
| Applying for a bursary or financial assistance | Contact details, financial information, employment status, supporting evidence and any information you choose to provide in support of your application. | Legitimate Interests – To assess applications fairly and consistently, administer bursary awards and maintain appropriate records. Where you voluntarily provide special category personal data, we will process it only where an additional condition under UK GDPR applies. |
| Receiving newsletters, updates and marketing communications | Name, email address and communication preferences. | Consent – You choose whether to receive these communications and may withdraw your consent at any time. |
| Making a donation or supporting our work | Contact details, donation history and payment details. | Legitimate Interests – To administer donations, thank supporters and maintain relationships. Legal Obligation – To comply with financial and tax record-keeping requirements. |
| Applying to work or volunteer with us | Contact details, CV, employment history, qualifications, references, right to work documentation and recruitment records. | Legitimate Interests – To recruit suitable employees and volunteers. Legal Obligation – To comply with employment and immigration legislation where applicable. |
| Complying with legal, regulatory and safeguarding obligations | Any personal data necessary to fulfil our legal responsibilities. | Legal Obligation – To comply with applicable legislation, safeguarding responsibilities, accounting requirements and regulatory obligations. |
6. Marketing Communications
If you choose to receive updates from us, we may send you information about:
- Training opportunities
- Events
- News
- Organisational developments
- Fundraising activities
You can unsubscribe from marketing communications at any time using the unsubscribe link provided in our emails or by contacting us directly.
7. Sharing Your Information
We respect your privacy and will never sell, rent or exchange your personal information with another organisation for marketing purposes.
We only share your personal information where it is necessary to deliver our services, fulfil our legal obligations, or support the work of our organisation.
End of Life Doula UK (EoLDUK)
We work closely with EoLDUK who provide membership and support for end of life doulas who have trained with Living Well Dying Well Training.
Where you have completed training with us and are, or choose to become, a member of EoLDUK we may share relevant personal information with them. This may include information necessary to:
- verify your training and certification status
- confirm your eligibility for membership or a particular membership category
- support professional standards and safe practice
- investigate or respond to matters relating to professional conduct where appropriate.
We will only share information that is relevant and necessary for these purposes, and both organisations are responsible for ensuring that personal information is processed in accordance with applicable data protection legislation.
Organisations Working on Our Behalf
We use carefully selected third-party organisations to provide services on our behalf. These include providers of:
- training and assessing;
- payment processing;
- IT systems and cloud storage;
- email and communication platforms;
- website hosting and support;
- learning, assessment and certification systems; and
- professional services such as legal, financial and auditing support.
These organisations act as our data processors and may only process personal information in accordance with our instructions. Appropriate contracts and security measures are in place to protect your information.
Payment Processing
Where you pay by debit or credit card, payments are processed securely by our trusted third-party payment providers. We do not receive or store your full payment card details.
Where payment is made by bank transfer (BACS), we receive only the information necessary to identify and reconcile your payment.
Trainers, Assessors and Facilitators
Many of our training courses are delivered by self-employed trainers and assessors who work with us under contract.
Where necessary to deliver your training and provide learner support, they may have access to relevant personal information, including your contact details, course attendance, learner records, assessment information and any reasonable adjustments or support requirements that are necessary for them to fulfil their role.
All trainers and assessors are contractually required to maintain the confidentiality and security of your personal information and to process it only in accordance with our instructions and applicable data protection legislation.
Training Verification Collaboration
We also work with Find a Doula to enable individuals to verify their training status.
If you choose to register with Find a Doula you provide your personal information directly to that organisation under its own Privacy Policy. As part of the verification process, training records are securely checked to confirm your training level or certification status.
This verification process does not involve the exchange of personal information between the organisations. Each organisation remains independently responsible for the personal information it collects and processes.
Legal and Regulatory Disclosures
We may disclose personal information where we are required or permitted to do so by law, including:
- to comply with a legal or regulatory obligation;
- to prevent or detect crime, fraud or other unlawful activity;
- to establish, exercise or defend legal claims; or
- to protect the rights, property or safety of Living Well Dying Well, our learners, staff, volunteers or others.
We will only disclose the minimum amount of information necessary for the relevant purpose.
Other than in the circumstances described in this Privacy Policy, we will not share your personal information without your knowledge unless required or permitted by law.
8. Transferring your information outside of the United Kingdom
Where personal information is transferred outside the UK, we will ensure that appropriate safeguards are in place to protect it in accordance with UK data protection legislation. These safeguards may include the use of the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses (SCCs), or transfers to countries that have been recognised by the UK Government as providing an adequate level of data protection.
Where required, we will carry out a Transfer Risk Assessment (TRA) or other appropriate assessment before transferring personal information internationally to ensure that your information continues to receive an appropriate level of protection.
9. How We Protect Your Information
LWDW Training shall ensure that personal data is stored securely using modern software that is kept-up-to-date. The following provisions take place:
- Access to personal data is limited to personnel who need access and appropriate security is in place to avoid unauthorised sharing of information.
- When personal data is deleted it is done such that the data is irrecoverable.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available and systems will be in place to ensure such revocation is reflected accurately in LWDW Training’s systems
We use appropriate technical and organisational measures to safeguard personal data, including:
- Secure systems
- Password protection
- Access controls
- Encryption where appropriate
- Staff confidentiality obligations
- Regular review of our security arrangements
Although we take reasonable steps to protect your information, no system can be guaranteed to be completely secure.
10. How Long We Keep Your Information
We only retain personal information for as long as necessary to fulfil the purposes for which it was collected or to meet legal, regulatory or contractual requirements.
Retention periods are set out in our internal records retention procedures.
11. Your Rights
Under data protection laws in the UK and EU, you have certain rights over the personal information that we hold about you. If you would like to exercise your rights, please get in contact with our Data Protection Lead at emmaclare@eol-doula.uk. Here is a summary of the rights we think apply:
- Right to be Informed: You have the right to be informed as to how we use your data and under what lawful basis we carry out any processing. This Privacy Notice sets this information out however if you would like further information, please get in touch.
- Right of Erasure – also known as the right to be forgotten: You may ask us to delete some or all of your information we hold about you. Sometimes where we have a legal obligation we cannot erase your personal data.
- Right to Object: You have the right to object to processing where we are using your personal information such as where it is based on legitimate interests or for direct marketing.
- Inaccurate personal information corrected: Inaccurate or incomplete information we hold about you can be corrected. The accuracy of your information is important to us and we are working on ways to make this easier for you to review and correct the information that we hold about you. We will also carry out an annual accuracy check. If any of your information is out of date or if you are unsure of this, please get in touch through any of the contact details listed in this notice.
- Right of restriction: You have a right to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy, or we are not lawfully allowed to use it.
- Right to Access your information: You have a right to request access to a copy of your personal information that we hold about you, along with the information on what personal information we use, why we use it, who we share it with, how long we keep it for and whenever it has been used for automated decision making. You can make a request for access free of charge and proof of identity is required.
- Automated decision making: Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right to question the outcome of automated decisions that may create legal effects or create a similar significant impact on you. We currently do not undertake automated decision making.
- Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you.
- Right to withdraw consent: Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data
12. Website Cookies
Our website uses cookies to improve your browsing experience and help us understand how visitors use our website.
You can manage cookies through your browser settings.
Where cookies are used to collect personal data, we list these purposes above, along with other personal data that we collect. However, we also use some cookies that do not collect personal information but that do help us collect anonymous information about how people use our website. We use Google Analytics for this purpose. Google Analytics generates statistical and other information about website usage by means of cookies, which are stored on users’ computers. We will always ask for your consent where non-essential cookies are requested. The information collected by Google Analytics is aggregated or pseudonymised where possible. The data is collected anonymously, stored by Google and used by us to create reports about website usage. Google’s privacy policy is available at http://www.google.com/privacypolicy.html. For more information about our website cookies, please refer to our Cookies Policy online.
13. Links to Other Websites
Our website may contain links to other websites of interest. Once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Notice. You should exercise caution and look at the Privacy Notice applicable to the website in question.
14. Data Breach
Although we take appropriate steps to protect your personal information, no method of electronic storage or transmission over the internet can be guaranteed to be completely secure.
If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will respond promptly, investigate the incident, take appropriate steps to minimise any impact, and meet our legal obligations under applicable data protection legislation, including notifying affected individuals and the Information Commissioner's Office (ICO) where required.
15. Changes to this Privacy Policy
This privacy policy is kept under regular review. If we make any significant changes to the way in which we process your information, we’ll make the required changes to this Privacy Notice and will notify you so that you can raise any concerns or objections with us.
When making less impactful changes, we’ll update this notice and post a summary of the changes on our website.
16. Complaints
If you are unhappy with how we have handled your personal information, please contact us first so that we have the opportunity to resolve your concerns.
You also have the right to complain to the Information Commissioner's Office (ICO).
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Website: https://ico.org.uk
Telephone: 0303 123 1113