Privacy Policy

MCR Pathways Website Privacy Notice
At MCR Pathways we are  deeply committed to respecting and protecting the privacy and security of personal data. This privacy notice explains how we collect, use and protect any personal data you provide or that collect when you visit and use our website mcrpathways.org.  We are committed to protecting your privacy in compliance with the UK General Data Protection Regulation  ( UKGDPR) and Data Protection Act 2018. 

What personal data we collect and how we collect it

We may collect and process the following types of personal data from you when you interact with our website:

Information you provide directly- 

• General Inquiries/Get in touch: If you fill out a ‘Get in touch’ form, sign up for a newsletter, we collect your name, email address, phone number, and any other information you choose to provide in your message.
• Mentor Applications: When you apply to become a mentor through our website, we collect the personal data required for your application. This will include contact details, information about your suitability for the role, and any necessary background check information, including criminal conviction data. More specific details about the processing of mentor data, including emergency contact details and the handling of criminal convictions, are provided in our dedicated MCR Pathways Volunteer Privacy Notice, which you will be presented with during the application process.
• Partner Enquiries: If you contact us about  partnership opportunities through the website, we collect data on your name, organisation/company, contact information, how you wish to be contacted and what partnership opportunities are of interest. 
• Donations: If you make a donation through our website, we will collect the necessary payment and contact details. This processing is typically handled by a third-party payment provider, and their privacy policy will also apply.

Information collected automatically:

• Usage Data: When you visit our website, we may automatically collect certain information about your device and how you interact with our site. This can include your IP address, browser type, operating system, referring URLs, pages viewed, and the dates/times of your visits. This data is primarily collected through cookies and similar technologies (See Cookies Selection below).
• Cookies: Our website uses cookies to enhance your Browse experience, analyse site traffic, and understand user behaviour.

Cookies and tracking technologies 

Necessary Cookies

These cookies are required for the website to function properly.

Functional Cookies

These cookies add functionality from approved third party services.

Analytics Cookies

These cookies allow us to understand user behaviour on the website, anonymously.

Lawful Basis for Processing Your Data

We rely on the following lawful bases under UK GDPR for processing your personal data collected via the website:

Legitimate Interests: For website analytics, improving our website, preventing fraud, and responding to general inquiries where we believe our interests are balanced against your rights and freedoms. Our legitimate interest is to maintain an effective and engaging website and communicate effectively.

Consent: For non-essential cookies (e.g., analytics, marketing cookies) and for sending you marketing communications (like newsletters), where required. You have the right to withdraw your consent at any time.

Performance of a Contract: If you are applying to become a mentor application or making a donation that forms a contractual relationship.

Legal Obligation / Substantial Public Interest: Where we are required to process data to comply with a legal obligation such as safeguarding purposes, including criminal background checks for mentors or for reasons of substantial public interest (safeguarding children and individuals at risk).

How We Use Your Personal Data

We use the personal data collected from our website for the following specific purposes:

• To respond to your general inquiries and provide you with information you request.
• To process and manage mentor applications, including conducting necessary criminal background checks, to assess suitability for working with vulnerable young people, and to meet our safeguarding obligations.
• To manage your newsletter subscriptions 
• To improve our website’s content, functionality, and user experience.
• To analyse website traffic and user trends.
• To process donations securely.
• For internal administrative purposes and record-keeping.
• To comply with legal and regulatory obligations.

Sharing Your Personal Data

MCR Pathways will not sell or rent your personal data to third parties. We may share your data in the following limited circumstances:

• Service Providers: With trusted third-party service providers who assist us in operating our website, conducting our business, or providing services to you (e.g., website hosting, analytics providers, payment processors, applicant tracking systems, background check providers/vetting bodies). These providers are contractually bound to protect your data and only use it for the purposes we specify.
• Legal Requirements: When required by law, court order, or to protect our rights, property, or safety, or the rights, property, or safety of others.
• Organisational Changes: In the event of a merger, acquisition, or restructuring of MCR Pathways, your data may be transferred to the new entity.

International Data Transfers

MCR Pathways primarily processes and stores data within the United Kingdom. However, some of our third-party service providers (e.g., cloud hosting, analytics tools, email platforms) may store or process data outside the UK. Where this occurs, MCR Pathways ensures appropriate safeguards are in place to protect your data, such as relying on adequacy decisions by the UK government or implementing Standard Contractual Clauses (SCCs) approved for UK transfers.

Data Retention

We will retain your personal data for no longer than is necessary for the purposes for which it was collected, and in line with our internal Data Retention Policy. Data collected via website forms (e.g., general inquiries) will be kept only as long as needed to address your inquiry. Data related to mentor applications, will be retained according to our Data Retention Policy, details of which are provided in the Volunteer Mentor Privacy Notice. Anonymous website usage data may be retained for longer for analytical purposes.

Your Data Protection Rights

Under UK GDPR, you have the following rights regarding your personal data. To exercise any of these rights, please email privacy@mcrpathways.org:

• The Right to Be Informed: To receive clear, transparent, and easily understandable information about how we use your data.
• The Right of Access (Subject Access Request – SAR): To request a copy of the personal data we hold about you. We will respond within 30 days of receipt.
• The Right to Rectification: To request that inaccurate or incomplete personal data we hold about you be corrected.
• The Right to Erasure (“Right to be Forgotten”): To request the deletion or removal of your personal data where there is no compelling reason for its continued processing. Please note that certain data, particularly criminal conviction data required for safeguarding, may be exempt from immediate erasure due to legal obligations.
• The Right to Restrict Processing: To request the suspension of processing of your personal data in certain circumstances.
• The Right to Data Portability: To receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller, where technically feasible.
• The Right to Object: To object to the processing of your personal data based on legitimate interests (unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms) or for direct marketing purposes.
• The Right to Withdraw Consent: Where we rely on your consent for processing (e.g., for certain cookies or marketing emails), you have the right to withdraw that consent at any time.

Links to Other Websites

Our website may contain links to other websites of interest. Please note that we do not have any control over these external websites. Therefore, we cannot be responsible for the protection and privacy of any information 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 policy applicable to the website in question.

Complaints

If you have concerns about how MCR Pathways has processed your data or handled your requests regarding your data, please contact us in the first instance at privacy@mcrpathways.org. We aim to resolve all complaints promptly and fairly.

If you are not satisfied with our response or how we have handled your complaint, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s independent authority for upholding information rights. Their helpline number is 0303 123 1113, or you can visit their website at www.ico.org.uk.

Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our practices or for legal or regulatory reasons. We encourage you to review this page periodically for any updates. The “Last Updated” date at the top of this notice will indicate when it was last revised.

Contacting Us

For any questions or concerns about this Website Privacy Notice or our data protection practices, please do not hesitate to contact us at:

privacy@mcrpathways.org