The JTS service is text/phone helpline for our community teens providing non-judgemental support, guidance, empowerment for any emotional challenges they may be facing. Trained volunteer counsellors are available to have conversations with texters/callers in which teens feel able to discuss difficult topics. Volunteer counsellors support, guide and empower teens and if necessary, help them form an action plan or signpost them on to more appropriate services. Our volunteers are trained and supervised by clinical staff.
Your privacy and the security of information about you are very important to us. Our privacy and security guidelines apply to all JTS volunteers, JTS therapists as well as well as those who provide technical support. We take these privacy safeguards very seriously
Please read through these documents before using the service. If you have any questions email email@example.com
- Changes to the terms
The Terms may be changed from time to time. The most up-to-date Terms will always be the ones that are posted here. Changes to the Terms of Service will be effective immediately upon our posting them here on our website.
If we decide to make any changes which affect how we use your personal information we will place clear notifications on the front page of our website for a minimum of a month prior to those changes being implemented. This is to allow you time to review them here. If you then continue to use the Service after that time we will take it that you agree to those changes.
On each separate occasion that you first send a text or call JTS to initiate a conversation, you will receive an automated message with a request to go to our website to find out more information about our service. By using our Service after receiving the initial automated message, you agree to the practices outlined in the current Terms, including the collection and processing of your personal data, including special category data.
In order to protect your confidentiality, we never initiate direct contact with you. We are therefore unable to notify you directly of any changes to the Terms. Your use of the service after any such changes have been posted shall constitute your acceptance of the revised Terms.
- Collection and use of your personal and special category data
When you first text us we will NOT be able to see your mobile telephone number. Instead, the software will allocate you a unique ID number and it is ONLY with this number which we will identify you by. Our software provider, Call Handling Services Limited will be able to locate your phone number. Only in rare situations will we need to obtain your mobile phone number from the software provider and when we do we will tell you about it. (For further information about see section of this policy titled “CONFIDENTIALITY AND DISCLOSURE TO THIRD PARTIES.”)
If you contact us by phone, the volunteer counsellors will not be able to see your phone number. Only those with supervisor access will be able to see your phone number. All calls are recorded and kept by Call Handling Services Limited for the duration of 45 days.
If you are referred to a JTS therapist then we will ask you for a contact number so that the therapist can contact you at the agreed upon time and date. The therapist will delete this information upon conclusion of therapy.
We do not require you to supply any other personal data in order to access our service. We do not even need your name.
- What personal and special category data we collect
We do not routinely collect any other personally identifying data from you. But, in order to help you more effectively we may ask you for your age and gender. You may wish to provide us with your first name, but please do not tell us your surname.
When you are in conversation with us you may be upset or in a difficult situation. You may choose to tell us things that are deeply personal to you, that you may never have told another person. This could mean that you may tell us things which involve the following topics:
- ethnic origin;
- political opinions;
- religious or philosophical beliefs;
- sexual orientation.
- Location data
We do not routinely gather data about your specific location. If you message us, we do not automatically know where you are. There are occasions when we may ask you to give us your location. You are not under any obligation to give it to us. We will only ever ask for it if we feel that we need it to help you. You can find more information about this in the section of this policy titled “CONFIDENTIALITY AND DISCLOSURE TO THIRD PARTIES.”
We may collect general location data such as region and city in our optional post conversation survey. You are not under any obligation to provide this information to us.
- How we use your personal and sensitive data
Our software provider Call Handling Services Limited holds call records, data Capture records, transaction records, SMS messages will be for a maximum of 3 years. Call recordings are retained for 45 days. This data is kept for a few reasons. We use the information for internal purposes such as auditing, data analysis and research to improve the service that we provide; additionally, we clear it of all personal data (so that you can never be identified) and use the anonymised data that is produced to conduct an analysis of the trends that are occurring within our conversations.
If you are also eligible for phone therapy with a qualified therapist then we will also ask you for permission to send a copy of your text messages between you and the volunteer to the therapist. This enables the therapist to get a greater understanding of you and the issue.
- Collection and use of data that is neither personal nor sensitive
We also collect data that is neither personal nor special category; that is, data that cannot be directly used to identify or contact you. We may collect, use, transfer, and disclose this type of data for any purpose, including but not limited to improving services, disclosing to third parties to generate support for JTS, or as required by law.
Below are examples of data that are neither personal nor sensitive, that we collect and how we may use it:
We may use aggregated, anonymised information such as age, gender, language, and the time of our conversation to better understand user behaviour and improve our service.
We also may collect information regarding usage of JTS’s service, such as the conversation volume, average length of conversation, and other data. This information is aggregated and helps us conduct internal research, so we can improve the quality of our service.
- Confidentiality and disclosure to third parties
JTS respects and seeks to preserve the confidentiality of people who use our service. This confidentiality is based on the common law ‘duty of confidence’ and is shared between you, the service user and JTS. Our Volunteers and Supervisors also have an obligation of confidentiality. They will only use and disclose any information provided to them within the rules set by JTS. We do not routinely ask for names or location information. No identifying information or discussion between you and the service is disclosed to an external third party except in the exceptional circumstances outlined below.
We will always endeavour to get your consent before we contact a third party but there are situations, described below, where we will pass on information without consent. If we deem that the situation is safe for you, we will work with you in making decisions about involving a third party. We will only share information with people or entities when the law allows us to do so.
We will always think carefully about whether we need to break confidentiality. This is especially important if you are a young person, aged under 18. We will choose to break confidentiality and engage with a third party in the following circumstances:
- You ask us to;
- We believe that your life or someone else’s life is in imminent danger;
- You are a young person, aged under 18, who is being hurt, abused or neglected;
- You tell us that you are endangering the safety of another person.
- We are aware of specific information about a terrorist suspect or terrorist activity that will take place or has taken place in the world.
- We are forced through legal action to disclose specific confidential information; this can include legal action taken under the Data Protection Act and during criminal investigations.
- Police, social and medical services
If one of our Volunteer counsellors identifies imminent risk of harm to yourself or someone else (you have the desire, plan, means, timeframe) or suspects emotional/physical abuse or neglect, they may let you know they’re concerned about your safety. At this point, they might ask you for some identifiable information (such as your phone number, age, where you are and your name). If they have concerns about your safety or you share information about the abuse of a child or young person, they may contact the police, medical, or social services.
- JTS volunteers
Our service is made up of volunteer counsellors, managers and JTS supervisors. Any information, including Personal and Special Category Data, that you share with us may be viewed by the above people, for quality control, to contact emergency services or to better assist you with your need.
If you provide feedback through an anonymous feedback survey, that feedback may also be shared with the above people.
We do hope in the future that we may share anonymised data with trusted researchers when it will result in insights that create a better experience for our service users. We will always follow best practices for sharing data based on the guidance from the institution’s ethics committee, and any relevant legal limitations or security checks.
- Outside resources
Sometimes, we may provide information and signpost to another service. We will give YOU information to help you contact them, but we will NOT give them your contact information. It is up to you if you want to follow our signpost to their service. If you would like to receive support from other services, please note that different rules may apply to their use or disclosure of Personal and Special Category Data. We do not control the privacy policies of other services.
- Other third parties; legal processes
In certain narrow circumstances, we may disclose Personal Data that we collect from you to additional third parties if we believe such disclosure is necessary:
- to comply with the law or in response to a court order, government request, or other legal process;
- to protect the interests, rights, safety, or property of JTS, its employees, therapists, mangers, supervisors including but not limited to our volunteer counsellors.
- Retention of information
Our software provider. Call Handling Services LTD stores two different types of data after our conversation with you. Your Personal and Special Category Data, that is your telephone number and the record of all the text messages that you exchange with us. This will be stored for up to 3 years after you last contact us. For the phone line, your phone number and recording of calls will be stored for 45 days. Once this time has passed, they will permanently delete this data from their records. If you contact us again after this time, you will appear to be a new service user. We will not have any record of our previous conversations with you.
We anonymise the data that is extracted from our conversations with you. This anonymised data will be retained indefinitely. This data is independent of the text record and cannot be attributed to you. We keep this data as it helps us to improve our own services and it contributes to our data set.
- How we protect your personal and sensitive data
Our software providers Call Handling Services Limited take the protection of your data very seriously. They take administrative, technical, and physical measures, to protect your Personal and Sensitive Data from loss, theft, misuse, unauthorised access, disclosure, alteration, and destruction. They store all information on servers within the UK and will not use any data for their own market research, marketing, or behavioural analysis.
They do not sell or otherwise release this data to anyone other than the JTS, and even then, only in the form of statistics or as part of the JTS service provision. Call Handling Services Limited only permit approved employees and third parties, such as data processors to access their servers.
Although Call Handling Services have never had a data breach and make every effort to guard against one, they cannot absolutely guarantee that there will never be unauthorised access or interception by third parties.
JTS will take all reasonable precautions to protect your data which is transferred between members of staff and that which is stored for safeguarding and administrative purposes.
- You should also protect yourself
Always be careful and responsible regarding your Personal and Sensitive Data. You might want to delete our conversations from your phone. You might even want to clear us from your history and make sure we are not saved in your contact list.
- Your rights regarding your personal and sensitive data
If you wish to exercise any of your rights, as listed below please write to us at firstname.lastname@example.org or the address below for:
- Access to your personal information;
- Objection to processing of your personal information;
- Restriction of processing of your personal information;
- Your personal data portability;
- Rectification of your personal information; or
- Erasure of your personal information.
If you make a request relating to any of the rights listed above, we will consider each request in accordance with all applicable data protection laws and regulations. No administration fee will be charged for considering and/or complying with such a request unless the request is deemed to be excessive in nature. Upon successful verification of your identity you are entitled to obtain the following information about your own personal information:
- The purposes of the collection, processing, use and storage of your personal data.
- The categories of personal data stored about you.
- The recipients or categories of recipients to whom your personal data has been or may be transmitted, along with the location of those recipients.
- The envisaged period of storage for your personal data or the rationale for determining the storage period.
- You may request that we delete your Personal and Sensitive Data, such as your name, physical address (if applicable), phone number, and texts/message transcripts.
You can make any of the other above requests by emailing email@example.com or by writing to:
Data Protection Officer
1 The Approach
You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you believe your data has been processed in a way that does not comply with the GDPR. You can do so by calling the ICO helpline on 0303 123 1113 or via their website.
- Data Protection information
Contact JTS by emailing firstname.lastname@example.org or by writing to:
Data Protection Officer
1 The Approach
Created: 14 December 2020
By Jacob Barr (Head of Service)