Privacy Policy

1. Who We Are

[Bold Cymru Ltd / BUILDING OPPORTUNITIES LEARNING DISABILITIES LTD is a company registered in England and Wales with company number 15928115 whose registered office is at 16 Nant Celyn, Crynant, Neath, Wales, SA10 8PZ.

All references to “we”, “us” or “our” in this policy are to Bold Cymru.

If you have any questions about this Privacy Policy or how we use your information, contact us using the details at the end of this statement.

2. Controller

Unless otherwise stated, [Bold Cymru Ltd] is the Data Controller of the personal data we process. This means we determine what personal data is collected and how it’s used.

3. Family Members, Representatives and Advocates

Where you’re acting on behalf of a person we support, we may collect:

Name and contact details
Relationship to the person we support
Authority to act on their behalf

4. Referring Authorities and Professionals

Where referrals are made by local authorities, health boards, CCGs or partner agencies, we may process personal data required to assess suitability and deliver supported living services, including information about learning disabilities, autism, mental health needs and behavioural support requirements.

5. Job Applicants and Employees

If you apply to work with us, we may collect:

Name, contact details and employment history
Qualifications and training records, including PBM/PBS training
Right-to-work documentation
DBS and safeguarding information
References

For employees, we also process payroll, pension and HR-related information in accordance with employment law.

6. Website Users

When you use our website, we may collect:

Contact and referral form submissions
Cookie and analytics data
Technical information such as IP address and browser type

See our Cookie Policy for more information.

7. How We Use Your Information

We use personal data to:

Assess and deliver safe, person-centred supported living
Communicate with the people we support and their representatives
Comply with safeguarding and CIW regulatory obligations
Manage referrals and support planning
Process job applications and employment matters
Improve our services and website
Meet legal and contractual obligations

8. Lawful Basis for Processing

Depending on the circumstances, we rely on one or more of:

Performance of a contract
Compliance with a legal obligation
Legitimate interests
Consent
Provision of health or social care (for special category data under Article 9 UK GDPR)

9. Who We May Share Your Data With

We may share personal data where necessary with local authorities and commissioning bodies, health boards and NHS professionals, CIW and other regulatory authorities, safeguarding bodies, professional advisors and auditors, IT and secure service providers, and law enforcement agencies where required by law. We do not sell personal data to third parties.

10. Keeping Your Data Secure

We use appropriate technical and organisational safeguards, including secure IT systems, restricted access to sensitive information, staff training on data protection and confidentiality, and encryption where appropriate. While we take reasonable steps to protect personal data, transmission over the internet is never completely secure.

11. International Transfers

We do not routinely transfer personal data outside the UK. Where third-party providers process data outside the UK, we ensure appropriate safeguards are in place under UK data protection legislation.

12. Retention of Data

We retain personal data only as long as necessary: enquiries up to 6 months, employment applications up to 12 months, care and support records in line with CIW and statutory guidance, marketing communications until you unsubscribe. Retention periods may vary depending on legal and regulatory requirements.

13. Your Rights

Under data protection law, you have the right to request access to your personal data, request correction of inaccurate information, request erasure where applicable, restrict or object to processing, withdraw consent where processing is based on consent, and lodge a complaint with the Information Commissioner’s Office (ico.org.uk). To exercise your rights, contact us in writing using the details below.

14. Changes to This Policy

We may update this Privacy Policy from time to time. The most recent version will always be available on our website.

15. Contact Us

Bold Cymru
Address: 16 Nant Celyn, Crynant, Neath, Wales, SA10 8PZ

Email: Nikki.Doyle@bold.cymu

Telephone: +44 7889 727061