GDPR - Legitimate Interests Assessment (LIA) 16 April 2018
The Charitable Purposes of The Foundation For Growth through Grieving (trading as the Emotional Logic Centre - ELC) are:
The ELC vision is: “One day, people everywhere will feel empowered to harness their unpleasant emotions during times of change or hurt, and turn them to constructive, useful purposes,”
and ELC mission is: “To train and support networks of skilled practitioners who enable individuals and families to learn practical life skills that help to turn the stress of unpleasant emotions into an ability to build adaptability and stronger relationships.”
Processing of data is all targeted at achieving the above aims and objectives, where grieving is not restricted just to bereavement through death but rather applies to any situation of loss. Emotional Logic was developed by a doctor as a lifelong learning, ‘home-or-workplace’ conversational method quite akin to systemic family therapy. It helps people of all ages to understand how unpleasant loss emotions have useful purposes when seen as part of an integrated process of adjusting to change, disappointment, setback or hurt. When one member of a family learns this way to understand and talk about emotions, he or she can teach it to others in the family, so a spreading wave of understanding can transform the atmosphere and social environment for growing children. Emotional Logic provides a solution-focused approach to managing distress, tension or confusion. It brings feelings and reasoning into a constructive partnership that leads to a values-based action plan. It is not counselling or therapy. It is a transferable life skill that builds relationship anywhere, anytime. The Emotional Logic Centre provides training for all ages to understand emotions in this constructive way.
The Emotional Logic Centre continues to research and develop new methods and tools to communicate the EL method well. As a lifelong learning method, we process data to inform those who have expressed an interest through any communication channel of access to training, whether that be tried and tested, or innovative new, courses or materials that help people find greater freedom and adaptability in life. The individual person benefits through being provided awareness of opportunities to extend their lifelong learning practice of the EL method; the ELC benefits in being able to propagate understanding of the method through wider areas of society. The ripples of such lifelong learning can positively impact workplace, homelife, education and healthcare arenas, and can be cross-generational. As an example, in a time where many studies consistently raise awareness of the prevalence of anxiety and depression causing significant distress and debilitation across many sectors of our society, without regard to age, socio-economic, cultural or any other delineating factor, it is critically important to be able to share good information about interventions that have great track record of having positive outcome to greater resilience and adaptability.
Without ability to share information about EL, the method and associated breakthrough tools and training would remain unharnessed for the good of society. ELC has no intention to use any data in any unethical or unlawful way and is simply genuinely interested in getting the good news as far and wide as possible in support of the stated charitable aims and vision/mission stated.
The processing of personal data is necessary to share information about access to the EL method lifelong learning opportunities. Since this is person-focussed lifelong learning, personal communications to individuals is absolutely reasonable, as ELC aims to be person-centric as an organisation, sharing information about learning opportunities only to those to whom the specific opportunity is deemed pertinent. Experience has shown us that generic advertising of training opportunities does not reach well at all those who have already expressed interest in EL, nor connect well with those people who would most obviously benefit from accessing the method; rather, personal contacts have had the most helpful outcomes. ELC also seeks to understand the effectiveness of its training opportunities and from time to time will solicit feedback from learners about their experiences.
As a person-centric organisation, the relationships of individuals to the ELC organisation are invariably based on personal conversations during which individuals have expressed interest to learn more. Notwithstanding a few exceptions (see below), data stored is of a very generic nature related to contact details and the nature of any contracts (purchases) made and any conversation had about further learning opportunities. ELC considers it reasonable to keep records of conversations about an individual’s learning progress in order to be able to share information about further opportunities for growth or practice of the method, and ELC is happy to explain this policy to individuals upon request. ELC does not find it at all likely, especially given the anticipated volume of sharing information, that individuals would object or find communications intrusive; there would be limited impact to the individual that may take the form of very occasional telephone, email or written letter interrupts.
Data pertaining to individual Personal Learning Appointments, in which a tutor helps to guide the self-help learning of an individual, inevitably causes more personal information to surface and those data will be handled accordingly; these appointments can apply to both adults and children and may include vulnerable individuals. All are treated with equal sensitivity and privacy.
ELC firmly believes the minor impact to an individual of the data stored and any learning opportunity notification is minimal compared to the potential of having the EL method positively impact both their lives and the social networks within which they live and breathe.
ELC can offer an opt-out to any individual who desires to cease their learning of EL or notification of further opportunities to do so.
ELC confirms that “Legitimate interests” is the most appropriate lawful basis for processing, outside of “Contracts” that applies to data processing for training services or resources sold through ELC’s website, events or network of skilled practitioners. We understand our responsibility to protect the individual’s interests, and have conducted the legitimate interests assessment (LIA) above to ensure that we can justify our decision. We have identified the relevant legitimate interests, and have checked that the processing is necessary and there is no less intrusive way to achieve the same result. We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests. We only use individuals’ data in ways they would reasonably expect, unless we have a very good reason. We are not using people’s data in ways they would find intrusive or which could cause them harm, unless we have a very good reason. If we process children’s data or those of vulnerable adults, we take extra care to make sure we protect their interests. We have considered safeguards to reduce the impact where possible. We have considered whether we can offer an opt out. If our LIA identifies a significant privacy impact, we have considered whether we also need to conduct a DPIA. We keep our LIA under review, and repeat it if circumstances change. We include information about our legitimate interests in our privacy information.
Emotional Logic Centre, South Highlands,
Blachford Road, Ivybridge
Devon, PL21 0AD
Tel: 01752 892455
UK Registered Charity No. 1107527
Company Registration No. 4756998
The Emotional Logic Centre is a UK registered charity (1107527)
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