Jump Start Therapy CIC

Customer Privacy Notice

This privacy notice tells you what to expect us to do with your personal information.

Contact details

Telephone: 07920573860

Email: amie@jumpstarttherapy.org.uk

What information we collect, use, and why

We collect or use the following information to provide services and goods, including delivery:

  • Names and contact details

  • Addresses

  • Date of birth

  • Purchase or account history

  • Payment details (including card or bank information for transfers and direct debits)

  • Health information (including dietary requirements, allergies and health conditions)

  • Health and safety information

  • Account information

  • Website user information (including user journeys and cookie tracking)

  • Photographs or video recordings

  • Records of meetings and decisions

  • Identification documents

  • Information relating to compliments or complaints

We also collect or use the following special category information to provide services and goods, including delivery. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following information for the operation of customer accounts and guarantees:

  • Names and contact details

  • Addresses

  • Payment details (including card or bank information for transfers and direct debits)

  • Purchase history

  • Account information, including registration details

  • Information used for security purposes

  • Marketing preferences

We also collect or use the following special category information for the operation of customer accounts and guarantees. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following information to prevent, detect, investigate or prosecute crimes:

  • Names and contact information

  • Customer or client accounts and records

  • Criminal offence data (including Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)

  • Financial transaction information

  • Information relating to health and safety

We also collect or use the following special category information to prevent, detect, investigate or prosecute crimes. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following information for service updates or marketing purposes:

  • Names and contact details

  • Addresses

  • Marketing preferences

  • Recorded images, such as photos or videos

  • Purchase or viewing history

  • IP addresses

  • Website and app user journey information

  • Records of consent, where appropriate

We collect or use the following information for scientific or historical research purposes, for statistical purposes or for archiving in the public interest:

  • Purchase or viewing history

  • Personal information used for the purpose of research

  • Records of consent, where appropriate

  • Health information

We collect or use the following information to comply with legal requirements:

  • Name

  • Contact information

  • Financial transaction information

  • Any other personal information required to comply with legal obligations

  • Health and safety information

  • Safeguarding information

We also collect or use the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following information for recruitment purposes:

  • Contact details (eg name, address, telephone number or personal email address)

  • Date of birth

  • National Insurance number

  • Copies of passports or other photo ID

  • Employment history (eg job application, employment references or secondary employment)

  • Education history (eg qualifications)

  • Right to work information

  • Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)

  • Security clearance details (eg basic checks and higher security clearance)

We also collect or use the following special category information for recruitment purposes. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following personal information for dealing with queries, complaints or claims:

  • Names and contact details

  • Account information

  • Purchase or service history

  • Witness statements and contact details

  • Customer or client accounts and records

  • Financial transaction information

  • Information relating to health and safety

  • Correspondence

We also collect the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following information to To securely process Special Category Health Data, sensory preferences, and SEND accommodation profiles under UK GDPR Article 9(2)(h) to ensure physical and psychological safety during specialist gymnastics and Occupational Therapy sessions:

  • Names and contact details

  • Date of birth

  • Purchase or account history

  • Health information (including dietary requirements, allergies and health conditions)

  • Photographs or video recordings

  • Records of meetings and decisions

  • Customer or client accounts and records

  • Recorded images, such as photos or videos

  • Records of consent, where appropriate

We also collect or use the following special category information to To securely process Special Category Health Data, sensory preferences, and SEND accommodation profiles under UK GDPR Article 9(2)(h) to ensure physical and psychological safety during specialist gymnastics and Occupational Therapy sessions. This information is subject to additional protection due to its sensitive nature:

  • Health information

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide services and goods are:

  • Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • Our legitimate interest is the efficient administration, coordination, and safety management of our mobile therapeutic movement, gymnastics and occupational therapy service. Because we operate as a mobile social enterprise across multiple hired village halls and school venues, we require basic operational data (such as booking records, session histories, and contact logs) to manage schedules, optimise venue setups, and ensure equipment safety. Furthermore, as a Community Interest Company (CIC), we have a legitimate interest in processing anonymised attendance metrics to generate community impact reports, satisfy our mandatory annual CIC34 regulatory filings, and secure grant funding to expand our services. The benefits of this processing heavily outweigh any minimal privacy risks to our service users. We process only necessary administrative data, enforce strict access controls, and never sell or share data for commercial marketing. For our families, this processing ensures seamless session coordination, small and safe class sizes, and the long-term sustainability of a vital community service tailored to neurodivergent and SEND youth.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • Our legitimate interest in operating customer accounts is to provide a secure, efficient, and user-friendly digital platform for families to manage their recurring therapeutic and gymnastics sessions. Because we coordinate services across multiple venues, persistent user accounts are necessary to track client attendance, process secure transactions via our payment gateway, manage block bookings for our 1-to-1 and group sessions, and maintain continuity of service. This processing directly benefits our users by allowing them to easily update their contact preferences, review their service history, and manage their bookings at their own convenience. The privacy risk to individuals is minimal, as account data is restricted to essential administrative and transactional details, protected by strict security protocols, and is never sold or shared with third parties for commercial marketing. This administrative structure is vital for the operational efficiency and long-term financial sustainability of our social enterprise.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information to prevent, detect, investigate or prosecute crimes are:

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • Our legitimate interest is to protect our organisation\'s physical and digital assets, ensure the safety of our staff and service users, and prevent financial fraud. Because we operate as a mobile service transporting specialist gymnastics and therapeutic equipment in a dedicated van to various hired community and school venues, we have a legitimate interest in processing necessary data (such as transaction records and booking identifiers) to protect our equipment from theft and defend our automated billing systems from fraudulent transactions. Furthermore, we have a vital legitimate interest in maintaining an ironclad safeguarding environment for the vulnerable SEND youth in our care. In the rare event of a physical security breach, financial fraud, or a serious safeguarding incident at a hired venue, processing this information allows us to investigate internally and cooperate fully with law enforcement or regulatory bodies. The benefits of this processing heavily outweigh any impact on individuals. Data processing for this purpose is strictly reactive and restrictive; it is only ever invoked to investigate specific security threats or fraudulent activities, ensuring that the privacy of our regular families is entirely unaffected and their community assets are fully protected.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

  • Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • Our legitimate interest is to provide timely, relevant, and necessary service updates and promotional alerts to our existing customers to ensure the smooth operation and financial sustainability of our mobile therapeutic services. Because we utilise a mobile equipment van across multiple hired village halls and school venues, we require the ability to communicate directly with our active families regarding immediate logistics, venue changes, scheduling modifications, or urgent operational updates that directly impact their booked sessions. Furthermore, because our business model relies on a blend of break-even group sessions and higher-margin 1-to-1 therapeutic blocks, we have a legitimate interest in notifying our active customer base when premium 1-to-1 slots or holiday blocks become available due to cancellations. This allows us to maximise our session occupancy, protect our social enterprise\'s revenue stream, and maintain the financial viability required to deliver our core services. The benefits of this communication heavily outweigh any potential privacy risks to our users. We do not use intrusive tracking, we never sell or share customer data with third parties for commercial gain, and we limit our messaging strictly to our own relevant therapeutic and movement services. Every operational and promotional message features a clear, immediate, and frictionless mechanism to opt out of future communications, ensuring that our needs never unfairly override the privacy preferences or autonomy of our families.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for scientific or historical research purposes, for statistical purposes or for archiving in the public interest are:

  • Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • Our legitimate interest is to compile, analyse, and process anonymised statistical data regarding session attendance, service delivery volumes, and therapeutic outcomes. Because we operate as a mobile social enterprise using a dedicated equipment van across various hired village and school venues, generating these metrics is necessary for internal service evaluation, monitoring equipment utilisation, and ensuring total clinical safety. Furthermore, as a regulated Community Interest Company (CIC), we have a critical legitimate interest in compiling aggregated social impact data to complete our mandatory annual CIC34 reports for the CIC Regulator. We also utilise these anonymised statistics as essential evidence when applying for grant funding to secure permanent equipment, expand our successful Rebound pilot, and integrate our upcoming Occupational Therapy services. The benefits of this processing heavily outweigh any minimal risks to our individuals. All data used for statistical reporting is strictly pseudonymised and aggregated, meaning no individual child or parent can be identified in any public or funding report. We enforce rigid internal access controls, never use this data for tracking or commercial marketing, and limit its scope strictly to demonstrating our community impact. This statistical architecture is vital to prove our efficacy, maintain our academic-year school contracts, and secure the long-term sustainability of our SEND services.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for legal requirements are:

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for recruitment purposes are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • Our legitimate interest is to process, evaluate, and securely retain candidate applications, CVs, and interview notes to facilitate an efficient, safe, and professional recruitment process. Because we operate a mobile OT, SEND gymnastics and therapeutic movement service across various hired village halls and school venues, we have a legitimate interest in identifying and maintaining a talent pipeline of specialist coaches, volunteers, and future Occupational Therapists. This ensures operational continuity, allows us to service our academic-year school contracts efficiently, and supports the expansion of our high-margin 1-to-1 therapeutic sessions. Furthermore, because our team works directly with vulnerable SEND youth in small group environments, we have a vital legitimate interest in processing applicant data to execute rigorous pre-employment screening, verify professional credentials, and fulfill our strict UK safeguarding and Enhanced DBS vetting duties before any hiring contract is formalized. The benefits of this processing heavily outweigh any potential risks to the individuals involved. Candidates voluntarily submit their personal data with the explicit intention of seeking employment or volunteering opportunities. We protect candidate privacy by enforcing strict data minimization, restricting internal access to hiring managers, and implementing a clear retention schedule where unsuccessful applications are securely destroyed after 6 months unless the candidate explicitly requests otherwise. This recruitment architecture is essential to protect our community assets, maintain total clinical safety, and ensure the long-term sustainability of our social enterprise.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • Our legitimate interest is to efficiently manage, resolve, and maintain an accurate administrative record of all customer queries, operational complaints, and legal claims. Because we operate a mobile therapeutic and gymnastics service across multiple hired community and school venues, we require a reliable correspondence trail to address user feedback, optimise our venue safety layouts, manage booking changes for our 1-to-1 and group sessions, and ensure continuous quality assurance across our coaching staff. Furthermore, we have a vital legitimate interest in retaining detailed logs of any operational incidents, grievances, or safety concerns to fulfill our statutory safeguarding duties, protect our staff, and defend our organisation against potential liabilities or insurance claims. This record-keeping is critical to protect the financial assets and community asset lock of our Community Interest Company (CIC), satisfy our annual CIC34 regulatory reporting, and maintain our stable academic-year contracts with special schools. The benefits of this processing heavily outweigh any minimal risks to our service users. We only collect and retain information that is strictly relevant to the specific query, complaint, or claim. This data is kept strictly confidential within secure administrative systems, is subject to robust data retention schedules, and is never used for tracking or commercial marketing. For our families, this practice guarantees that their concerns are handled with absolute professionalism, transparency, and clinical accountability, ensuring the long-term safety and sustainability of our community SEND services.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for To securely process Special Category Health Data, sensory preferences, and SEND accommodation profiles under UK GDPR Article 9(2)(h) to ensure physical and psychological safety during specialist gymnastics and Occupational Therapy sessions are:

  • Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • Our legitimate interest in processing pseudonymised health and disability information is to safely manage, group, and administer our specialist SEND gymnastics and therapeutic movement sessions. Because we operate as a mobile service utilising a dedicated equipment van across multiple hired village and school venues, we have a legitimate interest in analysing aggregated health profiles to ensure that our physical setups, venue choices, and staff allocations match the specific sensory and physical accessibility needs of our attendees. This processing is essential to maintain our strict safety limit of 4–6 children per group session and to optimise the delivery of our high-margin 1-to-1 therapeutic blocks. Furthermore, we utilize anonymized, macro-level health and disability statistics derived from our intake data to complete our mandatory annual CIC34 reports for the CIC Regulator and to provide evidence-based social impact metrics for grant funding applications. This funding is vital to secure permanent equipment, expand our successful Rebound pilot, and pave the way for our upcoming integrated Occupational Therapy clinical services. The benefits of this processing heavily favor our service users, as it allows us to design highly regulated, neuro-affirming environments that protect the physical safety and emotional autonomy of SEND youth. The privacy risk is negligible because individual clinical details are locked behind strict access controls, used solely for internal session coordination, and are never shared with external parties for commercial or marketing purposes.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Where we get personal information from

  • Directly from you

  • Health care providers

  • Schools, colleges, universities or other education organisations

  • Councils and other public sector organisations

  • Previous employers

  • Suppliers and service providers

How long we keep information

As a provider of specialist SEND gymnastics, therapeutic movement, and integrated Occupational Therapy (OT) services for children and vulnerable young people, we enforce a strict, legally mandated data retention schedule. We store different categories of personal information for varying lengths of time to comply with UK clinical, safeguarding, financial, and employment laws.

| Data Category | Specific Types of Data | Retention Period & Rationale |

| Pediatric Clinical & Therapeutic Records | Special Category Health Data, SEND sensory profiles, milestone tracking, EHCPs, and progress notes. | Until the child’s 25th birthday (or 26th birthday if they were 17 at the time of treatment). This complies with the UK Limitation Act 1980 and NHS clinical records standards for pediatric therapies. |

| Operational & Session Administration | Hired venue logs, mobile equipment van schedules, session booking registers, and parental emergency contact details. | 3 years following the conclusion of the academic-year service contract or session block, to verify operational safety compliance. |

| Financial & Transactional Records | Online booking payments via our payment gateway, invoicing trails, bank transfers, and automated billing records. | 6 financial years plus the current year, to comply with mandatory statutory auditing requirements under HMRC and the UK CIC Regulator (for our annual CIC34 filings). |

| Staff & Volunteer Vetting (Safeguarding) | Verification logs of mandatory Enhanced DBS background checks, professional references, and safeguarding training records. | For the active duration of employment, plus 25 years following their departure from the organization, to satisfy strict UK child safeguarding defense and insurance parameters. |

| Recruitment (Unsuccessful Candidates) | CVs, job applications, qualifications, and interview notes from individuals not selected for coaching roles. | 6 months from the date of the hiring decision. Data is then securely destroyed to prevent unnecessary data hoarding under UK GDPR data minimization rules. |

| Queries, Complaints, and Legal Claims | Correspondence logs, formal complaint files, accident/injury logs at hired community halls, and witness statements. | 6 years from the date of final resolution, to protect corporate assets and defend the organization against insurance or civil liabilities. |

How we destroy data: Once personal information reaches its designated expiration date under this schedule, it is permanently and securely deleted from our Google Workspace cloud architecture and Smile Notes electronic database using enterprise-grade electronic erasure protocols. Any temporary paper files or printed attendance registers are instantly destroyed via cross-cut secure shredding.

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

Who we share information with

Data processors

FinTech\/Payment Processors (UK\/EEA) for session billing. 2. Cloud Admin\/CRM (Sports\/Education, UK\/EEA) for van logistics & registers. 3. Secure Health-Tech Platforms (UK\/EEA) for clinical notes & SEND sensory profiles.

This data processor does the following activities for us: Our data processors execute specific operational, financial, and clinical tasks on our behalf to support our mobile OT, SEND gymnastics and therapeutic movement services across various hired village halls and special schools. Their processing activities are categorised as follows: 1. Financial & Payment Processing: Our FinTech and merchant processors (operating within the UK\/EEA) securely handle online booking payments, automate recurring invoicing, and process transactional records for our after-school sessions, corporate school commissions, and high-margin 1-to-1 therapeutic engine blocks, ensuring full financial compliance and transparent accounting for our annual CIC34 regulatory reporting. 2. Cloud Administration, Scheduling & CRM: Our administrative software processors manage our mobile operations, including equipment van logistics, venue hire calendars, parental emergency contact databases, and session attendance registers. They also securely host job applicant CVs, professional references, and tracking logs for mandatory Enhanced DBS safeguarding checks during our coaching and volunteer recruitment rounds. 3. Secure Health-Tech & Clinical Records Storage: In preparation for our integrated Occupational Therapy (OT) framework, our specialized healthcare data processors securely host highly sensitive client profiles. This includes pediatric medical histories, neuro-affirming sensory-avoidant profiles, EHCP documents, and clinical milestone progress notes, maintaining absolute compliance with HCPC guidelines and UK statutory healthcare retention laws.

Others we share personal information with

  • Health care providers

  • Organisations we need to share information with for safeguarding reasons

  • Professional or legal advisors

  • Relevant regulatory authorities

  • Organisations we’re legally obliged to share personal information with

  • Emergency services

  • Publicly on our website, social media or other marketing and information media

  • Previous employers

Sharing information outside the UK

Where necessary, our data processors may share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.

Organisation name: Google

Category of recipient: Cloud Storage, Productivity, and Email Service Provider

Country the personal information is sent to: united states

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

Email: amie@jumpstarttherapy.org.uk

Telephone: 07920573860

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint


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🌟 Jump Start Therapy: Our Child-Friendly Privacy Notice

Hey kids! 🎒 When you come to jump, roll, play, and practice your exercises with the Jump Start Therapy and Occupational Therapy (OT) coaches, we look after some of your information to keep you safe. Here is how we do it:

  • What we know about you: 🤔 We know your name, your birthday, and a few things about how your body moves, how your senses feel things, and how you like to learn!

  • Why we keep it: 🔒 Your coaches and therapists use this information so they can plan the most fun, safe, and awesome gymnastics or therapy exercises just for you.

  • Who we show it to: 👥 We only show your information to your parents/carers and your coaching/therapy team. We never, ever sell it or show it to strangers.

  • Where we lock it up: 🖥️ Everything is locked away inside our secure, private digital filing cabinets on the computer where only our team can see it.

Your Rights: ✋ It is your data! If you ever want to know what notes we have about your jumping milestones or therapy progress, or if you want us to fix a mistake, you or your grown-up can ask us at any time.

© 2025. All rights reserved.

Registered Company No: 147 28657

24 Longleat Road, Holcombe, Radstock, BA3 5DY

Privacy Notice