Privacy Policy

The Modern Slavery and Helpline Resource Centre (MSHRC), is operated by Unseen (UK) and follows Unseen’s privacy policy. The following policy should be read in conjunction with Unseen’s Privacy Policy.

The MSHRC is committed to hosting a helpline that is victim-centred and prioritises the wellbeing, safety and recovery of potential victims. The MSHRC strives to protect the confidentiality of personal data provided by individuals contacting the Modern Slavery
Helpline and Resource Centre (MSHRC). All communication with the MSHRC will be treated as confidential to the extent permitted by applicable law. The policies outlined below have been designed to ensure the privacy and safety of the individual contacting the MSHRC, victims and survivors, and the Modern Slavery Helpline staff.
As the data controller, Unseen (UK) (“we”) promises to respect any personal data that you share with us or that other organisations share with us and to keep it safe. We want to be clear when we collect your data and be transparent about how we use your data. The Modern Slavery Helpline can be contacted by calling 08000 121700 or by using Unseen’s mobile app or a webform accessible via www.modernslaveryhelpline.org/report. You may wish to tell us about a suspected situation of modern slavery or request more information about modern slavery or relevant services. This policy will clearly set out the data that we collect, our reasons for collecting it and your options around how that data is used.

Data Protection Officer
Our Data Protection Officer is Stuart Mellis - Director of Finance & Operations. He can be contacted via email datacontroller@unseenuk.org.


Our Websites or Apps
Like most websites, we use “cookies” to help us make our site – and the way you use it – better. Cookies mean that a website will remember you. They’re small text files that sites transfer to your computer (or phone or tablet). They make interacting with a website faster and easier – for example by automatically filling your name and address in text fields. There are more details in our Cookies Policy. In addition, the type of device you’re using to access our website or apps and the settings on that device may provide us with information about your device, including what type of device it is, what specific device you have, what operating system you’re using, what your device settings are, and why a crash has happened. Your device manufacturer or operating system provider will have more details about what information your device makes available to us.
What personal data we collect, how we use it and the legal basis for processing The objective of the MSHRC is to provide a tool for victims of modern slavery to safely seek the help and information they urgently need, enable members of the public to report
potential and suspected incidences of modern slavery and frontline professionals to call for support and advice. The Helpline significantly increases the UK’s effective capability of dealing with modern slavery and therefore the lawful basis for processing personal information is that of carrying out a task in the public interest. Additionally, some of the data the Helpline collects rests on the consent of the caller, while all of the data the Helpline collects furthers the legitimate interests and mission of Unseen to end modern slavery.

Contacting the Helpline
The MSHRC treats communications with the Helpline as confidential while also prioritising the sharing of information relating to suspected instances of modern slavery with local authorities, police, relevant government entities, or other NGOs. Any sharing of information is limited by an overarching policy of ‘Do No Harm.’ As such, the Helpline will make every effort to ensure that the information shared by the MSHRC will not increase risk of harm to any individual. This means that if the MSHRC’s staff have a reasonable basis to suspect that the sharing of information about any particular instance or victim of modern slavery or trafficking would place suspected victims or survivors in greater danger or lead to greater harm suffered by suspected victims or survivors, then the MSHRC may refrain from referring the information concerned.

Contact by phone call
When you contact the Helpline by phone one of our trained advisors will answer your call. If you wish you may contact the Helpline without giving any personal details such as your name or contact details; please note section below on Caller ID. We will record any details that you share with us.

The Helpline advisor will ask you whether or not we can contact you. This is to allow us the opportunity to gather further information and determine how best we can help you. We will only contact you if you have given us permission to do so.

The Helpline advisor will ask you whether you are happy for your personal data, such as your name and contact details, that you have shared with us to be shared with a third party. Third parties who we may wish to pass your information to include police and other law enforcement agencies, local authorities and other NGOs.

Where contact information is required, and the sharing of contact details is a condition for requested action, such as application to the National Referral Mechanism, the MSHRC staff will inform the individual of the conditions to share contact information associated with the action requested by the individual and proceed in collecting and sharing that contact information with the understanding and consent of the caller.

Where the MSHRC determines that it may be beneficial to have a third party contact the caller directly, the caller’s consent to share the individual’s contact information with that third party will be confirmed before any contact information is shared. Individuals can withdraw their consent to be contacted or to have their contact information shared subsequently, according to the processes outlined above, in part or in full at anytime. We will only pass your personal data or contact information onto a third party if you have given us permission to do so or one of the following exceptions applies:
a. to comply with the law (e.g. the police, Inland Revenue and Council Tax Registration Officer) or a court order, or a lawful request from a regulatory body (Housing Corporation, Social Services, Inspection Unit)
b. where there is a clear risk of imminent harm to an individual
c. a call references the suspected abuse or neglect of a minor who remains at risk
d. anonymously for bona fide statistical or research purposes, provided it is not possible to identify the individuals to whom the information relates.

In cases a-c above, we will inform the caller or potential victim of the need to breach confidentiality prior to this happening or in all instances, as soon as possible afterwards, where possible, if prior notification is not possible. For specific cases in which a referral to a third party, such as police, local authorities or an NGO is needed, the MSHRC will make reasonable efforts to protect the identity of callers who wish to remain anonymous. The MSHRC will not confirm that a specific individual has or has not contacted the Helpline, unless the individual has provided the MSHRC with explicit consent to do so.


App or webform users
When you submit a report via the mobile app or the webform you may give us the following information:
- name or a pseudonym
- Email address
- Telephone number
However, the app or webform will also allow you to submit your form without any of these details being included.
We will use this information to record a suspected incidence of modern day slavery or prepare a response to a question, concern, or a request you have raised. The app or webform asks whether or not we can contact you. This is to allow us the opportunity to gather further information and determine how best we can help you. We will only contact you if you have given us permission to do so. The app or webform asks whether you are happy for the information you have shared with us to be shared with a third party. Third parties who we may wish to pass your information to include police and other law enforcement agencies, local authorities and other NGOs. We will only pass your information onto a third party if you have given us permission to do so, subject to the following exceptions:

  1. to comply with the law (e.g. the police, Inland Revenue and Council Tax Registration Officer) or a court order, or a request from a regulatory body (Housing Corporation, Social Services, Inspection Unit)
  2. where there is a clear risk of imminent harm to an individual
  3. a call references the suspected abuse or neglect of a minor who remains at risk
  4. anonymously for bona fide statistical or research purposes, provided it is not possible to identify the individuals to whom the information relates.In cases a-c, the caller or potential victim will be informed of the need to breach confidentiality prior to this happening or in all instances, as soon as possible afterwards, where possible, if prior notification is not possible.

Call Backs
In certain cases, the MSHRC may deem it necessary or advisable to place outgoing calls (“Call Backs”) to follow up on matters brought to the MSHRC’s attention. The MSHRC will place such Call Backs only to individuals who have provided their contact information directly to the MSHRC and have provided prior consent to such a Call Back. A caller may provide such consent orally during a call or when submitting on an online webform or submission via the app. A caller may limit the scope of his or her consent to permit the use of Contact Information to facilitate a Call Back by the MSHRC only, in which case the MSHRC will not disclose the Contact Information to any third party, unless one of the above exceptions apply. A caller also may specify whether a message may be left at the telephone number provided (whether with a person or on an answering machine/voicemail system), and how the relevant the MSHRC should refer to itself and to the individual when leaving any such message.


Caller ID

The Helpline uses a phone system that displays incoming phone numbers. The MSHRC may record information about incoming helpline calls made available through the Caller ID function (“Caller ID Information”). This enables Helpline advisors to identify if a caller has called before from that number and therefore speed our ability to respond to a potential victim of modern slavery or to be used in the exceptions listed above. The MSHRC will not use Caller ID information to facilitate Call Backs except in rare
circumstances, for example when it is believed that the caller has knowledge of a child or vulnerable adult at risk and this information is necessary to ensure immediate safety.

Call Recordings
Callers are informed at the start of a call by a recorded message before speaking with a Helpline Advisor, that calls to the Helpline may be recorded for training and quality purposes. Unless specifically saved, call recordings are automatically deleted after 30 days. Call recordings may be used by the Helpline Advisor immediately in order to aid the input of notes, after which point it would be deleted. Call recordings may be used confidentially, within the Helpline only for training purposes. Call recordings are not routinely included with referrals to third parties and recordings would only be shared externally in accordance with this privacy policy.

Children’s data
From time to time the Helpline receives personal information relating to children, some who are older than 13 years old and some who are younger than 13 years old. For the latter category we do not seek to verify the age of the child or to seek consent for holding their personal information. The lawful basis for the processing of the personal information of children is that of carrying out a task in the public interest and may be necessary to protect vital interests of the child.

Referring to Third Parties
When a caller provides information about a potential case of modern slavery, the MSHRC conducts a comprehensive and formal review of all such cases. The MSHRC respects an individual’s right to make the decision regarding whether or not to report information about his/her identity to police or other parties. For suspected instances of modern slavery and for other suspected crimes, the MSHRC may report information about specific situations to one or more specialised government agencies, police units, potentially involved businesses, or NGOs with expertise in addressing modern slavery or vulnerable individuals.
If the caller consents to share his/her contact information with police, the MSHRC will include this information in the police referral, and police may contact the individual for additional information. The MSHRC will not disclose identifying information about the
caller to third parties, or confirm that information shared resulted from any specific helpline call or caller, without the caller’s prior consent, except in circumstances outlined in the following section entitled ‘exceptions to caller confidentiality’. If any individual who has contacted the MSHRC wishes to remain anonymous, the MSHRC will take reasonable measures to protect the contact’s anonymity. Additionally, the MSHRC reserves the right to share selected information in a redacted form with the public authorities regarding suspected instances of modern slavery/trafficking or other crimes to facilitate crime prevention and data collection while protecting the identity of any given contact. In accordance with the MSHRC’s adoption of a ‘Do No Harm’ approach, if the MSHRC Staff have a reasonable basis to suspect that the sharing of information about any particular instance or victim of modern slavery may lead to greater harm suffered by suspected victims or any other person involved, then the MSHRC will refrain from reporting the information.
Once a case is reported to police, The MSHRC is not responsible for how this information is used.


Exceptions to caller confidentiality
As noted above, the MSHRC seeks to preserve the anonymity of any given caller in accordance with their wishes. Nevertheless, the MSHRC reserves the right to disclose Caller Contact Information, Caller ID Information, or any other information collected in connection with a given form of communication to the MSHRC to an appropriate authority or police, without the caller’s consent, where:

  1. a call references the suspected abuse or neglect of a child or vulnerable adult who remains at risk;
  2. the caller has indicated that he/she has or may harm him/herself or others;
  3. the caller is in imminent harm; or
  4. the MSHRC is required by law to disclose such information.

As appropriate, the MSHRC will attempt to notify a caller that such report has been or is likely to be made.

What information is stored from calls?
The MSHRC Helpline Advisers enter notes onto a secure database, including the details provided by the caller or gathered from an online submission through the website or app. The MSHRC does not investigate or attempt to corroborate the reports given; the information is stored according to what is reported. Information recorded may include any details shared by the caller regarding the situation and people who may potentially be involved, including minors or individuals unaware of the report to the MSRHC. Relevant information may be kept about without the respective individuals’ knowledge, for example information around a suspected perpetrator, to the extent that it is reasonable and necessary to do so, according to the Helpline’s carrying out of a public interest and to further the legitimate interests of the Helpline to end modern slavery, abuse and exploitation and facilitate safeguarding of vulnerable people. As noted above, referenced individuals will not be contacted by the Helpline unless they call themselves to provide consent.


How we keep your data safe and who has access?
We ensure that there are appropriate technical controls in place to protect your personal details. For example, our online forms are always encrypted, and our network is protected and routinely monitored. All data is retained within the EEA. We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors. Occasionally we use external companies to collect or process personal data on our behalf. We do comprehensive checks on these companies before we work with them and put a contract or confidentiality agreement in place that sets out our expectations and requirements, especially regarding how they manage the personal data they have collected or have access to.

Receiving one’s own Data
In circumstances where a victim of modern slavery or individual has contacted the helpline, he/she may request that the MSHRC provide a summary of his/her call to the victim/victim’s lawyer or to himself/herself. In circumstances where identifiable information about multiple victims is referenced in the case, information may be redacted to preserve the confidentiality of any and all victims or other individuals who have not provided consent to release their information. The MSHRC reserves the right to refuse access to information about a victim’s call if there is legitimate reason to believe access will have a negative impact on victims or callers involved in the case or where the identity of the requesting victim cannot be verified as such.
An individual may have the right to receive information that the MSHRC holds about them. If you would like to exercise these rights, then contact the MSRHC. The MSHRC will honour lawful exemptions applying to Subject Access Requests. Such requests to receive one’s one information or that information be sent to a third party, should be made in writing and submitted to the MSHRC at modernslaveryhelpline@unseenuk.org or info.mshelpline@unseenuk.org, and should include the subject’s signature, scope and date of request. If the individual wishes to have such notes released to a lawyer, adviser, or other third party, the individual must include in this request a signed statement authorizing the MSHRC to release such notes to a specified third party.

Information Retention
Data will be kept for as long as necessary to fulfil the purposes for which they were collected.

Right To Erasure
An individual about whom the MSHRC holds information may have the right to have the information about them erased. If you would like to exercise these rights, then contact the MSHRC via email to modernslaveryhelpline@unseenuk.org or info.mshelpline@unseenuk.org, or call 08000 121 700.


Right to Rectification
An individual about whom the MSHRC holds inaccurate personal data has the right to request that it be corrected. If you would like to request that information held about you be corrected or more fully completed, please contact the MSHRC via email to modernslaveryhelpline@unseenuk.org or info.mshelpline@unseenuk.org, or call 08000 121 700.

Right to portability- transferring your data
Your right to data portability allows you to obtain and re-use your personal data with other organisations. Unseen will ensure that your data is able to be moved, copied and transferred easily from one IT environment to another in a secure way. We will ensure that the information is structured, commonly used and in a machine-readable format, for example in a clearly labelled spreadsheet. Contact us via email to modernslaveryhelpline@unseenuk.org or info.mshelpline@unseenuk.org, or call 08000 121
700. to exercise your right to portability. We will respond within 28 days.Right to restrict processing- ask us to stop using your data
Individuals about whom the MSHRC holds personal data have the right to request that the use of their data be restricted or supressed. For such requests, please contact the MSHRC via email to modernslaveryhelpline@unseenuk.org or info.mshelpline@unseenuk.org, or call 08000 121 700.


Complaints process
If you wish to make a complaint, in the first instance, please contact the person or email address that you usually interact with at the Helpline. If this informal approach does not resolve your concerns, then please request a copy of Unseen’s formal Complaints Policy and Procedure via admin@unseenuk.org. This will be sent to you on the day of request. If we hear nothing further from you within 28 calendar days from this date, we will regard the complaint to be closed.
Upon receipt of Unseen’s Complaints Policy and Procedure, you should write a formal letter of complaint to the line manager of the member of staff concerned that sets out the details of your complaint, the consequences for you as a result, and the remedy you are seeking.
You can expect the complaint (stage 1) to be acknowledged within 4 working days of receipt. You should get a response and an explanation within 10 working days. Following receipt of this letter you will have 28 days in which to ask for the complaint and response to be reviewed if you are dissatisfied with the response they have received. If you are unsure which member of Unseen staff to write to, your complaint should be addressed to Unseen’s Data Controller. Our contact details are Unseen, 103 First Floor,
Deben House, 1-5 Lawrence Hill, Bristol BS5 0BY. Telephone number 0303 040 2888.Website address www.unseenuk.org.
If you are dissatisfied with the response to your complaint, then two further levels of escalation are available. Stage 2 will be dealt with by a member of the Senior Management Team and Stage 3 by the Chief Executive and the Chair of the Trustees. If you have any questions please send these to info@unseenuk.org, and for further information see the Information Commissioner’s guidance here: https://ico.org.uk/yourdata-matters/