Privacy Policy
This Privacy Policy explains how we collect and use personal data about you during and after your engagement with the My Wellbeing Hub Digital Platform (“MWH”) when used to deliver the Wellbeing for Work contract, in accordance with the Data Protection Act 2018 (“DPA”). In collecting this information and providing the services to you we are acting as a data controller.

This notice applies to all service users on this platform. This notice does not form part of any other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the DPA. We only use your personal data for the purposes outlined to provide the best service for you.

We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

Who are we?
We are Reed Wellbeing Limited (“RW”). Our address is Academy Court, 94 Chancery Lane, London, WC2A 1DT. You can contact us by post at the above address or by email at RinP.dataprotection@reed.com.
Any queries about how your personal data is being processed should be made to the RW directly by using the postal or email address listed at the beginning of this section.

What information do we collect about you?
MWH is a platform designed to help and guide you on your wellbeing journey and help you improve your physical and mental health.

The personal data that we collect directly from yourself includes:

• Identity Data includes names, title, date of birth.

• Contact Data includes email address and telephone numbers and contact details for your next of kin or emergency contact/carer.

• Clinical categories of data includes mental health information, alcohol and smoking habits.

Third Parties
Reed in Partnership Limited provide business services to RW and have access to process your data in order for Reed in Partnership to provide business services.

MEGANEXUS Limited provide digital and IT support for MWH and may have access to your personal data when they are completing updates and maintenance on the platform.

We may also share your personal data with third party service providers who assist us in carrying out our business activities. These third parties act as our data processors and are bound by strict contractual provisions to only process your personal data under our instructions and for the limited purposes we permit them. These third parties include (but are not limited to) evaluation, research and market research and analysis service providers, and all other outsourced service providers (such as communication providers) that assist us in the provision of our services.

We may also share your personal data with courts, tribunals, regulators and other governmental and public authorities (such as the police or tax authorities) to: (i) to comply with legal process, (ii) to comply with applicable law, and (iii) to respond to requests from public and governmental bodies.
We do not share your personal data with any other third parties, apart from where it is necessary to do so in order to deliver the programme as described above, and we will never sell your data. Where your data is stored (electronically or otherwise) it is held securely in the UK and will not be transferred outside the EEA.

Why do we collect this information?
We only collect this data because it is required to provide an effective and tailored service to you through MWH.
Any data which is collected by RW which is not outlined in this privacy policy is collected under the grounds of legitimate interests, as without this information, RW would be unable to provide you with the service and support you require in order to engage with the platform effectively.

In order to provide you with additional support, we may also ask for your consent to share your personal data with a network of organisations. The consent form will provide you with the ability to control the personal data you are prepared to share as well as the organisations you are prepared to share it with. You are able to withdraw your consent at any time.

What do we do with your information?
We only use your personal data to advise and support you in your wellbeing journey and for audit purposes and to track the effectiveness of our service delivery.

How long do we keep your information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once we are no longer contractually required to keep your data we will securely destroy your personal information in accordance with our Retention Policy.

Your rights over your information
By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. Under certain circumstances you have the right to request that we either delete or restrict the processing of your personal data or can request the transfer of your personal data

Requests can be submitted to Reed by email at: rinp.dataprotection@reed.com
Or by post to: Data Protection Officer, Academy Court, 94 Chancery Lane, London, WC2A 1DT

Your right to complain
If you have a complaint about our use of your information, you can contact the Information Commissioner’s Office via their website at www.ico.org.uk/concerns or write to them at:
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire,
SK9 5AF

Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

This notice was last updated on 24th March 2025.