THE WELLBEING HUB
Data Protection & Privacy Policy
Version 1.2 • Last updated: March 2026
1. PURPOSE OF THIS POLICY
The Wellbeing Hub (“the Hub”) is committed to protecting the privacy and personal data of its members, event attendees, partners, and others who interact with the Hub.
This policy explains what personal data we collect, how we use it, how we store it, and your rights in relation to that data. It reflects our commitment to transparency, care, and good data stewardship, in line with the Data Protection (Jersey) Law 2018 and any applicable successor legislation.
2. WHO WE ARE
The Wellbeing Hub operates from 19 Commercial Buildings, St Helier, Jersey JE4 8PW, and provides shared workspace and facilities for organisations and individuals working in wellbeing, mental health, and community support.
The Wellbeing Hub Ltd is a not-for-profit company registered with the Jersey Financial Services Commission, run by Khora Partners.
For the purposes of data protection law, the Hub acts as the data controller for the personal data it collects and holds.
3. WHAT DATA WE COLLECT
We only collect data that is necessary for the operation of the Hub and the management of membership and events. This may include:
- Name
- Organisation name (if applicable)
- Email address
- Telephone number
- Membership type and tier
- Billing and payment information
- Access or booking-related information
- Records of communication with the Hub (including via email, WhatsApp, and SpaceBring)
- Emergency contact details (where provided)
We do not routinely collect sensitive personal data (such as health information). If sensitive information is shared with us incidentally, it will be treated with additional care and confidentiality.
4. HOW WE USE YOUR DATA
We use personal data only for legitimate Hub-related purposes, including:
- Managing memberships and access to the Hub
- Communicating about bookings, events, closures, or operational matters
- Administering payments and invoicing
- Responding to queries or concerns
- Meeting safeguarding, safety, or legal obligations
- Improving the operation of the Hub
- We do not sell personal data or use it for unrelated marketing purposes.
5. LEGAL BASIS FOR PROCESSING
We process personal data under the Data Protection (Jersey) Law 2018 on the following bases:
- Contractual necessity: to manage your membership or use of the Hub.
- Legitimate interests: to operate the Hub safely and effectively.
- Legal obligations: where required by law, including safeguarding duties.
- Consent: where you have explicitly agreed (e.g. event communications or photography).
6. DATA STORAGE AND SECRUITY
Personal data is stored securely and accessed only by those responsible for running the Hub. This may include:
- Secure email systems
- Password-protected files or platforms (including SpaceBring, our primary membership platform)
- WhatsApp groups used for operational communications (please be aware these are subject to WhatsApp’s own privacy terms)
- Locked physical storage where applicable
We take reasonable steps to protect data against loss, misuse, unauthorised access, or disclosure. As a small organisation, we keep systems simple and proportionate, and review them as the Hub grows.
7. DATA SHARING
We do not share personal data with third parties except where:
- It is necessary for Hub operations (e.g. payment processing or platform providers)
- We are legally required to do so
- There is a safeguarding or safety concern requiring disclosure to relevant authorities
- You have given explicit consent
Any third parties we work with are expected to handle data responsibly and in compliance with applicable law.
8. DATA RETENTION
- We keep personal data only for as long as necessary:
- Membership data is retained while you are a member and for a reasonable period afterwards for administrative purposes.
- Financial records are kept in line with legal and accounting requirements under Jersey law.
- Data no longer needed is securely deleted or destroyed.
9. YOUR RIGHTS
- Under the Data Protection (Jersey) Law 2018, you have the right to:
- Request access to the personal data we hold about you
- Request correction of inaccurate or incomplete data
- Request deletion of your data where appropriate
- Withdraw consent where processing is based on consent
- Raise concerns about how your data is used
- Requests can be made by contacting the Hub using the details in Section 12 below. We will respond within a reasonable timeframe and in accordance with our legal obligations.
10. PHOTOGRAPHY AND COMMUNICATIONS
From time to time, the Hub may take photographs at events for communications or promotional purposes. We will do this sensitively, and will respect requests not to be photographed wherever reasonably possible. Photography or recording by members that includes others requires explicit consent.
We will only send communications relevant to Hub membership, operations, or events. Where communications are sent via WhatsApp or SpaceBring, these are managed by the Hub Team and subject to the same standards of relevance and respect.
11. MEMBERS' OWN DATA PROTECTION OBLIGATIONS
Members who collect or process personal data as part of their own professional practice or services are responsible for their own compliance with the Data Protection (Jersey) Law 2018.
The Hub does not act as a data processor for members’ client or organisational data. Members must:
- Keep client and personal data secure when using Hub facilities.
- Use private rooms for confidential conversations and avoid discussing client matters in open areas.
- Not leave printed or written sensitive information unattended in shared areas.
- Position screens to avoid inadvertent viewing.
- Securely store and transport client records and devices.
Any data breach arising from a member’s own practice is the responsibility of that member.
12. CHANGES TO THIS POLICY
This policy may be updated as the Hub develops, systems change, or legal requirements evolve. Any significant changes will be communicated to members. This policy is reviewed periodically alongside the Hub’s Membership Terms and Conditions.
13. CONTACT
If you have questions about this policy or how your data is handled, please contact:
Programme Co-ordinator: Kelly Eastwood (kelly@wellbeinghub.je)
Membership Co-ordinator: Tim Nash (tim@wellbeinghub.je)
General/Data Enquiries: info@wellbeinghub.je or WhatsApp +44 7700 351709
The Wellbeing Hub, 19 Commercial Buildings, St Helier, Jersey JE4 8PW
This policy should be read alongside the Wellbeing Hub Membership Terms and Conditions.