Who we are.
Why we collect your information, and how we will use the information that you give us.
Changes Health & Wellbeing will take all reasonable steps to keep your information safe and secure.
To process your information we must have a legal basis. For most of the information that we process, this is based on what is known as a ‘legitimate interest’. We only ask for the bare minimum of information that we have identified that we need to carry out our role as a charitable company and mental health service provider, and to balance our duties towards you, our own requirements, and those who commission our services, (Clinical Commissioning Groups and Local Authorities) without whom we could not operate. Please see below for more details on how your information is used by us.
Some of the information that we ask you for is known as ‘special category data’. To process this we need to provide an additional reason on top of the legal basis above. We have identified the following reason from the General Data Protection Regulations, Article 9(2)(d)
‘…processing is carried out in the course of its legitimate activities with appropriate safeguards by a foundation, association or any other not-for-profit body with a political, philosophical, religious or trade union aim and on condition that the processing relates solely to the members or to former members of the body or to persons who have regular contact with it in connection with its purposes and that the personal data are not disclosed outside that body without the consent of the data subjects’
The information that we ask you for that falls under special category data are: your ethnic origin / ethnicity; information about your health; and information about your sexual orientation.
By processing information relating to ethnicity and sexual orientation, we are able to see who is accessing our services, and to ensure that we are reaching often under-represented groups within the community.
The health information that you give us, though basic, would still fall under ‘special category data’. Certain aspects, such as what mental health condition you have, or physical ailments, will again allow us to see what parts of the community we are reaching and that we are providing a diverse service. Other data, such as that collected through regular monitoring, such as GAD7 forms and PHQ9 forms, are used to help you to see how you are progressing, and also for us to be able to evaluate how our services are performing.
All information that we process that falls under ‘special category data’ will never be shared without your explicit consent. We may, though, use this information for anonymous statistical purposes. This could be internal reporting, or as part of a report to commissioners. For example, we would be able to state that 45 people identifying as White British attended our Stoke-on-Trent service in March 2018– there would be no identifiable information attached to this figure.
Other information that you give us will be used for different purposes.
Your name, address, telephone number and email address will be used to keep in touch with you, for example to inform you that a venue that you are due to attend, or regularly attend, is closed so that you do not unnecessarily travel. If you do not provide us with this information, or it is out of date, we cannot let you know of any changes. These details will also enable us to create an individual ‘file’ for you, keeping your information secure and separate from that of other persons. We will also be able to use the first parts of your postcode to see which geographical areas are well served by our services, and which areas are not. For example, our postcode is ST4 4AL – we would only make use of ST4 4 for this purpose.
We will never sell your information.
We will not use your information for marketing, unless we ask for your express permission to do so.
Your personal data will not be shared with other organisations or individuals outside of Changes Health & Wellbeing’s services without your express permission, when we will explain the reason for passing on your information and what information it is we are passing on.
There are exceptions to this, however. These include:
> a serious concern about your safety or the safety of another person. In these circumstances we may need to organise a ‘welfare check’, which will often mean passing on your name, address, telephone number and the nature of our concerns to the police in order for them to carry out the welfare check.
> Protection of children, young people, and vulnerable adults – in these circumstances we are obliged to report our concerns to the local Safeguarding Team. This will involve providing them with your name, address telephone number and any information which we hold to enable the Safeguarding Team to carry out their due-diligence.
How we collect your information.
In most cases, your information will be collected via forms that you complete in sessions or groups provided by Changes Health & Wellbeing. In some circumstances, we may have received your information from a 3rd party, such as a partner organisation that has made a referral to us on your behalf. The same retention and security applies to this information as if we have collected it ourselves.
How long will we keep your information?
We will usually keep your information for up to 7 years after you have stopped using our service. After this date, we will either fully anonymise your records, permanently delete your records, or a combination of the two.
How we will store your information?
Most of the information that we collect is originally in a paper format. Once it has been returned to the office, we enter the information into a secure and encrypted system called Charitylog. Only relevant members of staff will have access to the system, meaning that the number of people with access to your information within Changes is strictly controlled and limited. The paper information is kept in locked filing cabinets for up to two years for the purpose of data quality and data audits; once this time period has elapsed, the paper documents are securely shredded and disposed of.
How to request a copy of your information.
If you would like to see a copy of the information that we hold about you, please send an email to email@example.com, or write to our registered Head Office – Data Protection, Changes Health & Wellbeing, Victoria Court, Booth Street, Stoke, Stoke-on-Trent, ST4 4AL. We will send you a copy of your information as soon as possible, but within one month of receiving your request. We may need contact you about the information if we need any more details; for example, we may need to request a proof of identification.
There is no cost to you in requesting to see a copy of your information.
Any questions or concerns.
If you have any questions or concerns about how we use your information, please contact us via email to firstname.lastname@example.org or write to us at our registered Head Office – Data Protection, Changes Health & Wellbeing, Victoria Court, Booth Street, Stoke, Stoke-on-Trent, ST4 4AL. Alternatively, contact Kris Kinsella on 01782 411433. You may request a copy of our more detailed Data Protection Policy by the same methods of contact too.
If you are unhappy with how we deal with any of your requests, or have concerns over how we handle your data, you may complain to the Information Commissioner’s Office at any time https://ico.org.uk/concerns/handling/
Privacy Notice Dated 18th May 2018.
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