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Services Privacy Notice

This Privacy Notice is for users of all Family Action services. Services that have separate, specific Privacy Notices and the applicable Notices can be found here:

National Schools Breakfast Programme

Portsmouth Abuse and Rape Counselling Service (PARCS)

City and Hackney Neighbourhoods MDT

About Us

Family Action is a registered charity (Charity number 264713) referred to variously in this document as ‘Family Action’, ‘<Service Name>’, Us’ and ‘We’.

For the purposes of the data processing described in this statement, Family Action act as the Data Controller unless otherwise stated.

Throughout this Privacy Notice, where we refer to ‘you’, if you engage with us on behalf of your family, we are referring to both you and your family.

Commitment

If you and/or your family use a Family Action service, you can be assured that we are committed to making sure that any information we hold about you will be collected, stored and used in accordance with The Data Protection Act 2018 and General Data Protection Regulation 2016/679 (GDPR). Throughout this Privacy Notice, where we refer to ‘you’, if you engage with us on behalf of your family, we are also referring to your family.
This means that we adhere to the data protection principles of only holding information about you that is relevant to our work with you, that we make sure the information that we hold is accurate, up to date, secure, and only kept for as long as we need it.

Should you have any questions relating to this notice or our processing of personal data, please email [email protected] or contact us at the address below.

Where do we collect your information?

We may collect information about you at a number of stages in your use of our service.

Referral

You may be referred to our service by a healthcare professional, social worker or other support organisation that is providing services to you. Where they refer to us they will usually ask for your consent to do so. As part of the referral they may share with us your contact information and the reason for their referral.

If you choose not to participate the referral information will be removed, otherwise it will be added to the information we collect about you as part of providing the service to you.

Registration

When you register with a Family Action service, we may record the basic information we need in order to be able to provide the service and/or contact you. This will include your name, where you live, information about why you are using a Family Action service and the work that we are doing with you.

Data collected from you will be retained while you use our service and may be held for a number of years after you cease using the service for compliance purposes.

During your Engagement with us

Throughout your engagement with us, our service team will record information about the service provided to you, including case reporting, plans and reviews.

We collect this information so that we can keep in touch with you during the course of the work we are doing with you, to work out how best we can help you, to record the work that we have done and to assess how that work has gone. This will help us to fully understand your needs, recommend actions and improve the services that we deliver to you.

Data collected during service delivery will be maintained in your case file for a number of years after you cease using the service for compliance purposes.

When you contact our helplines

If you contact one of our helplines, the helpline team will collect information about your enquiry and the details of your call.

If necessary and with your consent, they may then refer you to another service team to resolve your request.

Calls will also be recorded for training and compliance purposes or to improve our services.

If you make a complaint

If you make a complaint about the services you have received or one of our service team, the details of the complaint will be recorded and processed to investigate and resolve the issue. Information will only be provided to members of the team with a need to know.

What Personal Information Do You Record?

The type of information (including personal information) that we collect and use and what we do with it will depend upon your relationship with us.
We collect only the personal data that we require to provide you with services, fulfil contracts or keep in touch.

The data we collect enables us to deliver services that are that are most appropriate to your needs. Should you choose not to divulge this information to us, it may affect our ability to provide the service to you.

The data that we need to collect will vary, but may include:
• Your name
• Your contact details, including email, telephone number and postal address
• Your date of birth
• The details of your family
• Reason for Referral
• Photographs (Of group sessions and events)
• Healthcare Information
• GP Name
• NI Number
• NHS Number
• Employment information, Occupation
• Social Care History
• Ethnicity information
• Disability information
• Your religion
• Sexual Orientation
• Details needed to improve your experience such as dietary requirements or accessibility needs

Special Categories of Data
Due to the nature of the services we provide, some of the data we collect is sensitive.
Information relating to Health, Ethnicity, Religion and Sexual Orientation are considered to be Special Categories of Data and we are required to take extra care when handling this information.

We may need to process this data under the following conditions:

• With your explicit consent.
• Where it is necessary in substantial public interest in:
– Preventing and detecting unlawful acts.
– Ensuring equality of opportunity and treatment
– Provision of confidential counselling or support services
– Safeguarding of children and individuals at risk.
– Safeguarding of economic wellbeing of at risk individuals
Who Will Have Access to Information About Me?
Your information will only be accessed by people who need to do so as part of their role. This could include:

• Staff working at the service that you use.
• Staff supporting the delivery of our services.
• Family Action senior managers (If there is a need to do so).
• Staff working for our partner organisations where we operate the service as part of a partnership.
• Our commissioners, on whose behalf we may be running the service you use. Commissioners will check files to make sure that we are providing you with the service that we should be.
• Regulators (such as OFSTED or CQC), who may review our work in order to ensure that we are doing a good job and keeping clear and accurate records.

We will always respect your privacy, and will seek your permission before sharing your record with any other services that you are working with.

In the following limited circumstances, we may also be obliged to share your information:
• If we believe you or somebody else could be at risk if we do not do so.
• If we are legally obliged to share your information, such as in response to a court order.

How Do We Use Your Information?

Family Action will only use your information in a fair and transparent manner and where we have a legal basis for doing so.

To Keep in Contact
In order to provide the services that you have registered for, we will need to communicate with you to arrange meetings and visits and discuss aspects of your requirements.
This communication may be via Mail, Email, Telephone or SMS.

Legal Basis: Performance of Contract

To send you newsletters and information you have requested
Where we provide an information service we will send you the requested information.

Legal Basis: Performance of Contract

To tell you about events and other services that may be of interest to you
Family Action provide a range of support and advice services throughout the UK.
If we feel that you may be interested in services for which you are not currently registered, we would like to send you this information.

Legal basis: Legitimate Interests

If we do so by email, we will ask for your consent.

Legal Basis: Consent

To provide the services you have agreed to
We will process your personal information in order to provide the services for which you have registered, this may include; providing support, information, social care or specific therapies.
We will use the information to work out how best we can help you, to provide the best possible service to you, and to record the work that we have done and to assess how that work has gone.
Legal Basis: Public Task / Legal Obligation / Legitimate Interests / Performance of Contract

To refer you for services provided by other service providers
If, in the course of our work together, we think that there may be other services that would be of benefit to you we may suggest a referral to those service providers.

We will discuss this with you and seek your consent before sharing your information with anyone else.

Legal Basis: Consent

To publicise the work that we do
Family Action would like to make people aware of the work that we do in the community, this enables us to provide services to more people. We may use anonymised case studies to tell people about our work.

Legal Basis: Legitimate Interests

To provide anonymous reports to our funders and commissioners
Many of our services are funded by other organisations, such as the local authority, government departments, the NHS or national charities. We may use anonymised data and statistics to report to them on the performance of our services.

Legal Basis: Legitimate Interests

Rights

You have the following rights with respect to the data that we hold about you.

Right To Access – I would like to see the information you hold about me
If you would like to see the information that Family Action holds about you, please email [email protected] or write to us at the below address.

We will then be able to arrange either for you to either look through your file with a member of staff, or for you to be sent a copy of the information.

Can I see all of the information that you hold about me?
In some circumstances, we may not be able to share the entire contents of your file with you. This could be if, for example, a doctor, has written to us in confidence. We would not be able to share such information with you unless the person who provided us with the information agreed to do so. We also may not be able to share information with you if we believe that it could seriously harm you to see it. In order to protect the privacy of others, we may not be able to share information about other people that appears in your file.

Right To Rectification – The information you hold about me is incorrect / I would like you to delete the information you hold about me.
We would like to ensure that all the information we hold is accurate and up-to-date.
If you believe that the information we hold about you is incorrect please first speak to a member of the service team who support you, they may be able to correct any inaccurate data.

To make a formal request to correct or make any changes to the information, or for us to delete the information we hold about you, please email [email protected] or write to us at the below address.

Each request will be dealt with on a case by case basis.

Once I’ve finished using a Family Action service, what happens to my files?
Once you’ve finished using a Family Action service, your file will be closed. We will then archive your file and keep it in accordance with our data retention policy and legal and compliance requirements. We will not keep your file for longer than it is needed. Once your file is no longer required, it will be securely disposed of. You can request access to the file at any point prior to its destruction.
In some circumstances, where Family Action are providing a service on behalf of another organisation, control over the retention and destruction of those fills will fall to that organisation and be dependent upon their own policies and procedures.

I am not happy with how my information is stored, or with what is in my file
If you are unhappy with any aspect of how your file is held, who sees it, or the contents of it, please contact [email protected] or follow the Family Action Complaints Procedure. For further information in relation to this, click here, or speak to the manager of the service you have been using. You can also complain to the Information Commissioner at: Information Commissioner, Wycliffe House, Water Lane, Wilmslow, SK9 5AF, or on 01625 545 745.

Contact with Corporate Subscribers under PECR

‘Corporate Subscribers’ are people who Family Action might contact in a professional context, using their work contact details, including phone, email and post.

These contact details may be obtained from public domain sources (company websites etc.), from our own business records or from other companies and business contacts.

Family Action may contact Corporate Subscribers under the legal basis of Legitimate Interests and as permitted under the PECR (2003) legislation.

We may contact corporate subscribers by email or telephone provided that the subscriber has not previously opted out and is not registered with the Telephone Preference Service (TPS) or its corporate equivalent (CTPS).

Direct Mail is not covered by PECR. We may contact subscribers by mail if they have not previously opted out of receiving such communications.

You have a right to object to the processing of your data for direct marketing.
We will provide opt-out notices on our communications to you, or you can advise our team at [email protected].

Family Action understands that PECR (2003) legislation will be replaced by the EU e-Privacy Regulation (ePR) in due course and reserves the right to review this privacy notice accordingly.

Changes

Family Action reserves the right to make changes to our privacy policy from time to time. Where we do so, we will publish the new policy on our website www.family-action.org.uk
and where appropriate notify you by email.

Contact

Should you wish to contact us, our registered address is:

Family Action
34 Wharf Road
London, N1 7GR

Or you can contact our data protection team on [email protected]