As part of the services we offer, we are required to process personal data our service users. “Processing” can mean collecting, recording, organising, storing, sharing or destroying data.
We are committed to being transparent about why we need your personal data and what we do with it. This information is set out in this privacy notice. It also explains your rights when it comes to your data.
Collecting your information
At the referral stage, we will use information provided to us in order to assess the suitability of our service for you and to understand your support needs. The information is provided to us:
- on a referral form
- on other information in forms provided with the referral form;
- during a visit to us and an assessment meeting with us;
- by telephone; and
- by relevant professionals involved in the referral process as well as your electronic and written communications.
If you become a user of our services, we will use your personal information to provide you with support services in relation to your support planning and provision; and risk assessment and management planning. This information is the information provided during the application stage and any information provided by you, relevant professionals or others such as family, friends or carers during on-going:
- face-to-face meetings and interactions;
- telephone calls; and
- electronic and written communications.
Information That We Collect
During the referral stage for our services, we will collect the following information:
- your name, date of birth and personal contact details;
- your National Insurance number;
- your language preferences and communication needs;
- the gender you identify as;
- the ethnicity you describe yourself as belonging to;
- your religious beliefs;
- if anyone acts on your behalf and you whether you have mental capacity e.g. to sign a tenancy
- your financial circumstances;
- any cautions or unspent convictions you may have and any other details relating to risks to yourself or others
- your housing history and any arrears or debts you may owe or recent anti-social behaviour;
- information about your family, including your marital status, whether you have any children or whether you are pregnant;
- information in relation to your mental and physical health; and
- relevant information about your personal life and any care or support requirements you may have.
If you become a user of our services, we will use the information provided during the referral process to provide you with our services. We will also collect the following information to provide you with our support and risk management planning services:
- contact details of next of kin, relatives and people you nominate;
- images of you to help us to support you to stay safe e.g. if we need to notify police that you are a missing person;
- information relating to your support requirements, including progress against your support planning goals;
- information relating to your well-being, physical and mental health;
- details of your contact and interactions with us face to face, by telephone and in electronic and written communications;
- information provided by third parties that is relevant to your support or risk management
- records about any repairs, maintenance or adaptation requirements you have with the relevant landlord
There is CCTV in operation at some locations where we are based. Where there is CCTV in operation, there will be clearly visible signs to indicate that this type of recording is happening. CCTV is only used in communal areas.
What We Do With Your Information
Information about you is stored and used by us in accordance with this privacy notice and with your rights under the GDPR.
During the referral stage, the information provided to us will be used for assessing the suitability of our services for you and understanding your support requirements and to ensure that our services are fair and accessible to all.
If you become a user of our services, the information provided to us will be used to support you with your goals and to provide you with support services and to understand your personal situation and individual requirements, so we can provide a person-centred service that meets any cultural, financial, learning, mental or physical needs that you may have. It will also be used to improve the services you receive from us.
The Legal Basis For Using Your Information
By law, we need to have a lawful basis for processing your personal data.
Julian Support processes your information under the legal basis of GDPR Article 6(1)(e) “for the performance of a task carried out in the public interest or in the exercise of official authority”. We would be unable to offer support services in line with how we are commissioned if we did not collect the relevant information about you. This is because the information Julian Support processes would need to be shared with the official authorities which are vested in Julian Support. More information can be seen below under our Commissioners and Partner Agencies.
Julian Support may on occasions need to consider the ethical principals in relation to your confidentiality and information sharing. Julian Support will aim to strike a balance between maintaining your confidentiality and privacy against wider considerations in terms of protecting an individual from harm. Where it is in the vital interests of the individual, the processing of data may be necessary in order to protect the vital interests of the data subject or of another natural person. In these instances your data maybe shared lawfully under GDPR Article 6(d) because it will be in your vital interests.
Where the information we process is special category data, for example your health data, the additional basis for processing that we rely on is:
- Article 9(2)(h) for the provision of health or social care or treatment or the management of health or social care systems.
We may also process your data with your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent.
Sharing Your Information
Commissioners and Partner Agencies
We are contractually required to share your information with those who commission our services and with other organisations where we have a legal obligation to share the information with them. Services we provide are contracted by;
Suffolk County Council – (The Mental Health and Learning Disability Commissioning Team) and by Norfolk and Suffolk Foundation Trust (NSFT), obliging us to share information with both organisations to fulfil our contract to provide services. Those who commission our services have responsibility for specifying the level of data minimisation applied to providing them with information on how we deliver the contract. Information relevant to your accommodation tenure is shared with housing providers (Registered Social Landlords), with which we have Service Level Agreements for Supported Housing Services. Julian Support and joint controllers such as Suffolk County Council and/or NSFT may share information when it is in the best interests of the data subject and when failure to share data may carry risks to vulnerable groups and individuals.
We may share your information with other organisations such as:
The police for the purpose of crime detection and prevention and managing risk. Organisations with a function of auditing/administering public funds in relation to detection and prevention of fraud.
Local authority teams such as adult community services, housing, safeguarding, environmental health, council tax departments and benefit agencies. We may also share information with other statutory agencies such as the fire service, ambulance service and the NHS in relevant circumstances.
Family, Friends and Carers
We will ask for your specific consent for sharing any information with your family, friends or carers and regularly review this.
Transferring Your Information Abroad
We will not transfer any information about you outside of the European Economic Area.
Security Of Your Information
Information that you provide will be stored securely in all formats and is not accessible to any staff that do not have relevant reasons to access this. Any breach of this policy will be recorded on a breach register and the Information Commissioners Office will be notified when appropriate.
Storing Your Information And Deleting It
We will hold your information securely during the period of our relationship and in line with contractual requirements of the commissioning bodies. If our contract terminates your data will be returned/destroyed/disposed of in a secure manner and in accordance with specific instructions by our commissioners.
At the referral stage, if you do not become a user of our services we will destroy all information about you within 3 months of the most recent relevant contact.
If you become a user of our services, we will hold the information collected at the referral stage and while you are a service user during the period of our relationship and in line with commissioning bodies requirements.
Under data protecton law, you have rights we need to make you aware of. Your rights under the GDPR allow you to:
- Ask us for access to the information we hold on you. There are some exceptions to this right, which means you may not always receive all the information we process.
- Ask us to correct the information if it is inaccurate or incomplete.
- Ask us to erase the information that is held by us, although in certain circumstances we may not be able to do this.
- Ask us to provide you with the information we hold about you in a structured and commonly used format or transmit that information directly to another.
- Ask us to restrict the processing of your personal data in certain circumstances.
- Object to the processing of your information if the process forms part of our public task, or is in our legitimate interests. However, we may not be able to provide you with a service should you choose to object to the processing of your data.
More information on the rights of the individual under GDPR are available from the Information Commissioners Office website, www.ico.org
If you wish to make any requests or want any further clarity about GDPR within Julian Support, you can contact our Data Protection Champion by writing to The Data Protection Champion, 23 Pilling Park Road, NR1 4PA or emailing firstname.lastname@example.org
You also have the right to complain to the Information Commissioner's Office (the "ICO") if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.