Privacy Notice

Housing, Care and Support Services: Privacy Notice


This privacy notice explains how we collect and use your personal information and
who we share it with. Personal data is information relating to an identifiable living
individual. Whenever personal data is processed, collected, recorded, stored or
disposed of it must be done within the terms of law. Some information may be more
sensitive than others as it may relate to a person’s health, race, sexuality etc. These
are known as ‘special categories of personal data’ and are subject to higher levels of
protection under the law.

This notice:

  • applies to information about people using our housing, care and support services.
  • says why we process your personal data.
  • states the legal basis for the processing (‘processing’ includes us just storing your personal information).
  • informs you of the rights you have about the data we hold about you.

We make sure our privacy notice is kept up to date and will inform you of any
changes to this as soon as is practicable.
We will apply appropriate technical and organisational measures to ensure your
personal information is secure. For example, we have systems in place to ensure
that access to personal information is restricted to authorised individuals on a strictly
need-to-know basis.

 

Who we are

Richmond Fellowship is one of the largest voluntary sector providers of mental
health support services in England. We also provide services in the domestic
violence sector as well as personal care to a wide range of client groups. Most of our
services are commissioned under a contract by local authorities and the NHS to
meet local needs.

Our mission is to ‘make recovery a reality’. We believe that every individual should
have the opportunity to take control over their life and to develop new meanings and
purposes. We concentrate on the person and their individual needs, choices and
aspirations, rather than on diagnostic categories or labels, and tailor what we do
accordingly.

Richmond Fellowship is the data processor for the majority of the services we
provide and a data controller for people who are tenants/licencees of Richmond
Fellowship.

We are registered with the Information Commissioners Office (ICO) which is the UK
regulator for data protection: Richmond Fellowship ICO Number: Z5557991
Richmond Fellowship is part of the Recovery Focus group but each legal company
responsible for its own ICO registration, so this notice covers only users of Richmond
Fellowship services


If you would like to find out more about how we use your personal information, you
can request further information from your service or by contacting:
The Data Protection Officer
Richmond Fellowship
Registered Office
80 Holloway Road
London
N7 8JG

Email: DataProtectionOfficer@Richmondfellowship.org.uk


We will only collect personal information when we need this. The type of information
we need from you will vary depending on our relationship with you. When we ask
you for information, we will make it clear why we need it.
How we collect your information

We collect most of our information directly from you, including when you use one of
our services, complete one of our forms, when you write, phone, email or meet with
us. We also collect information from other third parties where is it relevant to the
service we are providing to you.

This includes:

  • Local authorities, health and social care professionals, previous care providers
  • Other housing, care and support service providers, and referral agencies where we are working in partnership with them
  • Your family, next of kin and support network when it is directly related to your care and support
  • Any other statutory agencies involved in your care and support where relevant

 

How we use your personal information

  1. To assess your care and support needs, determine your eligibility for a service, enter into a contract with you and to provide you with personalised care and support.
    As a provider of housing, care and support services, we need information about your health, housing, support and/or social care needs to deliver our services and to meet your assessed needs. We need this information to assess your eligibility for a service and offer you housing or other support service. We use this information to develop a support plan and review your progress at regular intervals.
  2. To keep individuals safe and make sure no one is at risk of harm.
    We have a legal duty to do what we can to keep people safe – this includes you, our staff, as well as others that may be involved in supporting you. We use this information to agree a safety and protection plan or other emergency responses with you if this is necessary. We may also process information about:

     Risk history
     Incidents and accidents
     Housing history
     Substance use
     Criminal history and convictions
     Any legal restrictions, or court orders relevant to providing you with a service

  3. We may capture your image on our CCTV systems if you visit an office or it is
    installed in a housing service.
    When you provide information about household members we assume that you do so
    with their full knowledge and consent. We may record this, including information
    about your children, if it is significant or related to your wellbeing, in your case file
    though we do not routinely collect this information.

  4. To contact and communicate with you
    We use your contact details (including telephone numbers and email addresses) to
    get in touch with you about issues relating to the service we have agreed to provide
    you. We will not share your contact details except with your consent or where it is
    necessary to provide a service to you. We do not sell, share or provide contact
    details for marketing or other purposes.
    We may pass your details on to our contractors that provide services on our behalf,
    so that they can contact you. For example, some services have emergency out of
    hours support from another provider or where a repairs contractor may need
    information to carry out a repair to one of our properties. Where this is the case they
    will have to demonstrate that they can keep your information safe and secure.

  5. To monitor equality, diversity and inclusion
    We ask you to provide us with your diversity data (ethnicity, religion, sexual
    orientation). This information is not used to inform any decisions we make about you
    individually, but is gathered for statistical purposes to help us understand who is
    using our services. It helps us ensure fairness and equality in the services we
    provide. You do not have to provide this information but it helps us if you choose to
    do so.
    What legal basis do we rely on to process your data
    The law requires us to tell you the basis on which we process your data.

  6. To provide health and social care services: We process your information so
    that we can provide the service we have been commissioned to provide.

  7. For the performance of a contract: Some of our processing is carried out to
    fulfil a contract or an agreement we have with you. Where we require information
    because it is necessary in the performance of a contract you will not be able to
    opt out of providing this information. This is because without it we would be
    unable to do what you have asked us to do. We consider a contract to include a
    tenancy or licence agreement, care and/or support contract/agreement signed by
    you or where you purchase care and support directly from us.

  8. To fulfil our legal and regulatory obligations (substantial public interest):
    Some of our processing is carried out to ensure we fulfil our legal and regulatory
    obligations in providing housing, care and support services, for example under
    the:
     Charities Acts
     Housing and Regeneration Act 2008
     Care Act 2014
     Health and Social Care Act 2008 (regulated activities) Regulations 2014
     Mental Capacity Act 2005
     Mental Health Act 1983
     Health & Safety Legislation

  9. Consent: In some instances, we may ask for your consent to process your
    information where there is no other legal basis to do so. This applies to special
    categories of data such as your health information.

  10. Where it is necessary for our legitimate interests: In all other cases, we rely
    on a condition called “legitimate interests”. The law allows us to process your
    data if it is in our legitimate interests to do so. But we can only do this if:
     it does not disproportionately affect your rights
     it doesn’t cause you any harm
     it isn’t overly intrusive

    The law also says we must let you know what we consider our legitimate
    interests to be, in holding relevant personal data in relation to your housing, care
    and support.

    Our legitimate interests are to ensure that:
    • we are meeting our objectives as a charity of ‘making recovery a reality’
    • our services can meet peoples’ needs now and in the future
    • our services are accessible
    • we make the most efficient use of our resources
    • we understand how we are performing;
    • we provide a safe service
    • we understand people’s experiences and views so we can make our
    services better

    If you believe that you are adversely affected by us processing your data for our
    ‘legitimate interests’ you may ask us to stop processing it. This may not always be
    possible though we will explain why, if this is the case.


    Sharing your personal information

    If we are working with other organisations or services to support you, we may have
    to share information with them. We only do this if we have a good reason to and it is
    necessary for delivering the agreed support.

    Where we are providing care and support services as part of a local authority
    contract, we may share your information with the commissioning local authority or
    NHS health trust.

    Sometimes we might have to share information with authorities if we think that you or
    someone else is at serious risk of abuse or harm. We don’t need your consent to do
    this.

    We may also share some information with other organisations that carry out a
    service on our behalf. We only share information which is necessary for them to
    carry out the service they have been contracted to provide. All our contractors
    operate under the terms and conditions of a legally enforceable contract and will not
    use your information for anything other than carrying out a service on behalf of
    Richmond Fellowship.

    Other organisations we may share your information with include:
     Government departments such as the Benefits Agency
     Police and other law enforcement agencies
     Representatives acting on your behalf
     Care Quality Commission


    Keeping your personal information

    How long we keep your personal data for can depend on the type of data it is. We
    will never keep your information for any longer than is necessary for the purposes we
    need to use it for. In most cases we keep records for 6 years after the date of the last
    contact you have had with one of our services.


    Your data and privacy rights

    You have several rights which allow you to choose and control how we use your
    data. These rights are explained below. If you would like to use these rights, please
    ask your service and they will explain how you can do this.

    Transparency: You have the right to be informed about how we are using your data.
    If you think we are doing something with your information that we have not told you
    about in this Privacy Notice, you can object to this.

    Access: You have the right to ask us what personal information we hold about you,
    and to request a copy, free of charge.

    Objection: You can object to the processing of your personal data. You should note
    that this right does not apply in all circumstances, for example, where we are
    processing information because it is necessary in the performance of contract we will
    not be able to stop processing this information.

    Withdrawal of consent: if we are processing your data based on your consent, you
    can withdraw this consent at any time. Where this is the case we may no longer be
    able to provide the relevant service to you.

    Rectification: If you think that the personal data we hold about you is inaccurate or
    incomplete, you have a right to request that it be rectified.
    Erasure: You can ask us to delete your personal data where it is no longer
    necessary for us to use it, where you have withdrawn consent (if we process based
    on consent), or where we have no lawful basis for keeping it.

    Restriction: You can ask us to restrict the personal data we use about you where
    you have asked for it to be erased or where you have objected to our use of it.
    Data portability: You can ask us to provide you, or a third party (if possible), with
    some of the personal data we hold about you in a structured, commonly used,
    electronic form, so that it can be easily transferred.

    Concerns and Complaints: If you are not satisfied with the way that we have
    managed your personal data, please let us know and we will try and resolve your
    concerns. Please contact your service in the first instance, or the person who is
    dealing with the issue. If you are not satisfied with the outcome, you can make a
    formal complaint by using out Feedback Policy.

    If you are still not happy with our response, you have the right to appeal directly to
    the regulator:
    Information Commissioner’s Office
    Wycliffe House
    Water Lane
    Wilmslow
    Cheshire
    SK9 5AF
    Visit: https://ico.org.uk or telephone: 0303 123 1113