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.
- 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
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
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
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
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
80 Holloway Road
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.
- 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
- 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.
- 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:
Incidents and accidents
Criminal history and convictions
Any legal restrictions, or court orders relevant to providing you with a service
- 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.
- 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.
- 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
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.
- To provide health and social care services: We process your information so
that we can provide the service we have been commissioned to provide.
- 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.
- 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
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
- 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.
- 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
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
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 informationIf 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
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
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 informationHow 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 rightsYou 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
Information Commissioner’s Office
Visit: https://ico.org.uk or telephone: 0303 123 1113