Please note, if you would like to discuss this Privacy Notice in person or would like it made available in a different format, please contact us on 0115 8370693 or email firstname.lastname@example.org
Space Inclusive Ltd is an East Midlands based day service for adults with learning disabilities. We collect, store and process certain personal information about our clients, their carers, our staff and our volunteers. We are therefore registered as a data controller with the Information Commissioner’s Office (ICO) and our registration number is ZA334486.
We respect your right to privacy. This privacy notice explains what information we record, why we do this, what we do with the information and how we keep it safe in accordance with the General Data Protection Regulation (GDPR). It also explains your rights and how you can help us to make sure your information is kept up to date and accurate.
In this Privacy Notice all references to “we” or “us” or “our” relate to Space Inclusive Ltd, a company incorporated in England and Wales (Company No. 11001317), whose registered office is 20 Pelham Road, Nottingham, NG5 1AP. Space Inclusive Ltd is the controller of any personal information processed as set out in this Privacy Notice.
In this document we will explain the following:
- what information we collect
- our legal basis for collecting the information
- why we collect the information and how we use it
- how we store the information
- who we might share your information with and why
- how long we will keep your information
- your rights
- how to make sure your information is accurate
What information do we collect?
We collect information on our clients, staff, volunteers, general enquirers, job applicants and visitors to our website. We might also collect information on relatives or carers of clients, staff and volunteers so that we can contact them in an emergency.
We hold basic information about you such as your name, address, telephone number, email address, date of birth, gender, next of kin and GP. We may also hold more sensitive information such as:
- Medical and health details
- Disability details
- Client Care Plans
- Relevant information from health and social care professionals
- Education details
- Ethnicity – to help plan activities and ensure equal access
- Safeguarding reports
- Incident reports
- Protection Plans
We also store photographs of clients to enable identification for safeguarding purposes. Any other images and videos will only be held and used with prior consent.
What is our legal basis for collecting this information?
The legal bases for us collecting and processing your information is that:
- it is necessary to fulfil the contract between you and us or the steps you and/or your carer/representative have asked us to take towards entering into a contract
- it is necessary to meet legislation and contractual obligations arising from placements commissioned by Health and Social care services
Why do we collect this information and what do we do with it?
We collect this information so that we can:
- provide you with the best possible service
- enable you to work in partnership with us to meet your individual needs
- ensure the safety of everyone who uses and has contact with our service
- work effectively with others providing you with support and care
- contact and communicate with you regarding our service activities
- update you on service developments
- discuss and investigate any issues, concerns, complaints or legal claims
- review the service we are providing
- process financial transactions such as client fees and staff salaries
We may keep a record of any communications we have with you such as emails or telephone calls.
How do we store the information?
We hold your records securely in both paper and electronic format.
We have a duty to:
- Keep and maintain accurate and up to date records of the support we provide to our service users
- Keep and maintain accurate and up to date staff records
- Keep your information confidential and secure
We, or third parties acting on our behalf, may also store or process information that we collect about you in countries outside the European Economic Area, which may have lower standards of data protection. Specifically, servers used by our website are located in the United States and some of our third party service providers operate around the world. We have technical and organisational security measures in place to prevent the loss or unauthorised access of your personal information, however, please be aware that we cannot guarantee the security of information transmitted over the Internet.
Who might we share your information with and why?
We will share your information with third party organisations who are contracted to provide services to Space Inclusive Ltd. This will only be the case in order to meet our contractual obligations to you, to meet statutory requirements or to support the care needs of our clients such as:
- Local authorities and NHS – health and social care professionals
- Supply Staff Agencies – to enable their staff to support you safely and effectively
- IT provider responsible for maintaining IT systems and security
- Accountants – in order to process payroll
- Workplace Pension provider – staff pension scheme
- Website provider
- Insurance companies
We may also share your information where we believe there is a legal or regulatory reason for us to do so such as:
- to report safeguarding concerns or incidents
- to respond to any legal claims
- to comply with any relevant law or legal process
We will not sell your information to other organisations or share your personal information with other organisations for the purposes of marketing or fundraising.
How long we will keep your information?
We will keep your records for no longer than is reasonably necessary and in line with our records retention policy as follows:
Client records – 8 years from date service ended
Client records where no contract is entered into – 6 months from date of enquiry or referral
Employee pension details – 75 years post-employment
Employee records – 6 years post-employment
Recruitment (successful applicants) – 6 years post-employment
Recruitment (unsuccessful applicants) – 6 months post recruitment campaign
Finance records – 7 years
You have the right:
- to be informed
- to access your information
- to have inaccurate or incomplete information corrected
- to erasure – to have your information removed or deleted
- to restrict the processing of your information
- to data portability – to obtain and move your personal information
- to complain
Your right to be informed
You have the right to be informed about the information we keep and how we use it. That is why we have written this privacy notice. We may need to make changes to our Privacy Notice from time to time but the most up to date version will always be available on our website www.spaceinclusive.co.uk If we make any major changes to it we will post a notice on our website or let you know in writing.
Your right to access your information
You have the right to confirm we are processing your personal information and to access your personal information. You can do so by contacting us:
David Bingham / Richard Mynett / Claire Smith
Data Protection Officers
Space Inclusive Ltd
20 Pelham Road
Tel: 0115 8370693
Requests for access to information will be responded to as soon as is reasonably possible and no later than within one month in line with the GDPR.
Your right to have inaccurate or incomplete information corrected
If you think the personal information we have for you is not correct, you can contact us to ask that we put right any inaccurate or incomplete data. We will respond within one month.
Your right to erasure
You have the right to ask us to erase, or delete, your personal information or to restrict the processing of your data. Each request will be considered on an individual basis and in line with the GDPR. If we agree to your request to erase or delete your personal information, we will no longer be able to fulfil our contract with you.
Your right to restrict processing
You have the right to ask us to stop processing your information. Each request will be considered on an individual basis and in line with the GDPR. If your request is upheld we would continue to store your information but would not do anything with it. This restriction in processing your information could be temporary or permanent depending on the request.
Your right to data portability
This means you have the right to ask us to send you the information you have given to us so that you can pass it on to other organisations so that they can use the information. You may ask us to send the information straight to another organisation. If your personal information also contains information about other people we will need to consider whether sending the information would affect their rights. We will respond to all requests as soon as possible and within no more than one month, unless the request is complex, in line with the GDPR.
Your right to complain
If you are not happy with the way in which we are handling your personal information you can contact our Data Protection Officers at the address above or telephone 0115 8370693.
If you are not satisfied with the way we have dealt with your complaint you can contact the Information Commissioner’s Office (ICO):
Cheshire, SK9 5AF
Helpline: 0303 123 1113
How you can help us to make sure your information is accurate
It’s important that you let us know if any of your personal details change, for example if you change address, telephone number, email address, GP etc. In order to keep accurate records we need to know of any changes. We will then inform anyone with whom we have shared your information so they can update their records.
This privacy notice was last updated on 30th April 2018
Some of the information contained within this document was obtained from the Information Commissioner’s Office Guide to the General Data Protection Regulation (GDPR) web pages https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/
This document contains public sector information licensed under the Open Government Licence v3.0