Carers Centre Tower Hamlets Privacy Notice
At Carers Centre Tower Hamlets (CCTH) we take the collection, storage and use of personal data (personal information) held by us very seriously. This privacy notice is to inform you about what data we need to collect and why. Also, how we use it, store it, and for how long we keep it. What we do if we need to share it and your rights as the data subject.
The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”) and the Data Protection Act 2018, along with any other applicable implementing legislation as may from time to time be in force.
Some definitions of terms used in this notice:
- Data – information held in digital formats, paper forms or file, images such as photographs and other formats by which an individual can be identified. Note this list is not extensive.
- Data subject – the person who the information is about.
- Personal data is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address).
- Sensitive data – personal information of a more sensitive nature such as equality data, health information or financial details.
- Data Controller means the person or organisation who determines the purposes for which and the manner in which any personal data is processed. In this case we, CCTH is the Data Controller.
- Data processor has the authority to use this data on behalf of the data controller for a legitimate purpose.
- Data processing – the collecting, copying, viewing, sharing, storing and deleting of data.
- Lawful basis – Data controllers must have a lawful reason for collecting and processing an individual’s information.
Who is Carers Centre Tower Hamlets?
CCTH is a registered Charity and limited company by Guarantee. We are a network partner of the Carers Trust.
We provide confidential advice, information and support to adult carers living or caring for someone living in the London Borough of Tower Hamlets.
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What personal data does Carers Centre Tower Hamlets collect and why?
There are two ways carers make contact with CCTH.
- On initial contact with carers we ask for name and contact details so that we can maintain contact and respond to any enquiries. We will set up a contact record on our secure database to hold this information while we support the carer with their enquiry. We will offer carers the option to register with us in order to access our wider support provision. See registration below.
- We receive a referral for support from another support agency. The referrer will have completed a referral form with contact details and some basic information about the care situation and what type of support is required. This information will be used to create a contact record on our secure database while we try to contact the carer to establish how we might help. We will offer carers the option to register with CCTH in order to access our wider support provision. See registration below.
Registration with CCTH
- If a carer wishes to register with CCTH, they will be asked to attend an assessment which on completion, they will sign. On this form we gather further information about the carer and relevant information about the person being cared for and preference for how we may contact the carer. We will gather personal data and sensitive data. There is an option for the carer not to answer some questions if it is felt to be too intrusive.
We will process some or all of the following data where to do so is necessary to support carers and their families who are known to us:
- Names, titles, and aliases;
- Contact details such as telephone numbers, addresses, and email addresses;
- Where they are relevant to our service, or where you provide them to us, we may process demographic information such as gender, age, date of birth, family composition, and dependants (the person you care for);
- Where you make donations, contribute to the cost of activities or make an application for a grant through CCTH financial identifiers such as bank account details or benefits information;
- sensitive personal data including: racial or ethnic origin, sexual orientation, religious affiliation, mental and physical health;
- Images such as photographs at events and activities
How do we use your personal data?
CCTH will use your personal data for some or all of the following purposes:
- To deliver support services to carers and young carers living or caring for someone living in the London Borough of Tower Hamlets.
- To administer carers registration and contact records.
- To seek your feedback by ways of annual survey to carers or when you access particular support services and activities.
- To notify you of changes to our services, events and role holders.
- To send you regular communications such as Carers Centre Tower Hamlets newsletter or information which may be of interest to you.
- To process a grant or application for financial support.
- To enable us to provide a voluntary service for the benefit of the public within London Borough of Tower Hamlets as specified in our constitution.
- To enable us to meet all legal and statutory obligations.
- To carry out comprehensive safeguarding procedures (including due diligence and complaints handling) in accordance with best safeguarding practice with the aim of ensuring that all children and adults-at-risk are provided with safe environments;
- To maintain our own accounts and records.
- To process a donation that you have made (including Gift Aid information).
How do we process your personal data?
CCTH will comply with our legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal and sensitive data.
What is the legal basis for processing your personal data?
Our legal bases for processing your personal data are:
Processing is necessary for us to be able to comply with our legal obligations to provide support services under the Care Act 2014 or such other legislation as may be in force from time to time; and/or
Processing may be necessary to protect the vital interests of an individual (for example we are legally responsible for the health and safety of staff and job applicants whilst they are on our premises and so it is necessary to process data relating to those individuals for that reason; and/or
Most of the data we hold is processed because it is necessary for our legitimate interests as a provider of an information and support service to carers and young carers, or the legitimate interests of a third party -such as another organisation providing services to carers and their dependent(s). This includes London Borough of Tower Hamlets. However, we will always take into account your interests, rights and freedoms.
To enable us to hold and process sensitive personal data as part of registration with CCTH you will be asked to give your explicit consent to the processing of such data by signing a registration form. Where we rely upon your consent to process sensitive personal data, you may withdraw your consent at any time by contacting us at the contact details set out below. Any processing that has taken place prior to your withdrawal of consent will not, however, be affected by your revocation of consent.
Please note that under GDPR children over 13 years of age may give consent, however to comply with our risk management and safeguarding policies we will still require parental/guardians consent for young carers who are 16 years old and under to access the Carers Centre Tower Hamlets – Young Carers Service in the event we undertake such a service.
Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use.
Sharing your personal data
Your personal data and sensitive personal data will be treated as strictly confidential. It will only be shared with third parties where it is necessary for the performance of our tasks or where you first give us your prior consent. In order for us to be able to provide our services to you, we may need to share your data with some or all of the following (but only where necessary) and we make sure that any party with whom we share your data will keep that data secure.
- To make direct referrals to other voluntary or statutory agencies
- To contribute to anonymised statistical reports to funder or for service analysis.
- Our agents, servants and contractors/service providers (including their sub-contractors) that provide a service to us or act as our agents, on the understanding they keep the information confidential. These include, but are not limited to, any third parties that process information on our behalf (e.g. internet service and platform providers, technical support functions and IT consultants who may assist us from time to time) or a commercial provider we use to send out newsletters on our behalf.
- Our professional advisers for our business purposes, including (but not limited to audits);
- Where required to comply with a court order or under a legal obligation.
- Illustrative reports to funders or to use to promote CCTH services (we will always seek your consent for this).
How long do we keep your personal data?
Under the GDPR an organisation must have a data retention schedule as part of their data protection policy, and not keep data longer than required. Therefore, in general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed – for example if you have not completed a registration form or are no longer registered with us. Sometimes we lose contact with carers, so will delete data if we cannot regain contact.
We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits.
We will keep some records permanently if we are legally required to do so.
Your rights and your personal data
You have the following rights with respect to your personal data:
When exercising any of the rights listed below in order to process your request, for security, we will need to verify your identity. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
- The right to access information we hold on you
- At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we obtained the information from. Once we have received your request, we will respond within 28 days.
- There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee.
- The right to correct and update the information we hold on you
- If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
- The right to have your information erased
- If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold.
- When we receive your request, we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate interests or regulatory purpose(s)).
- The right to object to processing of your data
- You have the right to request that we stop processing your data. Upon receiving the request, we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
- The right to data portability
- You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent
- You may at any time withdraw your consent for any processing of data to which consent was sought.
- You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
- The right to objectto the processing of personal data where applicable.
- The right to lodge a complaintwith the Information Commissioner’s Office.
Transfer of Data Abroad
Any electronic personal data transferred to countries or territories outside the EU will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union.
While CCTH does not transfer data outside the UK, our website is accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed from overseas.
If we wish to use your personal data for a new purpose, not covered by this Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Please contact us if you have any questions about this Privacy Notice or the information, we hold about you or to exercise all relevant rights, queries or complaints at:
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Monday - Friday – 9.30am – 5pm
Saturday and Sunday – Closed