Agape Wellbeing privacy policy

Your privacy

Agape Wellbeing is committed to protecting your privacy when you use our services.

The Privacy Notice below explains how we use information about you and how we protect your privacy.

We have a Data Protection Officer who makes sure we respect your rights and follow the law.  If you have any concerns or questions about how we look after your personal information, please contact the Data Protection Officer by phone on 01355 708701 or by email:  info@agapewellbeing.com

Do you know what personal information is?

Personal information can be anything that identifies and relates to a living person. This can include information that when put together with other information can then identify a person.  For example, this could be your name and contact details.

Did you know that some of your personal information might be ‘special’?

Some information is ‘special’ and needs more protection due to its sensitivity.  It’s often information you would not want widely known and is very personal to you.  This is likely to include anything that can reveal your:

• sexuality and sexual health
• religious or philosophical beliefs
• ethnicity
• Physical or mental health
• trade union membership
• political opinion
• genetic/biometric data
• criminal history

Why do we need your personal information?

We may need to use some information about you to:

• deliver services and support to you;
• manage those services we provide to you;
• train and manage the employment of our workers who deliver those services;
• check the quality of services; and
• to help with research and planning of new services

How the law allows us to use your personal information

There are a number of legal reasons why we need to collect and use your personal information.

• You, or your legal representative, have given consent
• You have entered into a contract with us
• It is necessary to perform our statutory duties
• It is necessary to protect someone in an emergency
• It is required by law
• It is necessary for employment purposes
• It is necessary to deliver health or social care services
• You have made your information publicly available
• It is necessary for legal cases
• It is to the benefit of society as a whole
• It is necessary to protect public health
• It is necessary for archiving, research, or statistical purposes

If we have consent to use your personal information, you have the right to remove it at any time.  if you want to remove your consent, please contact the DPO at Agape Wellbeing by phone on 01355 708701 or by email at info@agapewellbeing.com

We only use what we need!

Where we can, we will only collect and use personal information if we need it to deliver a service or meet a requirement.

If we do not need personal information we will either keep you anonymous if we already have it for something else, or we won’t ask you for it.

If we use your personal information for research and analysis, we will always keep you anonymous or use a different name unless you have agreed that your personal information can be used for that research.

We do not sell your personal information to anyone else.

What you can do with your information

The law gives you a number of rights to control what personal information is used by us and how it is used by us.

You can ask for access to the information we hold on you.

We would normally expect to share what we record about you with you whenever we assess your needs or provide you with services.

However, you also have the right to ask for all the information we have about you and the services you receive from us. When we receive a request from you in writing, we must give you access to everything we have recorded about you.

However, we cannot let you see any parts of your record which contain:

• confidential information about other people; or
• data a professional thinks will cause serious harm to your or someone else’s physical or mental wellbeing; or
• if we think that giving you the information may stop us from preventing or detecting a crime

This applies to personal information that is in both paper and electronic records.  If you ask us, we will also let others see your record, except if one of the points above applies.

If you cannot ask for your records in writing, we will make sure there are other ways that you can.  If you have any queries about access to your information, please contact the DPO on 01355 708701

You can ask to change information you think is inaccurate

You should let us know if you disagree with something written on your file.

We may not always be able to change or remove that information but we will correct factual inaccuracies and may include your comments in the record to show that you disagree with it.

Please let us know if you wish to inform us of any inaccuracies.

You can ask to delete information (right to be forgotten)

In some circumstances you can ask for your personal information to be deleted, for example:

• Where your personal information is no longer needed for the reason it was collected in the first place
• Where you have removed your consent for use to use your information (where there is no other legal reason for us to use it)
• Where there is no legal reason for the use of your information
• Where deleting the information is a legal requirement
• Where your personal information has been shared with others, we will do what we can to make sure those using your personal information comply with your request for erasure.

Please note that we cannot delete your information where:

• we are required to have it by law
• it is used for freedom of expression
• it is used for public health purposes
• it is for scientific or historical research, or statistical purposes where it would make information unusable
• it is necessary for legal claims

You can ask to limit what we use your personal data for

You have the right to ask us to restrict what we use your personal information for:

• Where you have identified inaccurate information and have told us of it
• Where we have no legal reason to use that information but you want us to restrict what we use it for rather than erase the information altogether
• Where information is restricted it cannot be used other than to securely store the data and with your consent to handle legal claims and protect other, or where it’s for important public interests of the UK
• Where restriction of use has been granted we will inform you before we carry on using your personal information.

You have the right to ask us to stop using your personal information for any service we provide, however if this request is approved this may cause delays or prevent us from delivering that service.

Where possible we will seek to comply with your request, but we may need to hold or use information because we are required to by law.

You can ask to have your information moved to another provider (data portability)

You have the right to ask for your personal information to be given back to you or another given to another service provider of your choice in a commonly used format.  This is called data portability.  However, this only applies if we are using your personal information with consent, not if we are required to by law.  It is likely that data portability will not apply to most of the services you receive from Agape Wellbeing.

You also have the right to object if you are being ‘profiled’.  Profiling is where decisions are made about you based on certain things in your personal information, e.g. your health conditions.  It is likely that profiling will not apply to services you receive from Agape Wellbeing.

If and when Agape Wellbeing uses your personal information to profile you in order to deliver the most appropriate services to you, you will be informed.

If you have concerns regarding profiling, please contact the Data Protection Officer who will be able to advise you about how we are using your information.

Who do we share your information with?

We use other organisations to help delivery our services to you.  Where we have these arrangements there is always an agreement in place to make sure that the organisation complies with data protection law.

We will often complete a privacy impact assessment (PIA) before we share personal information to make sure we protect your privacy and comply with the law.

Sometimes we have a legal duty to provide personal information to other organisations.  This is often because we need to give that data to courts, including:

• if the court orders that we provide the information; or
• if someone is taken into care under mental health law

We may also share your personal information when we feel there’s a good reason that’s more important than protecting your privacy. This doesn’t happen often, but we may share your information:

• in order to find and stop crime fraud or if there are serious risks to the public, our staff or to other professionals; or
• to protect a child; or
• to protect adults who are thought to be at risk, for example if they are frail, confused or cannot understand what is happening to them

For all of these reasons the risk must be serious before we can override your right to privacy.

If we’re worried about your physical safety, or feel we need to take action to protect you from being harmed in other ways, we’ll discuss this with you and, if possible, get your permission to tell others about your situation before doing so.

We may still share your information if we believe the risk to others is serious enough to do so.

There may also be rare occasions when the risk to others is so great that we need to share information straight away.  If this is the case, we’ll make sure that we record what information we share and other reasons for doing so.  We’ll let you know what we’ve done and why if we think it is safe to do so.

How do we protect your information?

We’ll do what we can to make sure we hold records about you, both on paper and electronically, in a secure way, and we’ll only make them available to those who have a right to see them.  Examples of our security include:

• Controlling access to systems and network allows us to stop people who are not allowed to view your personal information from getting access to it
• Training our staff to allow us to make them away of how to handle information and how and when to report when something goes wrong
• Regular testing of our technology and ways of working, including keeping systems up-to-date with the latest security updates (commonly called patches)

Where in the world is your information?

All of your personal information is stored on systems in the UK.

How long do we keep your personal information?

We will only retain your personal information for as long as necessary to fulfil the purposes we are collecting it for. This may include to provide you with a service or services that Agape Wellbeing provide, legal requirement, financial, regulatory or reporting requirements. To determine the appropriate retention period for persona data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Once you are no longer an employee, of the organisation, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

Where can I get advice?

If you have any concerns or questions about how your personal information is handled, please contact our Data Protection Officer at 01355 708701 or by email at info@agapewellbeing.com

For independent advice about data protection, privacy and data sharing issues, you can contact the Information Commissioner’s Office (ICO) at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire  SK9 5AF

Phone 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.

Alternatively visit www.ico.org.uk or email casework@ico.org.uk