Privacy Policy
At Response, we are committed to ensuring your privacy, whether online or through other means of communicating with the charity. Data protection is of an exceptionally high priority for Response.
This privacy notice will provide you with all the information needed to help you understand how we obtain, use and share your personal data.
Who we are
Response Organisation (Response) is a registered charity providing accommodation, care and support in community-based settings in the Thames Valley for people with enduring mental health needs.
We are registered with the Charity Commission (charity number 1101071) and the Information Commissioner (Z762256X).
We are both a controller and processor of personal data for the UK General Data Protection Regulation (GDPR) purposes. We will always process your personal data in accordance with current data protection legislation.
You can contact us at:
The Data Protection Officer
Response
A G Palmer House, Morrell Crescent
OX4 4SU Oxford
United Kingdom (UK)
Phone: 01865 397 940
Email: info@response.org.uk
Website: https://www.response.org.uk
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated in TBC.
It is vital that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information related to someone who can be reasonably identified.
We may collect, use, store and transfer different kinds of personal data about you. This includes, but is not limited to, when you browse our website, contact us or when you receive housing and support services from Response.
We have grouped together the types of personal data as follows:
- Identity Data includes first name, birth name, last name, marital status, title, gender, birth date, age, NHS number, National Insurance number, facial photograph, Vaccination and immunisation status etc.
- Care and support data includes information relating to your health, notes recorded about your well-being and may consist of information shared with us by other agencies or authorities.
- CCTV data, including images recorded in and around Response, managed housing in accordance with our CCTV Policy.
- Contact Data includes address (including postcode), email address and telephone numbers.
- Financial Data includes billing information (but we do not store credit card data or any other sensitive payment amount), bank account and payment card details.
- Financial Transaction Data includes details about payments to and from you.
- Technical Data includes internet protocol (IP) address, unique device ID, browser type and version, operating system, referring domain, language preferences, mobile carrier if you are using a mobile device and other general information such as geolocation and online behavioural tracking.
- Marketing and Communications Data includes your communication preferences.
- Video and sound recordings includes your image and/or voice from meetings where recordings are made, with your knowledge and consent.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by corresponding with us by post, email or otherwise. This includes the personal data you provide when you ask us to carry out our services for you.
- Third parties or publicly available sources. We may receive personal data about you from various third parties, and public sources, as set out below.
- Technical Data from third parties such as google analytics, who may collect information such as website analytics through our website.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services and credit check providers.
- Identity and Contact Data from publicly availably sources.
- Social media platforms such as LinkedIn, Facebook, Instagram, Twitter or others.
- Youth Network and similar services. We may collect personal data about you when group or individual sessions are recorded (both video and sound) with your permission.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- To deliver our contractual obligations for the provision of services for our partners e.g., local authorities.
- To respond to your requests or enquiries regarding our services
- Where we need to comply with a legal or regulatory obligation.
- Where it is necessary for our legitimate interests (or those of a third party), but only when these are of lesser importance than your interests and fundamental privacy rights.
We may also use your personal data in the following situations, but these are not likely:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Below is a description of all the ways we plan to use your personal data, what makes it lawful to do so and, what legitimate interests we might rely on.
Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a client for our services. | Identity Contact Care and support data | Performance of a contract with you and our partners Legal obligation i.e., safeguarding |
To process and deliver our services including. fulfil our contractual obligations with relevant authorities to provide services. Manage payments, fees and charges. Collect and recover money owed to us. Other processing necessary to comply with our legal obligations such as detecting and reducing fraud. ensuring business policies are adhered to, such as security policies and internet use. manage complaints. | Identity Contact Financial Transaction Care and support data CCTV data | Performance of a contract with you i.e., tenancy agreements. Performance of a contract with our partners i.e., service provision contracts Necessary for our legitimate interests to recover debts due to us or to be as efficient as we can so we can deliver the service to you. Necessary for the purposes of crime prevention and to safeguard the health and safety of service users and members of staff. CCTV may also be used to investigate accidents and incidents which may give rise to criminal prosecution or civil victims. Your consent for the sharing of data with our service partners. |
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | Identity Contact Technical CCTV Data | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation Necessary for the purposes of crime prevention and to safeguard the health and safety of service users and members of staff. CCTV may also be used to investigate accidents and incidents which may give rise to criminal prosecution or civil victims. |
Employment | Identity Contact Financial | Legal obligation (employment law, EDI monitoring, tax, revenue and pensions, etc.) Contractual obligations re our contracts of employment including, but not limited to, deciding about your recruitment or appointment, checking you are legally entitled to work in the UK, administering contracts, conducting performance reviews, training and development, ascertaining your fitness to work, ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems etc. Our legitimate interests to protect the business from crime and fraudulent activity Our legitimate interests to keep staff, clients and others on our premises safe (Health and safety). |
USE OF SENSITIVE DATA
“Special categories” or sensitive personal data require higher levels of protection than non-sensitive data. To process such sensitive data, we need further justification. We may process special categories of personal data in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations or exercise rights in connection with employment.
- Where it is needed in the public interest.
Employment | In receipt of services from Response |
We may process sensitive personal data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We will use your sensitive personal data in the following ways: · In relation to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws. · In relation to your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits. · In relation to your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting. | We may process sensitive personal data where it is needed to provide the services we have been contracted to deliver. We will use your sensitive personal data in the following ways: · In relation to your physical or mental health, or disability status, to ensure your health and safety whilst in receipt of our services. · In relation to your physical or mental health, or disability status, to ensure you receive appropriate care. |
DISCLOSURES OF YOUR PERSONAL DATA
We will only share or disclose your personal data if there is a lawful reason to do so.
Employment | In receipt of services from Response |
We may share your personal data with third parties e.g., payroll, pension administration, benefits provision and administration, IT services or if we have other legitimate interests. Your data may also be shared with third parties if we restructure our business or when dealing with regulators and other competent bodies e.g., law enforcement. | When you receive services from us, we routinely share data with other organisations. These other organisations will be limited to those for whom we, · deliver contracted services e.g., local authorities or other relevant authorities., or · have a written data sharing agreement such that your data always remains protected by UK GDPR, or · have a written contract for the provision of data processing services such that your data always remains protected by UK GDPR, or · regulatory bodies and competent bodies e.g., law enforcement for whom we have a legal obligation to share the data. We require all recipients of your data to respect the security of your data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We may also share your data with third parties to whom we may choose to sell, transfer, or merge parts of our business. Alternatively, we may seek to acquire other businesses or merge with them. If our business is restructured, your personal data will be used in the same way as set out in this privacy notice. |
INTERNATIONAL TRANSFERS
Should we transfer your personal data out of the UK, we will ensure adequate safeguards are in place to protect your personal data. This may include, but is not limited to, reliance on adequacy regulations e.g., transfers to the European Economic Area (EEA), the use of approved standard contractual clauses and International Data Transfer Agreements and Transfer Risk Assessments.
Please contact us if you want further information on the specific mechanism used by us if we transfer your personal data out of the UK.
YOUR LEGAL RIGHTS
Whenever you have a question about your data rights, please get in touch with our data protection officer (DPO) using the contact details provided above in ‘Who we are’. If you contact another member of our staff, they will pass your request on to our DPO for prompt action.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no proper reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee is usually required to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have been duly authorised. They will only process your personal data on our instructions, or regarding the terms of an agreed data sharing arrangement and they are always subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected or actual personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Where we act as a data processor, we will fulfil the retention obligations as set by the data controller for whom we process your data.
Health data retention depends on the type of health data in question. Retention periods for health data are guided by the NHS health records retention schedules. Which can be found here: Records Management Code of Practice 2021 - NHS Transformation Directorate (england.nhs.uk) or by contacting us, if you have a specific question.
COMPLAINTS
Should you feel unhappy about the way we have handled your personal data, you have the right to complain to the regulator, the Information Commissioner at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate)