Privacy Policy

Data Protection & Privacy Policy

First Point Family Support Services is fully committed to comply with the UK General Data Protection Regulation (UK GDPR).

The UK GDPR applies to all organisations that process data relating to employees, as well as to others including customers, contractors, and clients. It sets out principles which should be followed by those who process data; it gives new and extended rights to those whose data is being processed.

To this end, First Point Family Support Services staff are fully trained to endorse fully and adhere to the six principles of data protection, as set out in Article 5 of the UK GDPR.

Data must be processed lawfully, fairly and in a transparent manner in relation to individuals

Data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
Data must be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed
Data must be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased, or rectified without delay
Data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed
Data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures

These principles must be followed at all times when processing or using personal information.

Therefore, through appropriate management and strict application of criteria and controls,

all First Point Family Support staff will:

Observe fully the conditions regarding the fair collection and use of information including the provision of consent
Meet its legal obligations to specify the purposes for which information is used
Collect and process appropriate information only to the extent that it is needed to fulfil
Ensure personal data is accurate and up to date
Ensure that the information is held for no longer than is necessary
Ensure that the rights of people about whom information is held can be fully exercised under the UK GDPR (i.e., the right to be informed that processing is being undertaken, to access one’s personal information; to prevent processing in certain circumstances, and to correct, rectify, block or erase information that is regarded as incorrect)
Take appropriate technical and organisational security measures to safeguard personal information
Publicise and abide by individuals' right to appeal or complain to the supervisory authority which is the Information Commissioner's Office (ICO) in the event that agreement cannot be reached in a dispute regarding data protection

Information Commissioner's Office, Phone 03031 231 113, Address; Wycliffe House Water Lane, Wilmslow SK9 5AF)

ensure that personal information is not transferred abroad without suitable safeguards

Who do we receive data from?

First Point Family Support Services works with multiple statuary and voluntary and private sector services across our strands of work, which are 1-1 Family Support, Post Diagnostic Support – ADHD and ASD, hosting specific events (lead by service user need), PACT, Riding the Rapids, and support with financial forms (DLA/PIP) and tribunals.

To perform our services effectively as well as yourself we may receive data about you from a wide variety of individuals and organisations such as:

Bury Local Authority
Bury Clinical Commissioning Group
Northern Care Alliance
Pennine Care NHS Foundation Trust
Pennine Acute Hospitals NHS Trust
Rehabilitation for Independence
HCRG Care Group
Schools within the borough of Bury
Schools outside the borough of Bury
Department of Work and Pensions
Bury SENDiass Service (Barnardo’s)
Housing providers
Third sector emotional health and wellbeing services (children and adults)

We will also keep you informed of who we have received information from whilst we are providing services to you.

What Data do we collect?

To be able to offer you the best possible service we need to collect relevant information about you, this helps us make decisions about your service. We do not collect or store any information that is not relevant to our work with you.

We offer a diverse range of services at First Point Family Support Services and can collect different levels of information about you dependent on what service you are accessing.

The below list covers the full list of data we may collect as a service:

·Your general demographic data

This means details about you such as your name, date of birth, address, contact details (phone number/email address) and dependent on your age, your parent/carers name and contact details

·Further information you give us

When we meet you for the first time, alongside the general information we obtain about you such as your name, date of birth, etc you might explain in more detail any difficulties you are experiencing such as anxiety. If this is relevant to functions the service needs to perform for you, we may also need to collect this. This information is called ‘Special Category’ data under the UK GDPR and is treated more sensitively and with extra safeguards in place

·Information to and from 3rd. Parties.

We may receive information about you from other people and services that you may have interacted with. This could include general demographic information as they may send a referral into the service on your behalf, or it could be part of the work of other organisations who contact us about you. Where we receive a request to share personal data about you to a 3rd. party, we will contact you first to seek your views. The exception to this is where we are legally obliged to do so or situations where we feel you are at risk of immediate harm or are being harmed

What about more sensitive data?

The laws says that some kinds of personal data needs to be handled more sensitively than others and as mentioned above is referred to by the UK GDPR as Special Category Data.

The categories of Special Category (sensitive) Data First Point Family Support Services would process is limited to:

Personal data about your ethic origin and race
Health related data

We promise that we will:

Only ever use information about your health or ethnic origin where you or your parent or guardian has given consent. An example of this is if you tell us something we believe is so important that it should be shared with your GP (Doctor) for your welfare
Never analyse or target any parent/carer or young person based on their gender, age, or ethnic origin

How we store data

Data is stored electronically on a password protected database where only staff fully trained in handling data have access to.
We take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

The lawful bases we use for processing your data

Consent
Contract
Legal Obligation
Vital Interests

The UK GDPR sets out different legal gateways for processing personal data where the purpose must be met by one or more for it to be lawful. Primarily First Point Family Support Services relies on the lawful basis of ‘Consent’ as its main legal basis to perform its services and takes a "granular" approach i.e., it asks for separate consent for separate items and will not use vague or blanket requests for consent. As well as keeping evidence of any consent First Point Family Support Services ensures that people can easily withdraw consent (and tells them how this can be done).

However sometimes we are required to process data via the terms of a business ‘Contract’ we enter into with other organisations such as sharing information back to them where we hold their data for the purposes of a data subject access request.

On some occasions we are obliged to share data under statutory legislation and regulations. We do this under the lawful basis of ‘Legal Obligation.’ An example of this is where we need to share certain items of personal data with the Department of Education.

A rare yet important lawful basis we may process your personal data under is also ‘Vital Interests. Circumstances where this may be relevant is if we believe you may be in danger and to protect your welfare interests it is essential that we need to share your data to organisations such as the Social Services or Ambulance Service or Police or your parent/carer without gaining your permission.

Who do we share your data with?

At the start of our work with you we will discuss if you are working with any other people, also during our work with you another service may become involved with you.

We do this to make sure that we understand how your needs are being met to make sure we are not duplicating work and to also join up our work with other organisations to better support you.

We will discuss these services with you and ask your permission if we can share relevant information with them. e.g., you may be involved with the Social Care service and want us to talk to you Social Worker about what work we are doing with you.

We may share data with our subcontracted companies, so they have your contact details to provide you with a seminar you have asked to book onto.

To be clear any sharing of your data is done with your consent.

File Retention (How long will we keep data about you)

At First Point Family Support Services We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. Your information we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information. More information on our retention schedule can be found online.