Community Living Well Privacy Notice
On the 25th May 2018, the data protection system across the EU (including the UK) changed. The GDPR replaces the provisions of the Data Protection Act 1998 (DPA). The GDPR preserves the rights provided under the current law and also provides new rights and enhanced protection for individuals, known as Data Subjects.
As a partnership of a number of different organisations, Community Living Well is committed to keeping any information you share with us private and secure. We want everyone who comes to us for help and support to feel confident about how their personal information will be looked after. This includes:
- People who use Community Living Well services
- People who visit our website
The Community Living Well website is managed by Kensington and Chelsea Mind and hosted by C27.
For the purposes of the Data Protection Act 1998 and (from 25 May 2018) the EU General Data Protection Regulation 2016/679 (“Data Protection Law”), Kensington and Chelsea Mind is both a “Data Controller” and a “Data Processor.” This means that we are responsible for and control the collection and processing of, your personal information.
Within the Community Living Well partnership, each organisation is responsible for their own GDPR compliance and how they manage and store your personal data will be set out in their own organisation’s privacy notice.
This Privacy Notice sets out:
- Your GDPR Rights, as an individual and where to go for more information about exercising them.
Our commitment to you:
All partners within Community Living Well will ensure our operational practice ensures that your personal information is:
- Processed lawfully, fairly and in a transparent manner in relation to individuals
- Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
- Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed
- Accurate and, where necessary, kept up to date; every reasonable step will be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay
- Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed
- 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
Why and how we collect information about you:
Everything we do, we do to fulfil our aim: to improve the mental and physical wellbeing of those with mental health needs, and provide better social support so that people are able to maintain good health and wellbeing, maintain independence and achieve their self-determined goals. This can include:
- Ensuring that you receive the communications that are most relevant to you; whether it is be it through visiting our website or receiving emails, post or phone calls
- Ensuring we have all the information we need to provide you with help and support if you are using our services
How we collect personal information:
When you interact with us directly, indirectly or through a third party: This includes when you phone us, visit our website or get in touch through the post, or in person, or are referred by your GP or another service with the purpose of accessing Community Living Well services.
Wysa Chat-Bot (for Talking Therapy referrals only)
The information you submit using the Wysa chatbot on our Talking Therapy service webpage will only be used to make a referral to the service. It is held securely on the NHS Talking Therapies clinical system (IAPTUS). The referral information is shared with your clinician prior to your appointment. If you indicate that your safety is at risk it may also be shared with your GP.
Wysa will hold user personal data for 90 days, which allows for clinical data to flow as well as re-process in case of any errors. Analytics-related data, which is void of any personal user information is held for longer durations.
The type of information we collect:
Personal information we collect includes
- Details such as your name, date of birth, email address, postal address and telephone number
- Details of the issues you are seeking support with
- Details of the contact we have had with you
- Details of the care and support that you are receiving.
A special note about the Sensitive Personal Information we hold:
Data Protection Law recognises that some categories of personal information are more sensitive. Sensitive Personal Information can include information about a person’s health, race, ethnic origin, political opinions, sex life, sexual orientation or religious beliefs.
- If you apply to one of our services, we may require personal information about your health in order to provide you with the help and support
We will only use this information:
- For the purposes of providing you with a service in support of your health
- We will not pass on your details to anyone else without your express permission except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or posing a threat to others or children contacting us and sharing serious issues such as physical abuse or exploitation. We will also share information where we are legally obliged to do so.
The legal basis for using your information:
In some cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a contract with you.
However, there are other lawful reasons that allow us to process your personal information and one of those is called ‘legitimate interests’. This means that the reason that we are processing information is because there is a legitimate interest for Community Living Well to process your information to enable us to provide you with a service. Whenever we process your personal information under the ‘legitimate interest’ lawful basis we make sure that we take into account your rights and interests.
We will only contact you about our work, services and events by phone, email or text message, if you have agreed for us to contact you in this manner. This is particularly important if you want to receive information about our peer support activities or receive the Community Living Well Newsletter.
Sharing your information:
When you use either of the Clinical or the Wellbeing Services, we will share relevant information within the Community Living Well Service so that we can:
- Determine which Community Living Well Services can best meet your needs
- Work effectively with others offering you care and support
- Co-ordinate your care and support and track progress made towards your goals
To enable the coordination of your care, your personal information is shared with Kensington and Chelsea Social Council (KCSC). If using Community Living Well Self-Care services, KCSC will share your information with relevant service providers via a secure online database. Service providers will then use your information to contact you and deliver your care directly. Your information will only be shared with organisations who are directly involved with the coordination or delivery of your care.
In addition, if you are using one of the services coordinated by BME Health Forum (emotional support services in another language), Kensington and Chelsea Social Council will share your information with BME Health Forum via the secure database, who will in turn share your information with a service provider that meets your specific language needs.
The services involved in Community Living Well are:
- BME Health Forum, who’s service providers include:
- Iranian Association
- French African Welfare Association
- Central London Youth Development
- Clement James
- Community Massage London
- Playground Theatre
- Volunteer Centre K&C
In some cases we will seek your consent to obtain information about you from other sources, e.g. other service providers that you have accessed. We will only do this with your informed consent.
You can opt out of sharing – however we will need to record and share a minimum amount of information in order to offer you support.
We will never sell or share your personal information with organisations so that they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity.
We may disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to enforce our contractual and other agreements.
Keeping your information safe:
We take looking after your information very seriously. Our partner organisations have implemented appropriate physical, technical and organisational measures to protect the personal information the collect, both on and off-line, from improper access, use, alteration, destruction and loss.
How long we hold your information for:
Our partner organisations will only keep it as long as is reasonable and necessary for the relevant activity, which may be to fulfil statutory obligations.
You have various rights in respect of the personal information we hold about you – these are set out in more detail below. If you wish to exercise any of these rights or make a complaint, you can do so by contacting the Community Living Well service you are accessing.
You can also make a complaint to the data protection supervisory authority, the Information Commissioner’s Office at: www.ico.co.uk
Access to your personal information:
You have the right to request access to a copy of the personal information that each partner organisation holds about you, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge. Please make all requests for access in writing, and provide us with evidence of your identity
Right to object:
You can object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
If you have given a partner organisation your consent to use personal information, you can withdraw your consent at any time
You can ask a partner organisation to change or complete any inaccurate or incomplete personal information held about you
You can ask a partner organisation to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it
You can ask a partner organisation to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred
You can ask a partner organisation to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it
‘Cookie’ is a name for a small file, usually of letters and numbers, which is downloaded onto your device, like your computer, mobile phone or table when you visit a website.
They let websites recognise your device, so that the sites can work more effectively, and also gather information about how you use the site. A cookie, by itself, can’t be used to identify you.
The cookies we use:
We use the categorisation set out by the International Chamber of Commerce in their UK Cookie Guide.
We use all four categories of cookies:
- Strictly necessary cookies are essential for you to move around our website and to use its features, like our shopping basket and your account
- Performance cookies collect anonymous information about how you use our site, like which pages are visited most
- Functionality cookies collect anonymous information that remember choices you make to improve your experience, like your text size or location. They may also be used to provide services you have asked for such as watching a video or commenting on a blog
No cookies, please:
You can opt out of all our cookies (except the strictly necessary ones). Find out how to control and delete cookies in your browser. However, if you choose to refuse all cookies, our website may not function for you as we would like it to.
For further information about our privacy practices, please contact the identified data protection officer for the service you are using. This will be displayed on each partner’s website, as part of their privacy notice.