Privacy Policy - Hafan Cymru

Hafan Cymru has signed the ICO Personal Information Promise and we promise that we will:

value the personal information entrusted to us and make sure we respect that trust.
go further than just the letter of the law when it comes to handling personal information, and adopt good practice standards.
consider and address the privacy risks first when we are planning to use or hold personal information in new ways, as when introducing new systems.
be open with individuals about how we use their information and who we give it to.
make it easy for individuals to access and correct their personal information.
keep personal information to the minimum necessary and delete it when we no longer need it.
have effective safeguards in place to make sure is kept securely and does not fall into the wrong hands.
provide training to staff who handle personal information and treat it as a disciplinary matter if they misuse or don’t look after personal information properly.
put appropriate financial and human resources into looking after personal information to make sure we can live up to our promises.
regularly check that we are living up to our promises and report on how we are doing.

If you would like a copy of our Data Protection, Data Subject Request or Data Breach policies please ask a member of staff.

How and why we collect your personal information, what we do with it and your Data Protection rights

What is “personal information”?
Personal information is data that Hafan Cymru hold about you and which identifies you. This includes your name, date of birth and address as well as things like health details and records of the type of needs you want us to support you with. Hafan Cymru may also record your religion or ethnic group. Photos, CCTV and video recordings of you are also personal information.

How and why do we collect and use personal information?
We get your personal information from:

you (e.g. through an application or assessment form you have filled in); or
another agency who has referred you to us (e.g. a Local Authority, Women’s Aid, the Police etc.)

We collect this information to help us to:

provide the services you have asked for;
help to keep you and your family safe;
let our funding commissioners (e.g. Local Authorities, the Welsh Government, Police and Crime Commissioners) know that we are doing what they have asked us to do in our contracts with them.

We will only share your information with other organisations when we have a good reason to do so. In exceptional circumstances we may need to share it more widely than we would normally. Here are some examples of how we use your data:

we use CCTV to make sure the housing project where you live is safe. CCTV is not used in private areas such as in your flat but only in communal parts.
we need to report some of your information to your Local Authority e.g. we have to tell your Local Authority Supporting People Team that you are receiving services from us, or to let them or other agencies (e.g. the police) know if we have any concerns about you or your family’s welfare.
we may use information about any court orders or criminal matters which relate to you so we can safeguard you and your family, or other tenants if you live in one of our shared properties.
when you leave us we may need to provide your information to other agencies, e.g. we may share information about the work we’ve.
completed with you so the new agency can safeguard you and your family’s welfare or so they can provide you with the services you have requested.
if you are from another country we have to make sure that you have the right to remain in the UK. We might have to provide information to UK Visas and Immigration department.
occasionally we use consultants, experts and other advisors to assist us to create reports or research into how we can improve our services. We might need to share your information with them if this is relevant to their work but we will always ask for your consent first and would not pass any personal data to them if you did not want us to.
we will only use photographs or videos of you for our website, newsletters or other publicity materials with your specific consent for this and you are always able to refuse consent.

Our legal grounds for processing your information
Hafan Cymru holds the legal right to collect and use personal data relating to our clients, learners service users, tenants and their families. We may also receive information regarding them from other agencies like a Local Authority.

We collect and use personal data in order to meet legal obligations, contractual requirements and legitimate interests as set out in the Data Protection Act 2018.

Legal Obligation
This is where Hafan Cymru needs to use your information in order to comply with a law, for example to report a concern to Children’s Services. We may also have to disclose your information to third parties such as the courts, Local Authority or the police where we are legally obliged to do so. Specifically, Hafan Cymru has legal obligations for:

safeguarding and promoting you and your family’s welfare and wellbeing, and the welfare of other tenants living in the same shared accommodation as you.
ensuring everyone receives a fair, non-discriminatory service.

Contract
This means that the processing of personal data is necessary for fulfilling our contractual obligations to you, except where the processing is unfair to you. Specifically, Hafan Cymru has contractual obligations with:

the Commissioners and funders for our services.
providing clients, learners, service users and tenants with the services they have requested.

Legitimate interests
This means that the processing of personal data is necessary for our legitimate interests, except where the processing is unfair to you. Specifically, Hafan Cymru has legitimate interest in:

promoting the purpose and activities of Hafan Cymru.
running our business efficiently and planning for the future.
ensuring that all of our relevant legal responsibilities are complied with.

Who do we share your information with?
We routinely share client, learner, service user or tenant information with:

agencies who are also acting on your behalf, e.g. Women’s Aid.
local authorities, e.g. Housing Benefit, Supporting People teams, child welfare services.
examination boards, e.g. where you are undertaking training while you are receiving support from us.

Occasionally your data might be outsourced to another agency who will process your information (for example if we asked a consultant to use your information for a report). However, this will only be done with your consent, unless the law requires Hafan Cymru to share your data. Where Hafan Cymru outsources data to a third-party processor, the same data protection standards are expected to be upheld by this agency.

For how long do we keep your information?
We will keep a record of the majority of your personal information for 7 years, however, in some circumstances we may keep information for a longer time. We would only do this if we had a good reason and only if we are allowed to do so under data protection law.

What decisions can you make about your information?
You can make various decisions about your information.

Your rights are:

if information is incorrect, you can ask us to correct it.
you can ask what information we hold about you and be provided with a copy. We will also give you extra information, such as why we use your personal data, where it came from and what types of people or organisations, we may have sent it to.
you can ask us to delete the information that we hold about you in certain circumstances, e.g. where we no longer need the information.
you can ask us to send you, or another organisation, certain types of information about you in a format that can be read by computer.
our use of your information may be restricted in some cases, e.g. if you tell us that the information is inaccurate, we can only use it for limited.
purposes while we check its accuracy.
where the processing of your data is based on your consent, you have the right to withdraw this consent at any time.

If you have any concerns about the way Hafan Cymru is collecting or using your personal data, you can raise them with the Information Commissioner’s Office (ICO). The ICO can be contacted on 0303 123 1113 or by visiting the website ico.org.uk.