Harm Reduction Co-ordination within Cwm Taf Morgannwg Region

Introduction

This privacy notice is intended to provide information about how Rhondda Cynon Taf County Borough Council (referred to as ‘RCTCBC’, ‘Council’, ‘Local Authority’, ‘we’) will use (or ‘process’) personal data about individuals for the purpose of harm reduction co-ordination in the Cwm Taf Morgannwg region.  

This notice should be read in conjunction with;

• The Council’s corporate privacy notice

The Data Controller

The Council is the data controller for the personal data processed for the purposes of harm reduction co-ordination.

The Council is registered with the Information Commissioner’s Office (ICO) as a controller under reference Z4870100.

Queries relating to this privacy notice

If you have any questions or queries relating to this privacy notice please contact the Area Planning Board Substance Misuse Team:

By email : contact@substancemisuerct.co.uk

By telephone : 01443 425612

In writing : Cwm Taf Morgannwg APB – Lead Officer (Substance Misuse), RCTCBC, Tŷ Elái, Dinas Isaf East, Williamstown, Tonypandy, CF40 1NY

Who we are what we do

Welsh Government have asked a number of partner organisations to work more closely together to improve substance misuse services for people in Wales.

Within the Cwn Taff Morgannwg (CTM) area, the following organisations work together to provide a service for the people who live in the area and have issues with drugs or alcohol. 

Bridgend County Borough Council

Merthyr County Borough Council

Rhondda Cynon Taf County Borough Council (RCTCBC)

Cwm Taf Morgannwg University Health Board

South Wales Police

Barod

Dyfodol 

The Service also works closely with a number of other trusted organisations and partners, examples of which are detailed in section 6.

One of the aims of the service is to reduce the number of drug related deaths and increase awareness of Naloxone. We do this by reviewing non-fatal drug poisoning incidents (overdoses), offering advice and guidance on reducing the risk of overdose and offering Naloxone training. We can also refer you to relevant services if you wish.

The term ‘we’ throughout this privacy notice refers to the services provided in Cwm Taf Morgannwg.

Whose personal data we process

We receive and hold information relating to adults and young people at risk of a drug related death and those who have experienced a non-fatal drug poisoning incident, which can include accidental drug poisonings. 

We may process personal data relating to the following individuals who are at risk of a drug realted death and those who have experienced a non-fatal drug poisoning incident, which can include accidental drug poisonings;

• Adults
• Young people

The categories of personal data we process

We may process the following categories of personal data to enable the team to carry out its function of reducing harm;

• Name, date of birth, address, contact number
• Your ethnic origin 
• Date, location and circumstances of incident (where known)
• Substances involved and treatment provided (where known)
• Discharge information (where relevant)
• Information regarding whether you are being supported by other agencies and if you have received Naloxone training
• Any other information that is relevant to reducing harm to yourself

Why we process the personal data

We process the personal data to enable the team to carry out its function of reducing harm.

This may include but is not limited to the following activities;

• Information relating to non-fatal incidents/overdoses will be used to engage with you to provide harm reduction advice and guidance, in order to prevent future overdose or death.
• When we receive notification of a non-fatal drug poisoning, your name, date of birth (and sometimes your address) will be circulated to our trusted partners to establish whether any of them are already working with you. If you are already known to an organisation, they will take the lead and contact you to offer support.
• Where you are not known to our partner organisations, a member of our team will get in contact with you, either by visiting you at home or speaking to you on the phone, to offer you support and promote ‘Take Home Naloxone’.
• In all instances, it is up to you if you wish to take up the support offered.

Our lawful basis for processing the personal data

Under the General Data Protection Regulation (GDPR), our lawful basis for processing the personal data to reduce harm is;

• Legal Obligation (c) – processing is necessary for compliance with a legal obligation to which the controller is subject. 
• Public Task - Article 6 (e) – processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
• Substantial public interest - Article 9 (2) (g) - processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

The primary legislation, regulations and guidance that supports this includes, but is not limited to;

Who or where we get the personal data from

We may receive the personal data from the following categories of individuals or organisations;>

• Directly from you e.g. if you tell a member of our team about an incident yourself
• From your family, friends, or members of the public e.g. if they tell a member of our team about an incident
• From a number of trusted partner organisations/services, including:

Cwm Taf Morgannwg University Health Board, including A&E departments e.g. if you are admitted to A&E for an overdose

South Wales Police e.g. if the police are involved in your overdose incident

Her Majesty’s Prison and Probation Service e.g. if you are being supervised by Probation or have served a custodial sentence

G4S Care & Justice Services/Her Majesty’s Prison Parc e.g. if you have served a custodial sentence in HMP Parc

Voluntary sector partners you are receiving support/a service from e.g. Barod, Dyfodol, Kaleidoscope, Pobl, The Wallich

Other departments in Rhondda Cynon Taf County Borough Council, Bridgend County Borough Council, Merthyr Tydfil County Borough Council e.g. Social Services, Housing Services, Youth Offending Services

Who we share personal data with

We may share the personal data with the following key organisations to work together effectively for your benefit and care and reduce harm.

When sharing the personal data, we only share the minimum amount necessary in relation to the purpose.

We also share non identifiable (anonymous) information with Welsh Government and Public Health Wales for statistical and research purposes

Data Processors

A data processor is a company or organisation that processes personal data on our behalf. Our data processors act only upon our instruction. They cannot do anything with the personal data unless we instruct them to do so. They will not share the personal data with any organisation apart from us or use it for their own purposes. They will hold it securely and retain it for the period we instruct.

The categories of data processors we use for the purpose of reducing harm are;

• IT system suppliers etc

How long we retain the personal data

We retain the personal data contained within records for:

In keeping with the General Data Protection Regulation storage limitation principle, records are periodically reviewed. Not all personal data is retained. Only personal data that is relevant to the record is retained for the entire retention period. Information that has not long term or evidential value is routinely destroyed in the normal course of business.  

Your data protection rights

The General Data Protection Regulation (GDPR) gives individuals important rights, including the right of access to the personal data that the Council holds about you.

Click here  for further information on your information rights and how to exercise them.

Your right to make a data protection complaint to the Council

You have the right to complain to the Council if you believe we have not handled your personal data responsibly and in line with good practice.

You can do this by contacting the Area Planning Board Substance Misuse Team directly via one of the following communication methods. Most concerns can be resolved relatively quickly through a simple phone call or email;

• By email : contact@substancemisuerct.co.uk
• By telephone : 01443 425612
• In writing : Cwm Taf Morgannwg APB – Lead Officer (Substance Misuse), RCTCBC, Tŷ Elái, Dinas Isaf East, Williamstown, Tonypandy, CF40 1NY

Alternatively, you can raise a formal complaint via the Council’s Customer Feedback Scheme using the following link (Make a comment, compliment or complaint online) or you can contact the Council’s Data Protection Officer at Information.management@rctcbc.gov.uk.

Your right to make a data protection complaint to the ICO

You also have the right to complain to the ICO if you are unhappy with how we have used your data. However, we encourage you to contact us first and provide us with an opportunity to look into your concern and put things right.

The ICO can be contacted:           

• Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
• Helpline number: 0303 123 1113
• Website: https://www.ico.org.uk