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Client Finance Privacy Notice

Privacy notice relating to the processing of personal data by Rhondda Cynon Taf County Borough Council for the purpose of the Client Finance (Assessment) Team

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 the Client Finance Team.

Whilst we have tried to make this privacy notice as clear and concise as possible, the categories of personal data we process may vary depending on the information you provide to us when completing a Financial Assessment form.

This notice should be read in conjunction with;

The Data Controller 

The Council is the data controller for the personal data processed for the purposes of administrating Client Finance,

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 Financial Assessment Team:

By email : SocialCareCharging@rctcbc.gov.uk

By telephone : 01443 680380 / 680383

In writing : Financial Assessment Team, Oldway House, Porth, CF39 9SD

Who we are what we do

Social Services in Wales are expected to make a charge for some of the services they provide. The Client Finance Team are responsible for assessing every adult service user’s ability to make a financial contribution towards any chargeable services they receive.

To assess your financial circumstances we will provide you with a Financial Assessment Form to record details of your income and expenditure. Once completed we will assess the amount you may need to pay towards the cost of any chargeable services you receive. 

The Client Finance Team will contact you to explain how any contribution you have to make has been calculated and how to make the required payment.

Whose personal data we process

We may process personal data relating to the following individuals as part of a financial assessment:

  • Service Users
  • Financial Representatives acting on behalf of the service user
  • Family Members of the Service User

The categories of personal data we process

We may process the following categories of personal data as part of a financial assessment:

Service User’ Personal Data

  • Contact Details such as Name, Address, Telephone Number and Email
  • Personal Identifiers such as D.O.B, National Insurance Numbers, WCCIS Number, Occupation and Marital Status Details on income, this could be earnings, Pension income and any Benefit Entitlements
  • Details on any savings or capital. Details on any outgoings, such as Rent, Mortgage and Council Tax
  • Bank Account number
  • Health Data, such as disability.

Financial Representative’s Personal Data

  • Contact Details such as Name, Address, Telephone Number and Email
  • Relationship to the Service User i.e Next of Kin, Power of Attorney.

Family Members Personal Data

  • Contact Details such as Name, Address, Telephone Number and Email
  • Personal Identifiers such as D.O.B, National Insurance Numbers,
  • Occupation and Marital Status
  • Relationship to the Service User i.e Next of Kin, Partner, Power of Attorney
  • Carers Allowance Benefit Entitlement.

Why we process the personal data

The purpose of the Client Finance Team processing your data is as follows:

  • To calculate any contribution that you may have to make towards the cost of any Social Services care and support you receive 
  • To process payments and issue invoices 
  • To recover any debt that may be outstanding.

Our lawful basis for processing the personal data

Under the General Data Protection Regulation (GDPR), our lawful basis for processing the personal data for Client Finances are:
  • Legal Obligation Article 6(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.
  • Article 9(h) – processing is necessary for the purposes of preventatibe occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health and social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contrach with a health professional and subject to the conditions and safeguards referred to in Paragraph  
  • Schedule 1, Part 1 Data Protection Act 2018

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

  • Social Services and Well-being (Wales) Act 2014
  • The Care & Support (Financial Assessment) (Wales) Regulations 2015
  • Mental Capacity Act.

Who or where we get the personal data from

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

  • The Service User
  • Financial Representative acting on your behalf
  • Social Care Staff who may be involved in assessing your needs
  • DWP, Banks, Building Society and Pension Providers to ensure we have the necessary information to complete the financial assessment

Who we share personal data with

We may share the personal data with the following key organisations when carrying out Financial Assessments: When sharing the personal data, we only share the minimum amount necessary in relation to the purpose. The information shared and who it is shared with will depend on the information provided within the Financial Assessment Form.   

Who

Purpose

Social Care Staff  

    To provide an update on the calculation of the assessment

Department of Work and Pensions
    To confirm Benefit Entitlements

Credit Reference Agencies
    To prevent or detect fraud to protect public funds

Other Public Authorities
    To prevent or detect fraud or crime To recover monies owed to us To improve public service delivery Statistical research

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 the Client Finance Team are

IT Suppliers

    WCCIS – Health & Social Care Record System
    ABACUS – Finanancial Management System
Commisioned Services
    Civica – To Assist with Financial Assessments

How long we retain the personal data

We retain the personal data contained within our records for:

Length of time

Reason

Client Finance Assessment data will be kept until social care is no longer required plus 7 years after.

Audit purposes and to evidence any outstanding payments after social care ends.
In keeping with the General Data Protection Regulation storage limitation principle, records are periodically reviewed. Information that has no 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 Client Finance Team directly via one of the following communication methods. Most concerns can be resolved relatively quickly through a simple phone call or email;

Email : SocialCareCharging@rctcbc.gov.uk

Telephone : 01443 680380 / 680383

In writing : Financial Assessment Team, Oldway House, Porth, CF39 9SD 

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