Privacy notice relating to the processing of personal data by Rhondda Cynon Taf County Borough Council for the purpose of Learning Curve – Daytime Opportunities
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 Learning Curve – Daytime Opportunities
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 Learning Curve – Daytime Opportunities
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 Learning Curve East (Gadlys) or West (Llwynypia) centres:
By telephone : Gadlys Learning Curve – 01685 873647
: Llwynypia Learning Curve – 01443 436937
In writing : Gadlys Learning Curve, Maelgwyn Terrace, Gadlys, Aberdare, CF44 8AU
: Llwynypia Learning Curve, Llwynypia Road, Tonypandy, Rhondda, CF40 2JQ
Who we are what we do
Learning Curve provides daytime opportunities for adults with a learning disability, including autism and physical disabilities, across Rhondda Cynon Taf.
The service is provided via a number of centres and bases, from large day centres, to small community bases. Activities are provided at the centres and bases, as well as in the local community
Whose personal data we process
We may process personal data relating to the following individuals for Daytime Opportunities
- Service Users
- Parents, Carers, Guardians
The categories of personal data we process
We may process the following categories of personal data for Daytime Opportunities
- Contact details such as name, address, post code, email address and telephone number
- Personal identifiers such as D.O.B, WCCIS reference
- Health Records including medication and care and support needs
- Criminal Data
Why we process the personal data
We process data to support the delivery of our services and to ensure the safety and wellbeing of individuals who visits our day centres. The processing may include, but not limited to the following activities:
- Collecting and storing emergency contact forms completed by parents/carers which include details such as names, addresses, phone numbers and medical records. These are securely stored at the centres in locked cabinets
- Maintaining daily logs of activities, communications with parents/carers or professionals, and attendance registers.
- Recording each instance of medication administered, including the name of the medication, dosage and how its administered
- Documenting any accidents or incidents that occur at the centres.
- Receiving and storing care plans from social workers, including information relevant to individual needs and support arrangements
- Completing and storing any safeguarding concerns, including criminal convictions to protect service users
- The processing and management of complaints.
- Processing of photo/video consent forms
- Referring service users to external partners for additional daytime activities
Our lawful basis for processing the personal data
Under the General Data Protection Regulation (GDPR), our lawful basis for processing the personal data for daytime opportunities is;
- Legal Obligation - Article 6(1)(c) – processing is necessary for compliance with a legal obligation to which the controller is subject.
- Public Task - Article 6 (1)(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.
- Health & Social Care – Article 9(2)(h) - Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of domestic law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3
- 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.
- Statutory and Government Purposes - Schedule 1, Part 2(6) – Data Protection Act 2018
The primary legislation, regulations and guidance that supports this includes, but is not limited to;
- Social Service & Well-being (Wales) Act 2014
Who or where we get the personal data from
We may receive the personal data from the following categories of individuals or organisations;
- Social Workers
- Next of Kin
- Parent / Carer / Guardian
- Directly from the Service User
- Health Professionals
- School / Colleges
Who we share personal data with
We may share the personal data with the following key organisations for Daytime Opportunities.
When sharing the personal data, we only share the minimum amount necessary in relation to the purposes.
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Who
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Purpose
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Internal Council Departments
- Adult Services
- Safeguarding
- Health & Safety
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- To assess and update care and support plans
- To raise any safeguarding concerns
- To report any accidents which occurs at the day centres.
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External Partners and trusted 3rd parties
- Arts Factory
- Cambrian Village Trust
- Two Rhythms
- Artis Community
- People First
- Elite Supported Employment Agency.
- Forget me Not Productions
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- Referring service users for additional daytime support and activities
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Cwm Taf Morgannwg Local Health Board
- Physiotherapists
- Speech & Language Therapists
- Occupational Therapists
- Learning Disability Nurses
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- To assess service users and provide necessary support
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Parents / Carers / Next of Kin
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- To provide updates on the support received whilst attending the centres
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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 category of data processors we use for the purpose of Daytime Opportunities are
- IT system suppliers etc
How long we retain the personal data
We retain the personal data contained within Daytime Opportunities records for:
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Length of time
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Reason
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Needs Assessments – End of Service plus 3x years
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Statutory Requirement
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Care and Support Plans – End of service plus 3x years
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Statutory Requirement
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Quick Reference Sheets – End of Service plus 3x years unless superseded
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Statutory Requirement
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Internal Monitoring and Recording logs – Date of less entry plus 3x years
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Statutory Requirement
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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 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 Learning Curve – Daytime Opportunities Service directly via one of the following communication methods. Most concerns can be resolved relatively quickly through a simple phone call or email;
- Telephone : Gadlys Learning Curve – 01685 873647
: Llwynypia Learning Curve – 01443 436937
- In writing : Gadlys Learning Curve, Maelgwyn Terrace, Gadlys, Aberdare, CF44 8AU
: Llwynypia Learning Curve, Llwynypia Road, Tonypandy, Rhondda, CF40 2JQ
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