At Edwin House we respect your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
This privacy notice is a public document available to anyone and applies to service users of Edwin House to explain how the service collects and processes personal information in order to conduct normal business activities as a UK charitable supported housing association and Independent Health care provider.
We are registered with the Care Quality Commission (CQC) as a registered provider of the following regulated activities:
- Accommodation for persons who require personal or nursing care
- Accommodation for persons who require treatment for substance misuse
- Treatment of disease, disorder or injury.
Purpose of this privacy notice
This privacy notice aims to give you information on how Framework Housing Association collects and processes your personal data.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Who we are
We are Framework Housing Association and our head office is located at Val Roberts House, 25 Gregory Boulevard, Nottingham, NG7 6NX. (“we”, “us”, “our”).
We are the controller and responsible for your personal data.
The organisational Data Protection Officer can be contacted at DPO@frameworkha.org
Our full details are:
Full name of legal entity: Framework Housing Association
Name or title of DPO: Daniel Meaney
Email address: DPO@frameworkha.org
Postal address: Val Roberts House, 25 Gregory Boulevard, Nottingham, NG7 6NX.
Telephone number: 0115 8417711
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
How we collect your information
We collect information about you via a variety of sources, including when you are referred to one of our services, complete one of our forms, when you call, write, email or meet with us or respond to a survey We may also collect your personal information when you use our social media sites or websites.
We operate CCTV systems at a number of Framework premises for the detection and prevention of crime. It operates continuously and recordings are held for one month.
We may receive information about your from other organisations including;
- Your local authority
- Benefits office
- Criminal justice
- Welfare or support organisations dealing with you.
What information we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
a) Identity Data includes first name, maiden name, last name, marital status, title, date of birth, national insurance number and gender.
b) Contact Data includes billing address, email address and telephone numbers.
c) Financial Data includes bank account and payment card details (for example, when you pay us via direct debit for service charges).
d) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
e) Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
f) Usage Data includes information about how you use our website and services.
g) Communications Data includes your communication preferences.
h) Medical data includes data relating to your health and care, GP reports and hospital visits.
We will also collect personal information about your next of kin. You must therefore ensure that you have the next of kin’s consent to providing their personal details to us, before you provide us with their information.
If you have authorised for someone to act on your behalf, we will also need their personal information before providing any services to you or responding to your queries. You will therefore need to ensure you have their consent to providing their personal details to us, before you provide us with their information.
In addition to the information above, in order to provide you with relevant support and/or treatment, we may also gather more sensitive information relating to your:
- support need (to provide you with the most appropriate support)
- health information
- ethnic origin
- sex life
- sexual orientation.
This information is classed as special category data and requires its own lawful basis for processing.
Our legal basis for processing your health data is to provide you with medical care and support, together with any necessary treatment. Our nurses and doctors are bound by a duty of confidence in relation to the processing of your health data.
We may ask you to complete a NDTMS (national drug treatment monitoring system) consent form to process your health data. Please note you are not obliged to sign this form or, provide your consent to the processing of your health data for the purposes specified by NDTMS.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the services).
What processing we do with the information collected
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you (e.g. to manage your support and/or treatment)
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- To protect your vital interests when sharing personal data to any medical practitioners, such as a GP or nurse, or to make referrals to hospitals and other health care providers, for the provision of your treatment and care. If we do not share your data in such circumstances, it could have a detrimental effect on your health.
To comply with our contractual obligations (e.g. any obligations owed to our Commissioners) we may anonymise your personal data and share the anonymised data with third parties.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We conduct statistical analysis to evaluate our performance against benchmarks and to demonstrate to our service commissioners that we are meeting agreed targets. Statistical information is always anonymised.
We also regularly conduct surveys relating to our services in order to gauge satisfaction and to make improvements based on feedback. We will anonymise personal data when producing any survey reports.
We operate a range of information and communications systems and technologies for efficient operation of the organisation. Personal and sensitive information is stored and managed within those systems which are maintained to achieve a high level of confidentiality, integrity and availability. We hold information in IT systems which may be copied for testing, backup, archiving and disaster recovery purposes.
Lawful basis for processing
Our lawful basis for processing personal information is for legitimate interests, in order to provide you with relevant support and/or treatment.
Our lawful basis for processing special category data is for the provision of health or social care or treatment, in order to provide you with relevant support and/or treatment.
How we will communicate with you
We need to communicate with our service users and this will usually be in writing or by telephone or face to face.
Who we share data with and how long we keep information
We may need to share personal information with government departments, local authorities and support agencies, with our regulator and auditors or with other organisations and agencies where we are legally obliged to do so.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
What we will not do
We will not send you unsolicited marketing material.
We will not sell your data to third parties.
We will not pass your personal data to unrelated third parties unless we are allowed or required to do so by law or we have your explicit permission to do so.
We will not transfer or store your personal data outside of the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will retain data relating to your health for a period of 8 years from the conclusion date of any treatment.
We will retain controlled drugs records for a minimum period of 2 years and a maximum period of 7 years.
We will retain contractual data for a period of 6 years following the date on which the contract was performed.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are set out in detail below. If you wish to exercise any of these rights please contact us at DPO@frameworkha.org.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.