Social Prescribing Privacy Notice
What information do we collect from you?
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes [first name, maiden name, last name, marital status, title, nationality, date of birth, gender and next of kin].
- Contact Data includes [your address, email address and telephone numbers, next of kin and other contact person data].
We also collect where required information which is categorised as Special Category Data under the General Data Protection Regulation. This includes:
- Health Information [NHS number, medical conditions and needs, carer needs, GP surgery]
- Ethnicity
- Religion
- Sexual Orientation
We use different methods to collect data from and about you including through direct interactions. You may give us your Identity, Contact and Special Category Data by filling in forms or by corresponding with us by post, phone, email or in person. This includes personal data you provide when you or someone on your behalf refers you to our service via our referral form or forms embedded in IT systems such as EMIS, DOCMAN, AccurX, Vision or Vision 360 GP systems.
Purposes for which we will use your personal data
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 public task category is being used for data handling 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 at Data Protection Officer, Involve Kent, 30 Turkey Court, Turkey Mill, Ashford Road, Maidstone, Kent, ME14 5PP, 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 run Pseudonymised data reports to measure the impact and/or equality of our services, This may involve us sharing non identifiable Pseudonymised NHS numbers with statutory health services to measure system usage. Pseudonymisation’ of data (defined in Article 4(5) GDPR) means replacing any information which could be used to identify an individual with a pseudonym, or, in other words, a value which does not allow the individual to be directly identified.
| Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
| To register you as a new client | (a) Identity | Art. 6 (1)(e) Necessary to carry out our public task |
| (b) Contact | Art. 9 (2)(a) consent to the processing of those personal data for one or more specified purposes | |
| (c) Special Category | Art. 9 (2)(h) Necessary for reasons of substantial public interest (health and social care) | |
| To deliver the Social Prescribing service which will include: | (a) Identity | Art. 6 (1)(a) Consent to process personal data |
| (a) Identifying and discussing medical and social needs | (b) Contact | Art. 6 (1)(e) Necessary to carry out a public task or in the exercise of official authority |
| (b) Making recommendations and signposting to services that may be of benefit | (c) Special Category | Art. 9 (2)(a) consent to the processing of those personal data for one or more specified purposes |
| (c) Contacting and referring to services/organisations on your behalf | Art. 9 (2)(h) Necessary for reasons of substantial public interest (health and social care) | |
| To monitor outcomes of the service which will include: | (a) Identity | Art. 6 (1)(e) Necessary to carry out a public task or in the exercise of official authority |
| (a) Asking you to complete a questionnaire at the beginning and end of the service | (b) Contact | Art. 9 (2)(h) Necessary for reasons of substantial public interest (health and social care) |
| (c) Special Category | ||
| (d) Profile | ||
| To manage our relationship with you which will include: | (a) Identity | Art. 6 (1)(a) Consent to process personal data |
| (a) Notifying you about changes to our terms or privacy policy | (b) Contact | |
| (b) Asking you to leave a review or provide a testimonial for a case study | (c) Profile | |
| To ensure our legal obligation to report e.g. safeguarding issues | (a) Identity | Art. 6 (1)(c) Necessary to comply with a legal obligation |
| (b) Contact | Art. 9 (2)(c) Necessary to comply with a legal obligation | |
| (c) Special Category | ||
| To provide anonymised data for research purposes | (c) Special Category | Art. 9 (2)(j) processing for purposes of historical or scientific research |
| To provide information in the event of a life or death situation | (a) Identity | Art. 6 (1)(d) vital interest of the data subject or of another natural person |
Who we will share your data with
Following any consultation, we will provide you with the details of an appropriate service who can conduct further assessments or provide suitable interventions. We will not pass any data that we hold to these third party organisations unless you explicitly request that we contact the services on your behalf.
Monitoring information is required to be provided to Clinical Commissioning Groups (CCG), Commissioning Support Units (CSU) but in all cases this is anonymised.
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.
Transferring data outside of the EEA
We do not transfer your personal data outside the European Economic Area (EEA).
How we handle data security
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 need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
How we handle data breaches
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.
How long will we retain your information for?
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.
By law we have to keep basic information about our clients (including Contact and Identity data) for 6 years after they cease being clients for internal administration purposes
What are my rights with regards to data?
You have the right to opt out of the Social Prescribing Service at any time, to do this please email DPO@involvekent.org.uk or phone 03000 810005.
In some circumstances you can ask us to delete your data, contact Donna Greenan, Data Protection Officer at Involve by emailing DPO@involvekent.org.uk or phone 03000 810005.
In some circumstances we may anonymise or pseudonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
To see more about your rights regarding data please visit the Involve Kent Privacy Policy.
