PRIVACY NOTICE FOR STUDENTS AND PARENT CARERS
Please read the information carefully in this notice
This notice describes the information we collect about you, why we collect it and what we do with it as well as other information you have the right to know under the General Data Protection Regulation.
If you in any way believe that the way your information is processed by GLAS Ltd is not compliant with the General Data Protection Regulations you can complain directly to us in writing (by letter or digitally) or to the Information Commissioners Office with the details of your complaint. The addresses you need for this are at the end of this Privacy Notice.
Who we are: –
Garnet Lodder Adolescent Services Ltd
Who you can talk to about your information: –
Chris Lodder – 07951 946303
The information/Data we collect:
- Contact details, Address and Date of Birth
- Education Health Care Plans (if in place)
- Safeguarding information
- Emotional or Behavioural Information
How we store the information securely:
All information stored and processed by GLAS ltd is stored in digital filing system on the professional computers of company staff. Only authorised staff have access to the password protected digital filing systems. Any information which is shared electronically with the organisations outlined in the information sharing part of this notice are password protected.
How we collect the information:
Contact details, Address and Date of Birth are supplied to us through the organisation responsible for your placement with us.
Education Health Care Plans (if in place) are collected and viewed from your school or provisions you attend.
Safeguarding information can be collected either directly from you or observations by members of staff or can be collected from other sources who may be aware of an issue concerning your emotional or physical safety. This information is also gathered from regular staff meetings and routinely discussed by the appropriate staff and recorded in the minutes of the meeting.
Emotional, Well-being and Behavioural Information may be collected from the organisation responsible for arranging your placement with us and by observation while in attendance or directly from yourselves during our conversations with you.
The reason why we collect this information about you and what we do or might do with it:
Contact details, Address and Date of Birth are collected for the purpose of communication and to enable GLAS ltd to organise age appropriate interventions.
Education Health Care Plans (if in place) are viewed in order for us to know how we can help you with your individual situation.
Safeguarding information (if it becomes necessary) would be used to engage other professionals who are in a position to support and protect you. Should there ever be a need for an intervention through children’s services this information would be used to inform that process.
Emotional, Well-being and Behavioural Information. Is gathered to ensure that your progress while working with us is based around your needs as they arise and to identify any extra help that you may need.
The lawful basis for collecting this information:
Under the General Data Protection Regulations, we must provide at least one lawful basis for processing any data (see our data protection policy on our web site for a list of these and what they mean)
Contact details, Address and Date of Birth – Legitimate interest and Legal obligation
Education Health Care Plans (if in place) – Legitimate interest
Safeguarding information – legal obligation, Vital Interests, Legitimate interest, contract
Emotional, Well-being and Behavioural Information – Legitimate interest
The legitimate interest for the processing:
Contact details, Address and Date of Birth it is in the legitimate interest of the parents/carers and the young people that we work with to remain contactable for a variety of reasons. We need to be able to communicate progress and arrange meetings throughout the time you are working with us. As well as to communicate any issues that arise during this time.
Education Health Care Plans (if in place) It is within the legitimate interests of the young people and families that we work with, that we are aware of the details of any EHCP which may be in place and that we refer to the document when configuring the individual package for you. It is within the legitimate interest of the company to deliver an effective service to you.
Safeguarding information: – It is a legal obligation under section 11 of the children’s act 2004 that safeguarding procedures are adequate and are discussed regularly during company meetings and recorded. It is a legitimate interest of the company that safeguarding is consistently monitored for its services to be delivered effectively. It is in the legitimate interest and/or vital interest of the young people and their parent carers that we work with that safeguarding is closely monitored and recorded in respect of their right to be in a safe environment, and for the monitoring of their emotional and physical wellbeing and, for us to act when necessary to protect those interest.
It is within the legitimate interests of the company to ensure that students are in attendance when expected in the performance of our duties related to safeguarding responsibilities.
Emotional or Behavioural Information: is collected for the legitimate interest of well-being of the young people we work with. Also, it is in the legitimate interest of the company to assist in making a decision on the suitability of an intervention and to individualise the help we can offer young people who have emotional and behavioural difficulties.
Who we (GLAS Ltd) share the information with:
Contact details, Address and Date of Birth will be shared with other agencies who may become involved with the support which GLAS Ltd can offer. In the case of a serious safeguarding issues or if a crime is committed by or against a student this information will have to be shared with the police and the local authority responsible for safeguarding.
Education Health Care Plans (if in place) will not be shared with anyone by GLAS Ltd
Safeguarding information will be shared with the organisation responsible for the student’s placement, in most cases with the parents or carers of the students, the local authority department responsible for safeguarding, in some cases with the police (for issues classed as a crime) and where necessary with social workers if their involvement becomes necessary. This information could also be shared as part of a multi-agency intervention where necessary (in this case you will be informed of the identity of the organisations involved and in most cases, will be consulted prior to engagement).
Emotional or Behavioural Information is shared with the organisation responsible for your placement. Depending on the impact of the situation this may be shared as part of a safeguarding concern (see safeguarding information above). If appropriate some or all of this information may be shared with parent carers (this is not always the case).
How long we keep the information:
Contact details, Address and Date of Birth is kept for 1 year after the student leaves the provision.
Education Health Care Plans (if in place) are not kept by GLAS ltd and remain in the possession of the school or provision you are registered with.
Safeguarding information – in the form of referrals are kept until the student leaves the provision. Information in the form of meeting recorded discussions is Kept for 1 year and 1 month from the time it is recorded.
Emotional or Behavioural Information is kept in the form of meeting recorded discussions for 1 year and 1 month after the time it is recorded. In session reports the information is kept for 1 year after the young person has finished working with us.
Your rights: Under the General Data Protection Regulations:
The following details outline your rights under the ‘GENERAL DATA PROTECTION REGULATION’. If you wish to act on these rights please put your request in writing to us with your contact details and the nature of the request and we will contact you to discuss the matter. Our contact details are at the end of this privacy notice.
The right to be informed;
|You have the right to be informed about the data we hold and process about you which is why we produce this privacy notice.|
|The right of access;
|In most cases you have the right to access the data we hold about you. All you need to do is put your request in writing and we have 30 days to respond.|
|The right to rectification;
|· If it is found that the information we hold about you is wrong in some way you have the right to have this corrected. All you need to do is put your issue in writing to us and we will correct the problem.|
|The right to erasure;
|In some case’s you have the right to have your data completely removed from any place where it is held. This does not apply when ‘legitimate interest’ is the lawful bases for processing but it does apply when the data is scheduled to be destroyed.|
|The right to restrict processing;
|Article 18 of the GDPR gives individuals the right to restrict the processing of their personal data in certain circumstances.|
|The right to data portability;
|· In some case’s the right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services. Relevant provision = articles 13,20 and recital 68|
|The right to object||Article 21 of the GDPR gives individuals the right to object to the processing of their personal data. This effectively allows you to ask us to stop processing your personal data. This applies when consent is the lawful basis for processing the data.|
|The right not to be subject to automated decision-making including profiling.
|Individuals have the right not to be subject to a decision when:
· it is based on automated processing; and
· it produces an adverse legal effect or a significantly affects the individual.
This is not the cases with any data processed by GLAS ltd
Details of statutory obligation: The work carried out by GLAS Ltd is by consent of the student and/or the parent carers of the student. Some of the data we process is necessary for us to carry out the legitimate interests of the student, the company and the organisation responsible for the placement with us. Some data is processed as a legal obligation and some for the vital interests of the student’s well-being also.
|GLAS Ltd||Information Commissioners Office|
|Information Commissioner’s Office
SK9 5AFTel: 0303 123 1113 (local rate)
01625 545 745 if you prefer to use a national rate number