Integra Community Living Options aims to adhere to the General Data Protection Regulations (GDPR) relating to the processing of personal data in manual and electronic records. Personal data is information that relates to an identifiable person who can be directly or indirectly identified from that information. It may include information containing religious beliefs, an individual’s racial or ethnic origin, political opinions, trade union membership, physical or mental health, sexual orientation and criminal records.
Our commitment requires that personal data must be processed in line with the data protection principles required by the Data Protection Act 1998:
- be processed fairly, lawfully and in a transparent manner;
- be processed for limited purposes and not in any manner incompatible with those purposes;
- be adequate, relevant and limited to what is necessary for the purposes of processing;
- be accurate and up to date. Every reasonable effort will be made to ensure that inaccurate data is rectified or erased without delay;
- not be kept for longer than is necessary for its given purpose;
- be processed in accordance with individuals’ rights
- be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures;
- will comply with the relevant GDPR procedures for international transferring of personal data. This includes where third parties process data on behalf of Integra.
How we collect personal information
We collect personal information from you: through your contact with us, including by phone, by email, through our website, by post, by filling in application or other forms, or face-to-face (for example, all our clients have a Mental Health Care Operational Plan which details their diagnosis and treatment).
For all our clients, we may collect information also from:
- doctors, psychologists, nurses, occupational therapists and other clinicians and healthcare professionals, hospitals, clinics and other health or social care providers;
- any service providers, professionals or statutory services who work with you and/or us in relation to your care, support, finances and/or accommodation, such as those providing you with medical treatment, dental treatment or health assessments, lawyers or local authority officers;
- a family member, advocate, or someone else acting on your behalf
Categories of Personal Information
We process two categories of personal information about you:
- standard personal information (for example, information we use to contact you, identify you or manage our relationship with you such as your name, address, contract details, age, date of birth and identifiers – such as your national insurance number, details of contact or involvement we have had with you – including any complaints or incidents, financial details, information about how you use or liaise with our services and/or website);
- special categories of information (for example, physical and mental health information, information about your actions and behaviours, race, ethnic origin, religion and beliefs, criminal convictions, sexual orientation, sex life, cautions and offending history that allows us to support you as effectively as possible) .
Special Category information may be obtained from:
- meetings with you;
- your Mental Health Care Operational plan that you have filled in;
- notes and reports about your health and any treatment and care you have received or need;
- details of contact we have had with you such as information about complaints or incidents;
- referrals from clinical teams and local authorities, quotes and records of medical services you have received;
- your medical preferences to allow us to provide care that is tailored to your needs;
- information shared with us by other professionals and/or statutory services
What do we use your personal information for?
By law, we must have a lawful reason for processing your personal information. We process standard personal information about you if this is:
- necessary to provide the services set out in a contract − if we have a contract with you, we will process your personal information in order to fulfil that contract (that is, to provide you with our services);
- in our, or a third party’s, legitimate interests including that of public interest (and your own fundamental rights do not override those interests);
- required, or allowed, by law or statutory guidance.
We process special category information about you because:
- it is necessary for the purposes of preventing or detecting an unlawful act in circumstances where we must carry out checks without your permission so as not to affect the outcome of those checks;
- it is necessary for a purpose designed to protect the public against seriously improper behaviour (for example, investigations in response to a safeguarding concern, a complaint or a regulator (such as the Care Inspectorate Wales) telling us about an issue); or
- we have your permission. Permission will only be asked for to process your personal information if there is no other legal reason to process it. When we ask for your permission, we will be clear that we are asking for, and ask you to confirm your choice to give us that permission. If we cannot provide a service without your permission, we will make this clear when we ask for your permission. If you later withdraw your permission, we will no longer be able to provide you with a service that relies on having your permission.
Data Storage and Transfer
Information we collect will be stored within the UK or European Union for the purposes of supplying our services. By submitting your personal data, you agree to this transfer, storing and processing. We will take reasonable steps to ensure that your data remains secure and is handled in accordance with this privacy notice.
- All manual files holding personal data are securely held in locked offices or cupboards. • Computerised records have passwords and laptops are encrypted
- All forms of data transfer are approved by our Management Team
Marketing and Preferences
Your personal information may be used by us to send you marketing by post, by phone and by email. We can only use your personal information to send you marketing material if we have your permission. If you don’t want to receive emails from us, you can contact us to unsubscribe. When we send you marketing information, it is because we believe it is necessary for our legitimate interests (informing you about potential services or events that may be of interest to you).
You have the right to object to direct marketing. Please see the section about your rights for more details.
Sharing your Information
We sometimes need to share your information with other people or organisations for the purposes set out in this privacy notice.
For all our clients, we share your information with:
- doctors, clinicians and other health-care professionals, social workers, hospitals, clinics, referrers, commissioners and other health/social care providers;
- other companies within the Unified Resources Group (of which Integra Community Living Options is a subsidiary)
- suppliers and partners who help deliver services on our or your behalf;
- people or organisations we have to, or are allowed to, share your personal information with by law (for example, for safeguarding purposes, including with Care Inspectorate Wales);
- the police and other law-enforcement agencies to help them perform their duties, or with others if we have to do this by law or under a court order;
- if we consider a potential transaction to develop the scale of services provided by the company (e.g. buying any business or assets), the potential buyer or seller, and any relevant supporting advisers in that process.
If we share your personal information, we will make sure appropriate protection is in place to protect your personal information in line with data-protection laws. This includes requesting that third parties only process your personal information based on our instructions and only following where they have agreed to keep your information confidential and secure.
Integra will take reasonable steps to make sure that, when we transfer your personal information to another country, appropriate protection is in place, in line with data-protection laws. Some or all of your data may be stored outside of the European Economic Area (“EEA”). You are deemed to agree to this by sharing information with us. Often, this protection is set out under a contract with the organisation who receives that information.
How long do we keep your Personal Information?
Integra will keep your personal information generally for as long as is necessary to fulfil the purposes for which it has been processed and also taking into account requirements based on the following criteria.
- The nature of the relationship you have with us and when that relationship ceases
- The length of time required to keep records to show we have met the obligations we have to you and as are required by law.
- Any periods which are set by law or recommended by regulators, professional bodies, insurance underwriters or associations.
- Any relevant legal proceedings that apply
You have the right to access your information and to ask us to correct any mistakes, delete or restrict the use of your information. You also have the right to object to us using your information, to ask us to transfer information you have provided, to withdraw permission you have given us to use your information and to ask us not to use automated decision-making which will affect you. For more information, see below.
You have the following rights (certain exceptions apply):
- Right of access: the right to make a written request for details of your personal information and a copy of that personal information
- Right to rectification: the right to have inaccurate information about you corrected or removed
- Right to erasure ('right to be forgotten'): the right to have certain personal information about you erased
- Right to restriction of processing: the right to request that your personal information is only used for restricted purposes
- Right to object: the right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests
- Right to data portability: the right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable formats
- Right to withdraw consent: you have the right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of Integra’s use of your personal information prior to the withdrawal of your consent and we will let you know if we will no longer be able to provide you with your chosen service.
Other than your right to object to the use of your data for direct marketing, your rights are not absolute: they do not always apply in all cases and we will let you know in our correspondence with you the extent to which we will, and if so, how we will, be able to comply with your request.
In relation to your right of access, Integra will consider the extent to which there is an exemption permitted under legal guidance including:
- Health and social work data – for instance if there would be serious harm to the physical or mental health of an individual
- References – these are confidentially given in relation to an employee’s employment
- Management information – personal data relating to forecasting and planning activities
- Legal advice – personal data covered by legal privilege
Integra will consider all requests relating to personal data and potential exemptions arising, on a case by case basis – in accordance with this privacy notice, our policy with regard to data protection, contractual requirements, professional advice and guidance publicly available from the Information Commissioner’s Office.
If you make a request, we will ask you to confirm your identity if we need to, and to provide information that helps us to understand your request better. If we do not meet your request, we will explain why.
Data Protection Contact
Integra has an appointed Data Protection Officer, Andrea O’Loughlin, who can be contacted in Integra’s central support office at the Maltings in Cardiff if you have any questions regarding our Privacy Notice or a complaint about a data breach.
If you are unsatisfied with the outcome, please share this with Integra by contacting Peter Max, the Managing Director. You may, at any stage, refer any complaint to the Information Commissioner’s Office (www.ico.org.uk to download personal complaints form) by email firstname.lastname@example.org or by post:
Information Commissioner's Office
Wycliffe House Water Lane