How we respect privacy when we deal with personal information about individuals using our services
Please note, “we” and “us” in this statement refers to Brighton Oasis Project.
Privacy is a fundamental right. When you access one of our support services, Brighton Oasis Project will always prioritise your privacy and protect your personal data with the greatest possible care.
In this Privacy Statement we explain how we manage the personal data of people receiving support, why we request it, and what we use it for.
If you have any comments or questions about this statement, feel free to email us at email@example.com or write to us at 3 Globe House, Morley Street, Brighton BN2 9RA.
1. Which services and teams does this privacy notice cover?
Brighton Oasis Project supports people across Brighton & Hove and East Sussex. Services covered in this privacy notice include:
· Our adult treatment services in Brighton (as part of Pavilions)
· Young Oasis
· Sex Workers Outreach Project (SWOP)
· East Sussex Oasis Women’s Recovery Services
· Our Crèche
· Art of Attachment
· (note: Fulfilling Lives Eastbourne and Hastings are managed under the BHT Privacy Notice)
2. When do we collect your personal data?
We collect your information when you are seeking to access one of our services. This may be a different route for each service. In most cases we will collect information at three stages:
· When you are enquiring about a service, referring yourself, or a professional you know is completing a referral form on your behalf.
· When you meet with a worker from one of the services for the first time and they complete an initial assessment to decide if a service is suitable for you and to know how we can best support you.
· Whilst you are receiving a service from us we will keep records of how the support we offer is going.
3. What personal data do we collect?
Each service will require different information about you depending on the needs you have and the support offered. We will collect these types of data:
· Personal details about you, for example your age, your health, and safe ways to contact you
· Personal details about your family and living situation (if this is relevant to the support you receive)
· Details about what is happening or has happened to you
· Any risks that you or your family are experiencing
· Information about anyone else supporting you
· Information on whether our support to you is being helpful.
We will never collect more information than is required.
We will ensure that we always seek your consent for each piece of personal data we process. In most cases this will be written consent at an initial meeting with a service.
We are always happy to explain why we gather particular pieces of personal data.
4. How do we use your personal data?
Data we collect about you is used for the following purposes:
· To ensure we are offering you the best possible service and that each service is considering your individual strengths, difficulties and situation.
· To know who is accessing our services and what needs they have. This is to help us know if a service is being successful or to help us identify areas we could improve.
· To communicate with other professionals about you (with your permission) so that the support you receive is ‘joined up’.
· To ensure you and those around you are safeguarded and to communicate with safeguarding professionals if required.
· Anonymised information (information where you can’t be identified) is reported back to commissioners of services to ensure we are providing the service we are receiving funding for.
· Some of our services are research projects and will have specific needs for the purposes of research. This will always be made very clear at any initial contact with the service. We will never gather research data on a service user without their knowledge and consent.
5. When are we allowed to use your personal data?
A legal ground is necessary for processing personal data. Brighton Oasis Project collects and processes your personal data solely on the basis of the following legal grounds:
· Legitimate interest: As a Charity providing a range of important services to people, we are unable to offer an effective service without processing Personal and Sensitive (Special Category) data. As a charity with a number of funding streams, including grant payments, it is in our legitimate interest to supply potential and current funders with anonymised data relating to service use as part of our business plan.
· Compliance with legal obligations: Brighton Oasis Project has a legal duty to share information with other agencies where there is a legitimate safeguarding risk or to prevent a serious crime.
If you do not want Brighton Oasis Project to use your personal data for the above-mentioned purposes, you can make use of your right of objection as detailed below.
6. What rights do you have with respect to your personal data?
As a service user at Brighton Oasis Project, you have a number of rights with regards to data we hold about you:
· You have the right to access your personal data. You can therefore request to see data we hold on you. Please see our policy on this.
· You have the right to correct your personal data if it has been processed incorrectly or incompletely.
· You have the right to object to the processing of your personal data. Where possible we will endeavour to continue to offer you a service but it may be that we decide we cannot without certain information about you. A manager from one of our services can discuss this with you.
· You have the right to ask us to erase your personal data so that we have no record of you. Please see our policy on this.
If you wish to make use of any of the above-mentioned rights, you may inform us by any means, though for clarity it would be helpful if you complete the following Data Request form.
7. With whom do we share your personal data?
We will share data with supporting organisations that you identify as being helpful to you. You may decide there are organisations you do not want us to share personal data with. This is something we will regularly check-in with about you and we will never share without your prior knowledge.
We do not share data about you with other services users.
We do not share data about you with members of the public.
On some occasions Brighton Oasis Project will need to share personal data about you for the purposes of safeguarding or preventing a crime. In most cases we will do this in partnership with you.
Brighton Oasis Project ensures that data is shared with the utmost care using secure systems.
8. How long do we store your personal data?
Each service in Brighton Oasis Project will have different rules around storage, depending on the service offered and the duration of that service. As a baseline, Brighton Oasis Project retains data for 5 years after you have stopped receiving a service.
9. How safe is your data at Brighton Oasis Project?
Each Service takes suitable technical and administrative measures to protect your personal data against loss and against any form of unlawful processing. We store your personal data on servers in a secure environment that provides protection against unlawful access, publication and use of the data by unauthorised persons inside or outside the organisation.
Paper-based recording is kept to a minimum and paper forms are usually scanned onto a secure system.
All Brighton Oasis Staff are trained in Data Protection, and Privacy By Design ensures that Data Security is considered at the beginning of all project developments.
Brighton Oasis Project has a Senior Information Risk Advisor sitting on the Board of Trustees with overall responsibility for data security.
10. Do you have questions about privacy within Brighton Oasis Project, or do you have a complaint?
Brighton Oasis Project operates a transparent and inclusive policy around queries and complaints. All complaints and queries will go to an appointed Data Protection Officer whose role it is to ensure the organisation is doing its utmost to care for your data.
If you feel that Brighton Oasis Project has been responsible for a Data Breach (where data has not been held safely) you may either notify us as a complaint or notify the Information Commissioner’s Office.
If Brighton Oasis Project is concerned there is a Data Breach we are obliged to notify to Information Commissioner’s Office for them to investigate.
As an inclusive organisation Brighton Oasis Project will seek to gather data on equalities. This data will be anonymised so that we can track levels of diversity and ensure no communities or groups of people are excluded from our services.
This statement was last updated August 2018.