1. Introduction

This website is one of the services provided by Coventry, Solihull and Warwickshire Partnership (CSWP) Ltd. CSWP Ltd is registered as a ‘data controller’ under the Data Protection Act 1998 because we collect, hold and process personal information about our customers.

This Privacy Policy explains why we keep information about you, what we do with the information and who we might share it with. It also explains your rights under current UK law and what you should do if you have any concerns.

2. Why do we keep information about you?

We need to collect, hold and process information about you in order to:

1. confirm your identity and keep in touch with you by post, fax, e-mail, text message or telephone.
2. understand your needs and inform you of relevant services we offer.
3. deliver one or more agreed services to you.
4. share information with selected agencies who work with us to deliver service.
5. update your client record.
6. obtain your opinion about the services you receive.
7. process financial transactions related to the services you receive, such as grants or payments.
8. build up a picture of how well we deliver services and what services might be needed in the future.
9. prevent and detect fraud and corruption in the use of public funds.
10. meet our statutory obligations including those related to equality and diversity

3. What information do we keep about you?

There are two types of information that we might need:

1. Personal Information – such as your name, date of birth, gender, contact details, unique customer reference number, notes about the services you have received, details of your current situation with regard to education, training or employment, your qualifications and your future career aspirations.
2. Sensitive Personal Information – such as your racial or ethnic origin, physical or mental health, sexual life, criminal record and court proceedings, religious beliefs and details of other agencies that currently supply help and support to you of a sensitive nature.

Our aim is to be unobtrusive, and we will never ask unnecessary questions beyond those needed to provide the service you are receiving. Information may be collected using paper forms, on-line forms, faxes, e-mails, telephone conversations, text messages or image/audio recording devices. Information may be provided by yourself or by your parent/guardian/carer, or may be passed to us from another agency working with you.

In many situations notes will be taken during, or shortly following, meetings with you, where such notes are necessary to maintain a proper record of the service we provide. Such notes will form part of the personal information that we hold, process and share about you.

We may not be able to provide you with a full service unless we hold adequate information about you, and have your permission to use that information in the ways that we need to.

4. What do we do with your information?

We use your information to help us understand your circumstances so that we can provide a better service to you. We will only use the information in ways that comply with the Data Protection Act. We will not keep your information longer than is necessary.

Access to your information will be on a need-to-know basis and limited to our own staff or staff at agencies that work with us to provide the service. We will endeavour to keep your information accurate, up-to-date and secure at all times.

We may supply your information to a third party ‘data processor’ that we engage to process information on our behalf. In this situation the data processor operates under our control and meets standards of confidentiality and security that we set and audit.

Sometimes we aggregate your information with that of other clients in order to produce reports and statistical analysis. In this format your information becomes de-personalised and can’t be traced back to you individually.

5. How do we protect your information?

We maintain a high standard of physical and network security designed to protect the paper or electronic systems that we use to hold and process your personal information.

The information we hold about you will be subject to rigorous safeguards to make sure it isn’t shown, accessed or disclosed in ways that are not appropriate. We also take steps to ensure that your information doesn’t become damaged or rendered unavailable to those who have a right and need to see it.

We follow agreed information security policies and provide training to staff involved in processing personal information about you. We treat it as a disciplinary matter if your personal information is misused or not looked after properly.

Where we need to transfer information over the Internet - for example as an e-mail attachment - we will protect it using appropriate measures, such as data encryption technology.

We will dispose of paper records, and delete electronic information, in secure ways that ensure the information can’t be recreated.

6. When might we share your information?

We may need to share some of your information with agencies that work with us to deliver the service to you. The agencies we work with are obliged to keep your personal information secure, and to use the information only to fulfil specific purposes. If we need to share personal information about you, we will first seek your consent to do so. We will seek your explicit consent before we share any sensitive personal information about you.

When we do pass on personal information we will first check, where possible, that sufficient steps have been taken by the recipient to protect the information.

In some circumstances we may have to share personal information about you – including sensitive personal information – without your consent or knowledge. This will only be done when there is a legal obligation for us to do so – for example where the disclosure is necessary for the prevention and/or detection of crime or to prevent a risk of harm to yourself or someone else.

7. How do we handle telephone calls and e-mails?

Ordinarily we will inform you if we record or monitor any telephone calls you make to us. Recording and monitoring will be used to increase your security, for our record keeping of the transaction and for staff training purposes.

If you e-mail us we may keep a record of your contact, your e-mail address and the e-mail text for our record keeping. For security reasons we minimise any confidential information in e-mails we send to you. We suggest that you also minimise the amount of confidential information you send to us via e-mail.

8. What happens when you use our websites?

We operate different websites in support of the services we deliver. Most of our websites are available to all users without any requirement for a log-in account. This type of website does not store or capture personal information, but does record a unique number called your ‘IP address’ which is automatically recognised by the system during your visit or when you return.

Our public websites will only record personal information if you:

1. subscribe to or apply for services that require personal information
2. report a fault and give your contact details for us to respond
3. contact us and leave your details for us to respond.

We may employ cookie technology to help log visitors to our websites. A cookie is a string of information that is sent by a website and stored on your hard drive or temporarily in your computer's memory. The information collected is used for the administration of the server and to improve the service provided by the website. No personal information is collected in this way. You can reject the use of cookies, but if you do so some parts of our websites may not function as intended – or you may be asked to repeat information that you had previously provided.

Some of our websites require that you have a log-in account to access personalised areas and features. Any information you provide – either at our request or at your own discretion (such as a post you choose to make in a forum) – will therefore be linked to your personal account. Some of this information will be viewable by others (such as when other account holders read your post in the forum). You must take personal responsibility for any personal information about yourself that you choose to reveal in this way. You must also keep your log-in details secret and secure.

These statements only covers those websites maintained by us and does not extend to external websites that we may link to.

9. Do we use CCTV or other recording devices?

We have installed CCTV systems at some of our locations used by members of the public. This is solely for the purposes of public safety and crime prevention/detection. Signs are displayed in all locations notifying you that CCTV is in operation and explaining who to contact for further information. None of our CCTV systems record audio – so your private conversations can’t be recorded.

We will only disclose CCTV images to others to meet the purposes stated above. CCTV images will not be released to the media for entertainment purposes or placed on the internet.

Images captured by CCTV will not be kept for longer than is necessary. However, on occasions we may hold images longer than normal - for example where a crime is being investigated or there is a statutory obligation on us to do so.

You have the right to see CCTV images of yourself and be provided with a copy of the images we currently retain, where practicable.

CSWP sometimes delivers projects that make use of creative digital technologies – such as digital photography and video/audio recordings. If the service we deliver to you involves this type of recording, you will be advised in advance about your rights relating to any personal information that may be captured as a result.· In general, we will require you to sign a ‘release form’ covering images and audio in which you appear.

10. What are your rights?

You have the right to withdraw your consent and request that we stop processing your personal information in relation to any services we deliver to you. However, this may cause delays or prevent us delivering a full service. Where possible, we will seek to comply with your request, but we may be required to continue holding or processing information to comply with a legal requirement placed on us.

You have the right to request a copy of any personal information that we currently hold about you. We try to ensure that any information we hold about you is correct. There may be situations where you find the information we hold is no longer accurate and you have the right to have this corrected.