Under the UK-GDPR (Data Protection Act 2018), individuals have a right to be informed about how Cedar uses any personal data that we hold about them. We comply with this right by providing ‘privacy notices’ to individuals where we are processing their personal data.

This privacy notice explains how we collect, store and use personal data about young people and their parents/carers.

We, The Cedar Foundation, are the ‘data controller’ for the purposes of data protection law.

The personal data we hold

Personal data that we may collect, use, store and share (when appropriate) about young people who access are services includes, but is not restricted to:

 

• Contact details, contact preferences, date of birth
• Results of assessments
• Characteristics, such as disability, ethnic background
• Details of any medical conditions, including physical and mental health
• Safeguarding information
• Records of support provided, including plans and risk assessments
• Records of contact with other professionals
• Review reports
• Photographs
• Video footage from events/activities

 

We may also hold data about pupils that we have received from other organisations, including other Health & Social Care Trusts or schools.  We will normally hold a referral form for each young person.

Personal data that we may collect, use, store and share (when appropriate) about parents/carers includes, but is not restricted to:

• Contact details and contact preferences
• Family Links
• Parental/Carer details
• Information you share with us

Why we use this data

We use this data to:

 

• Contact Parents/Carers to support their child
• Support child/young person to achieve their goals
• Monitor and report on progress
• Provide appropriate support
• Protect welfare of the young person
• Assess the quality of our services
• Administer waiting lists
• Carry out research
• Comply with the law regarding data sharing

 

Our legal basis for using this data

We only collect and use young people’s and parent/carer personal data when the law allows us to. Most commonly, we process it where:

 

• We have a ‘legitimate interest’ to do so (to help us deliver an effective service)

We may also process the young person’s personal data in situations where:

• We have obtained consent to use it in a certain way
• We need to protect the individual’s vital interests (or someone else’s interests)

Where we have obtained consent to use personal data, this consent can be withdrawn at any time. We will make this clear when we ask for consent, and explain how consent can be withdrawn.  This normally applies to our use of photos, videos and for any publicity/social media coverage.

Some of the reasons listed above for collecting and using the personal data of the young person overlap, and there may be several grounds which justify our use of this data.

Collecting this information

While the majority of information we collect about young people is mandatory, there is some information that can be provided voluntarily.

Whenever we seek to collect information from you or your child, we make it clear whether providing it is mandatory or optional. If it is mandatory, we will explain the possible consequences of not complying.

 

How we store this data

We keep personal information about young people while they are attending our service. We also need to keep it beyond them completing our service to comply with any legal requirements and also our requirement to have adequate insurance. 

We aim to keep your data safe and secure and ensure that anyone we share your information with also meets our data security requirements. Our record retention schedule sets out how long we keep information about young people. It is a currently requirement of our insurance cover terms & conditions that we normally keep records of the service we provided to children and young people for 30 years.

 

Records Management Database (iplanit)

We do not hold any paper records.  All our service records are stored electronically either on our server or on our information management system, iplanit.  Both these systems are secure electronic data management platforms and with access only available to authorised users with both passwords required and multi-factor authentication in place.  Aspirico (the company that manages iplanit) is fully ISO27001 certified to help ensure data is completely secure.

For more information, see iplanit FAQ | You Ask, We Answer | Aspirico

 

Data sharing

We do not share information about young people or parents/carers with any third party without consent unless the law and our policies allow us to do so.

Where it is legally required, or necessary (and it complies with data protection law) we may share personal information about young people or parents/carers with:

• The local Health & Social Care Trust (HSCT)– to meet our legal obligations to share certain information with it, such as safeguarding concerns and exclusions
• The HSCT or Department for Education – for statutory data returns
• Our regulator, RQIA, where relevant to the service
• Suppliers and service providers – to enable them to provide the service we have contracted them for
• Our auditors - to assist them discharging their legal duties
• Professional advisers and consultants – were they are supporting service improvement
• PSNI, courts, tribunals – to assist them discharging their legal duties

 

Transferring data internationally

Where we transfer personal data to a country or territory outside the European Economic Area, we will do so in accordance with data protection law.

 

Parents/carers and young person’s rights regarding personal data

Parents/carers have a legal right to access their child’s service records.  Individuals also have a right to make a ‘subject access request’ to gain access to personal information that Cedar holds about them.

Parents/carers can make a request with respect to their child’s data where the child is not considered mature enough to understand their rights over their own data (usually under the age of 12), or where the child has provided consent.

Parents also have the right to make a subject access request with respect to any personal data we hold about them.

If you make a subject access request, and if we do hold information about you or your child, we will:

 

• Give you a description of it
• Tell you why we are holding and processing it, and how long we will keep it for
• Explain where we got it from, if not from you or your child
• Tell you who it has been, or will be, shared with
• Let you know whether any automated decision-making is being applied to the data, and any consequences of this
• Give you a copy of the information in an intelligible form

Individuals also have the right for their personal information to be transmitted electronically to another organisation in certain circumstances.

If you would like any information please ask a member of the office team, or email our Data Protection Officer at [email protected]

 

Other rights

Under data protection law, individuals have certain rights regarding how their personal data is used and kept safe, including the right to:

• Object to the use of personal data if it would cause, or is causing, damage or distress
• Prevent it being used to send direct marketing
• Object to decisions being taken by automated means (by a computer or machine, rather than by a person)
• In certain circumstances, have inaccurate personal data corrected, deleted or destroyed, or restrict processing
• Claim compensation for damages caused by a breach of the data protection regulations

 

To exercise any of these rights, please contact our Data Protection Officer.

If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please speak to your Cedar keyworker, service manager, or email our Data Protection Officer [email protected]

Complaints

We take any complaints about our collection and use of personal information very seriously.  If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

To make a complaint, please contact our Data Protection Officer at email address above.

Alternatively, you can make a complaint to the Information Commissioner’s Office:

 

• Report a concern online at https://ico.org.uk/concerns/
• Call 0303 123 1113
• Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF