Privacy Statement

Healthy Minds (Calderdale Wellbeing) Privacy Policy
This notice explains how we collect and use your personal information.
Calderdale Wellbeing (operating as Healthy Minds) is registered as a ‘data controller’ with the Information Commissioner’s Office under the Data Protection Act. Registration reference: ZA004695. You can find out more about the Data Protection Act, and your legal rights at https://ico.org.uk
We collect and process your information in order to provide services to you and for keeping you up to date with what we’re doing by newsletter and periodic email / text communications.

The type of personal information we collect
Personal information is any information that can be used to identify a living person.
We currently collect and process the following information:

Your name Contact details: home address, telephone number, email address
Date of birth
Emergency contact: the person you agree for us to contact if there is an emergency. We collect their name and telephone number.

The Link service also collects NHS numbers

The Welfare Rights service may also need to keep relevant paperwork, such as letters and medical reports, so that we can provide suitable advice and support for your case until it reaches a conclusion.

We may also keep records about the contact you have with our services, for example:

Why you have contacted us (e.g. support needs)

Details of the advice / support we have given

Wellbeing measures that show what difference support is making

We also ask you to give us information relating to the Equality Act 2010 ‘protected characteristics’:

disability

gender reassignment

pregnancy and maternity

race

religion or belief

sexual orientation

This information is requested so that we can check how accessible our services are for everyone. You do not have to give these details but, if you do, they will be stored alongside your personal information.

“Special Category” Data
Details of race, religion, sexual orientation and health are classed as “special category data”. We collect and process this information under Article 9 of the UK GDPR, with the condition of (a) Explicit consent, as you can choose whether to provide this information.

Visiting our premises
We require visitors to sign in and out on arrival and exit for fire safety. The only information collected is your name. This does not have to be your full name. You consent to providing your name for this purpose, and our basis for collecting this information is our legal obligation for fire safety. Sign-in sheets are not retained and are disposed of within two weeks by shredding.

Using our websites
Healthy Minds’ website is: www.healthymindscalderdale.co.uk. Healthy Minds does not process personal information stored or captured through our site, but the hosting provider collates information through “cookies”:
Cookies are small text files that ‘remember’ bits of information from your visit to a website. This information is used to collect anonymous statistics about how many people have accessed the site, by what means (e.g. Google search) and how people use the site – for example, the pages viewed. The websites automatically generate a “cookie notice” that gives you more information and the choice not to allow the use of cookies.

How we get the personal information and why we have it
Most of the personal information we process is provided to us directly by you. We collect and process your information in order to provide services to you and for keeping you up to date with what we’re doing by newsletter and periodic email / text communications.
Personal information may be collected on paper or online / electronic forms, by phone, email or verbally by Healthy Minds staff / volunteers. You do not have to provide personal information to access most Healthy Minds’ services, but we will be able to provide a better service if you do.
We will only use your personal information for the purpose which we have stated when we collect it, and we will not collect unnecessary information about you. We will ensure your personal data is held securely and is not seen by anyone who has no legitimate purpose or authority to see it.
Where we need to pass on your information to other people and organisations that work with us to provide services, we will do so only with your prior explicit consent, or where we are required by law to do so – for example, where it is necessary for the prevention or detection of crime or to prevent risk of harm to an individual. This information may include sensitive or confidential information such as children’s data, financial data or health information. We will endeavour to ensure wherever possible that appropriate steps have been taken by the recipient to protect personal information that is shared.
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:
1: Your consent
Generally you will have provided us with personal information yourself and, therefore, consent to providing the information. You do not have to provide personal information in order to access most of Healthy Minds’ services but we will be able to provide a better service if you do.
You have the right to remove your consent at any time. You can do this by contacting us on the details at the end of this notice.
2: We have a legitimate interest
The information you provide enables us to provide services, including contacting you as necessary.
We are also required to report to funders about how many people access our services, what difference this achieves (e.g. wellbeing measures), and demographic information to demonstrate how well we reach all sections of the community. These reports are necessary so that we can continue to obtain funding to maintain the services we provide. Such reports are anonymised: no information that could identify any person is included in these reports.

How we store your personal information
Your information is securely stored in an electronic database to which only authorised Healthy Minds employees and authorised volunteers have access. If you provide information on a paper form, the details will be entered on the electronic database promptly and the paper record destroyed by shredding.
Healthy Minds employees and volunteers who have access to personal information are bound by our policies and procedures on confidentiality and data protection.
We have engaged an external provider (Actualised Living) to build and maintain our electronic recording system (Zone Standard). This arrangement is subject to a robust contract that includes data protection compliance and confidentiality. Further detail about this arrangement will be made available on request.

Retention
We keep personal information for as long as you are involved with services. To meet reporting requirements for services, as described in “legitimate interests” above, we may retain information for the lifetime of the service.
Data kept for administering membership and newsletter / communication distribution will be reviewed at least annually. We will ask you to confirm that you are happy to stay on the list and your information will be deleted if we do not have your confirmation.
If you made a formal complaint, we may retain information for up to six years as we may be required to provide an account of how complaints have been handled. We may also need to report on complaints as part of service contracts, as described in “legitimate interests” above.
You have the right to request that your personal information is removed at any time – see “Your data protection rights under GDPR” below.
Paper records are destroyed by shredding.
Electronic records by which you can be identified will be deleted fully from all electronic systems including the database, online storage systems and email folders.

Your data protection rights under GDPR
The General Data Protection Regulation 2018 includes the following rights:
The right to be informed.

Forms we use to collect your personal information will include a Privacy Notice explaining:

What the information is for, and the lawful basis for processing it
Whether the information will be shared and with whom
How long the information will be kept for (retention)
Your rights including the right to complain

The right of access.
You can request sight of the information that Healthy Minds holds about you.

The right to rectification.
You have the right to request that we correct any incorrect or inaccurate information held on our systems, such as wrong addresses, incorrect spellings etc.

The right to be forgotten (or right to erasure).
As long as the data is not required for a legal or safeguarding purpose, you have the right for your entry to be deleted from our systems at any time.

The right to restrict processing.
If you feel that we are acting upon incorrect or inaccurate information, you have the right to request that we restrict processing while we investigate your claim. This must be done and a decision made within a month. During this time no action or further processing can take place. Once a written decision is made and any inaccuracies documented and amended the processing can be re-commenced.

The right to data portability.
You can request that we provide electronically-held data to you in a format that you can give to someone else (like another service). This only applies to data that is already held in a portable format. Healthy Minds does not process in this way.

The right to object.
You can complain if you feel that your data rights have been incorrectly handled or breached.

The right not to be subject to automated decision-making including profiling.
Healthy Minds does not process data in this way but, if we were to, we must ensure that you provide explicit consent. You can request that a “human” make the decision and that the “automated” part is not utilised.

To exercise any of the above rights, or if you have any queries, please contact us on data@healthymindscalderdale or 01422 345154

Changes to this privacy notice
We will continually review and update this privacy notice to reflect changes in our services and feedback from service users, as well as to comply with the changes in the law.
Further information
Complaints about data protection or enquiries about this Privacy Notice should be sent to:
Chief Officer
Calderdale Wellbeing (Healthy Minds)
1 King Street
Halifax
HX1 1SR
Tel: 01422 345154
Email: [email protected]

You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data.
ICO Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk