What is the purpose of this privacy notice?
Under data protection legislation we are required to explain why we collect information about you, how we intend to use that information and whether we will share this information with anyone else. This notice applies to people who are currently engaging, or have previously engaged, with the Young Greenwich Partnership.
It is important that you read this statement so that you know how and why we collect and use your personal information. It is important that you inform us of any changes to your personal information (such as your contact details) we hold about you so that the information which we hold is accurate and current.
Key Points:
Why we use your personal data
We typically use your personal information (including special categories of personal data such as your health, sexuality, gender identity or disabilities) to help you to engage with the support services we offer.
Who else has access to your personal data?
To provide you with the care, treatment and support you need, we may share your personal information with third parties, such as other public sector organisations and third-party service providers.
Security of your personal data
We respect the security of your data and treat it in accordance with the law.
Transferring your data internationally
We do not process your personal data outside of the UK but may transfer your personal data outside of the UK where necessary for you to engage with a third party service provider or where you have consented for us to do so.
Introduction
The Young Greenwich Partnership (“Young Greenwich”) is committed to respecting any data you share with us, keeping it safe and only using it in legitimate ways, Young Greenwich takes your privacy seriously. The Young Greenwich Partnership is made up of:
We work together to provide an integrated service, to support the wellbeing, development and safeguarding of young people, their parents, and carers. We are joint data controllers of the information we hold and share about you. This notice outlines the use of personal data under the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR). Any enquiry regarding the collection and processing of your data should be made in writing to the Partnership’s Data Protection Officers at:
Oxleas NHS Foundation Trust oxl-tr.dpo@nhs.net
Charlton Athletic Community Trust (CACT) dataprotection@cact.org.uk
METRO Charity informationgovernance@metrocharity.org.uk
What is personal data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone, or in conjunction with any other information in the data controller’s possession, or likely to come into their possession.
Where we collect information
Young Greenwich will collect information about you in several ways, including when you provide it to us directly by filling in forms, over the telephone, face to face or on our website, including but not limited to when you:
Complete a Health and Wellbeing questionnaire, which includes registration
Request specific information that requires us to take your details
Attend an event, as you will be required to register
Sign up for online services (e.g. free condom programme, Chlamydia screening)
Register with Young Greenwich of any one of the partners
We may also collect information from the partners individually, where you have undertaken a service provided by one of the partners, in order to measure your progress.
Where we are delivering services to you, providing you with information about our work or where you are participating in one of our programmes, we may ask you for more information. This could include information about your health.
What personal data do we collect?
We may collect personal data (including special categories of personal data where appropriate) which includes the following:
Name
Address
Email address
Telephone number
Date of birth
Education information
Equal Opportunities information including: age, disability, ethnicity, gender identity, marital status, religion, sexual orientation
Images which include video/CCTV footage and photographs
Current activities and interests
Your engagement with any of our services, including how engagement is progressing
Any information you provide to us as part of a complaint, concern or compliment you may have about the services we are offering and providing
Depending on the service, event, or activity you are accessing, we may also collect information about:
Your health
Any special educational needs or disability you tell us about
Courses and events booked and attended
How and why do we use your personal data?
We must have a “lawful basis” to collect and use information about you, which are set out in the data protection legislation. We use the information you provide to us for the following purposes and on the following “lawful bases”.
Why we use your information:
To evaluate the information, you provide in a health and wellbeing form, or a referral from a third-party organisation, and to offer you an appropriate service based on that information
For evaluation, monitoring and service co-ordination purposes
To update the partnership in terms of your progress and engagement, where you have engaged with a service offered by one of the partners.
Note that where a partner is providing you with a service, that partner is doing so independently of the Young Greenwich Partnership, and will be processing your information as a sole data controller. The rest of the partnership will only be provided with limited information about your engagement with that service.
To provide you with any information you request
For safeguarding purposes, where we are concerned about the information you have provided to us, we may need to share that information with a third party, such as social services, the police or the emergency services
For the onward referral and treatment of sexually transmitted infections
To register your details for a course or event you have applied for
To process booking or payment details for a course or event you have registered for
To keep you up to date with our work (if you would like us to)
To tell your story, to help us promote our work
To promote activities you may be included in on social media platforms and in the form of blogs, newsletters, videos and photos.
To look into and respond to complaints
To create a profile of your interests and preferences. We do this to help us determine whether and in what ways you might be interested in helping us or getting involved in our activities
For security purposes, where you have accessed the premises of one of the partners, we may need to capture CCTV images of you, or ask you to sign in and out of the building, to ensure your safety and the safety of our staff and others
What are the lawful bases for using your personal data?
The lawful bases for one or more of the above uses are as follows:
Upon registering for Young Greenwich, consent is given (by a parent if a young person is under 16, or by a young person if over 16) for Young Greenwich to collect data to: share between the partners to safeguard participants, and for monitoring and evaluation purposes, to fulfil our contractual obligations.
Upon referral to a service, explicit consent is obtained (by a parent if a young person is under 16, or by a young person if over 16, or via the Fraser Guidelines) which allows Young Greenwich to complete the referral (to a Young Greenwich partner organisation) and carry out that specific service.
Official authority: where we have a duty, set out in law, to safeguard you.
Legal obligation: Where we have a legal or regulatory obligation
Health and social care: In the provision of health or social care or treatment, where this relates to special category personal data, such as information about your health
Contract: We will essentially be performing a ‘contract’ with you, at your request
Contract: As part of our contract with you, and in order for you to attend a course or event, we may need to process booking or payment details
Legitimate interests: It is in our legitimate interests to ensure the safety of everyone accessing our premises, and these interests are not overridden by your rights
How we keep your data safe and who has access to it?
Young Greenwich Partnership will only collect and store the personal data that we need and will store this in line with legislation and the Partnerships Data Retention Policy.
Young Greenwich will not retain personal data longer than is necessary and will only hold the data for compliance purposes and to meet our contractual obligations. For example, we will hold data from the registration forms for as long as you continue using our services, when you no longer wish to participate in our programmes or services, the data will be archived and securely destroyed six years after the date of your last contact with our services.
Sexual health records for people over 18 will be kept for a minimum of 10 years (both positive and negative) electronically. For clients under 18, records should be kept until their 25th birthday or for 8 years after last entry, whichever is the longer.
All personal data that we collect will be stored securely in password protected systems. Only staff whose role requires it will have access to your personal data.
All staff and third parties who process data on our behalf, who have access to your data, will regularly undertake data protection training and follow Young Greenwich’s Data Protection Policy and procedures.
When we collect your personal information, we use strict procedures and security features to prevent unauthorised access. Although the secure transmission of data via the internet or email can never be completely guaranteed, it is safer than using the postal system and/or a fax. We take every precaution to ensure your personal information remains secure and confidential.
Sharing your information
Young Greenwich complies with its obligations under the UK data protection legislation by keeping personal data up to date, by storing and destroying it securely, and by not collecting or retaining excessive amounts of data.
We only share your personal data based on your consent or because we need to share it in order to fulfil a contract with you (e.g. because you have subscribed to our membership, engaged with our services), we have a specified legitimate interest, or we have statutory obligations to share it (e.g. with the local or government authority).
We will share your personal data amongst ourselves to provide you with a service, but the Young Greenwich cannot deliver all the services on our own and sometimes we need help from our external Partners to provide activities and courses. We will never swap or sell your personal data. We may share your information with trusted third parties, for example, our Commissioners, as part of our contractual obligations, and our Partners who may deliver some of the services on our behalf. Young Greenwich will not share identifiable data with our external partners without your consent, where we are relying on consent to process your data in the first place.
When we use an external partner to deliver a service on behalf of Young Greenwich, we make sure that they apply the same protection to your personal data, this includes a legal agreement (sub-contract) that obliges them to only process data on our instructions and in accordance with the law. You can find more about our partners by clicking onto their websites below, or by visiting our 'About Us' section:
As One Youth
B Young Stars
Greenwich Peninsula FC
Transfers outside of the UK
Young Greenwich’s operations are based in the UK, and we store the data we hold within the UK.
We do not currently use any third party service providers who operate outside of the UK but we may use a supplier who stores data outside of the UK in the future. Where we do so, we will only transfer your data to them if we are confident that your data will be adequately protected, for example, the UK Government has determined that the recipient country provides a level of protection to personal data equivalent to that in the UK (an ‘adequacy decision’) or we have obtained contractual assurances from them that meet the UK’s data processing standards.
Your Rights
You can ask us for a copy of the information we hold about you at any time by contacting us using the contact details below. If you are being supported by a ‘specialist’ such as a counsellor, they may be processing your data as a Data Controller, in which case you would need to contact them directly for your data.
We will generally supply any information you ask for within 30 days unless it is a particularly complex request. This is known as a Subject Access Request. We will not charge you for this information other than in exceptional circumstances. We may also ask for proof of identify as we need to be sure we are only releasing your personal data to you. Unless subject to an exemption under the GDPR, and subject to the lawful basis on which we are processing your data, you have the following rights with respect to your personal data, you can:
Ask us to correct any data if it’s found to be inaccurate or out of date
To erase your personal data when it is no longer necessary for us to retain your data, unless we are processing it for a legal obligation
Withdraw consent (where processing your data is on this basis)
Object to the processing of your data where Young Greenwich is relying on its legitimate interests as the legal basis for processing
Ask us to place a restriction on further processing of your data, if you are in dispute in relation to the accuracy or the processing of your data
Young Greenwich complies with the National Data Opt-Out scheme however please be aware you may have provided explicit consent to us to process your data for specific reasons relating to the services you are being given access to.
If you would like information about the data we hold on you, or if you would like to exercise any of the rights set out above, please contact our Data Protection Officers.
Oxleas NHS Foundation Trust oxl-tr.dpo@nhs.net
Charlton Athletic Community Trust (CACT) dataprotection@cact.org.uk
METRO Charity informationgovernance@metrocharity.org.uk
If you believe that Young Greenwich has not complied with your data protection rights, you can complain to the Information Commissioner’s Office (which regulates the use of personal data in the UK). You can contact them here: https://ico.org.uk/global/contact-us/
Confidentiality
Young Greenwich treats your information as confidential unless there is a risk of serious harm or abuse to you or someone else. In this instance, we may have to pass this information onto a third party such as the emergency services.
If you are under 16
If you are under 16, we will need your parent’s or guardian’s permission to collect any personal about you, and we may require them to provide certain data on your behalf.
There are some health and sexual health services where young people (under 16) can be referred by professionals and community providers using the Fraser Guidelines. For such referrals, parental consent is not required.
Keeping your information up to date
We are keen to keep in touch with all our service users and supporters. Please keep your 'Profile' updated on the Young Greenwich website with the correct information, you can also contact us here, or speak to the person running your Young Greenwich service, activity, or event.
Changes to this notice
We regularly review our privacy notice and may make changes from time to time. Any changes made to our privacy notice will be posted on to our website. If we make substantial changes about how and why we use your information, we will make sure to bring this to your attention.
If you would like to receive a copy of each Young Greenwich Partner Organisations' Data Protection Policy, please contact the relevant Data Protection Officer:
Oxleas NHS Foundation Trust - Julie Lucas, Information Governance Manager oxl-tr.dpo@nhs.net
Charlton Athletic Community Trust (CACT) dataprotection@cact.org.uk
METRO Charity informationgovernance@metrocharity.org.uk
This privacy notice was last reviewed and updated on March 2022.
