Privacy Notices - Swindon Safeguarding Partnership training delegates Privacy Notice

Introduction

One of the key priorities of the Swindon Safeguarding Partnership (SSP) is to ensure that those who work directly or indirectly with children and adults at risk receive appropriate child and adult protection and safeguarding training. The SSP is committed to delivering a high quality inter-agency training programme, which supports professionals, volunteers and the independent sector in their work to safeguard and promote the welfare of children and adults.  In order to do this the SSP needs to collect personal data about training delegates.

The new General Data Protection Regulations (GDPR) came into force from 25 May 2018, the SSP are confirming our data protection arrangements in relation to training delegates and the data we hold about them. The GDPR has replaced the Data Protection Act 1998; it should be noted that the SSP is already compliant with the data protection principles under the Data Protection Act 1998.  These new regulations enhance those existing requirements making the Swindon Safeguarding Partnership (SSP) fully transparent to you as a training delegate.

The SSP is a Data Processor.  As part of the SSP training process the SSP collects and processes personal data that you provide as part of the training application process.  The SSP is committed to being transparent about how it collects and uses data and to meeting its data protection obligations.  We work hard to keep your personal data secure.  When there is an important change to our Privacy Notice Policy and subsequent Privacy Notices we will notify you via our website, so that you are aware how we use your data and what your options are. 

SSPs are not subject to Freedom of Information (FOI) requests.

This document summarises the key ways in which we deal with the information we hold about you when you apply to attend one of the SSP training courses, how we use it and your rights in relation to it.
 

What is a Privacy Notice?

A Privacy Notice is a statement issued by an organisation which explains how personal and confidential data about individuals is collected, used and shared.

This privacy statement summarises the key ways in which we deal with the information we hold about you when you apply to attend a training course, the ways in which we use that information and your rights in relation to it.

SSP does not capture or store any personal information about individuals who browse this website, except where you voluntary choose to give us your personal details via email or by completing an online booking form for a training course.  
 

Who is collecting and using your personal data?

The SSP takes the security of your data seriously.  The SSP Business Team are hosted by Swindon Borough Council, which is our Data Controller and we use their guidance and policies for information protection and retention of information.  Your employing agency will have their own policies for data protection and processing, contact your own safeguarding lead for further information.

Swindon Borough Council will act as a “Data Controller” for any personal data that you provide to us.  We will ensure that the data given to us is processed in line with our Data Protection Act 2018 (DPA 18) and the EU General Data Protection Regulations. (GDPR)

To find out more about Swindon Borough Council’s data protection policies please contact our Data Protection Officer. dataprotection@swindon.gov.uk or in writing to Data Protection Officer, Civic Offices, Euclid Street, Swindon, Wiltshire, SN1 2JH.

Please note that not providing your personal data may lead to you being unable to utilise the training provided by SSP.

Your personal data – what is it?

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 such possession.

The processing of data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”).
 

What personal data do we collect?

Applications for all SSP courses are made online via the SSP website where delegates complete an online booking form providing their personal data.  We only collect personal data that is absolutely necessary for our training function. When you apply for a course via the online booking form your information is forwarded via email to the SSP Business Team. The SSP  Business Team then collects a range of information about you. 

This includes:

  • your name
  • your employing agency
  • your job title
  • your work place address
  • your contact details (phone number and email address)
  • your line manager’s name and email address
  • whether or not you have a disability for which the SSP needs to make reasonable adjustments for you to undertake the training course
  • information about the type of training undertaken or to be undertaken
  • course details including attendance, the dates of when the training will or has taken place and the training venue
  • any costs associated with the training and your agency’s cost code, payment or debit card details or invoicing details
  • feedback and course evaluation information after the training has taken place

Your data will be stored in a range of different places, including IT systems, email and paper records such as evaluation forms.

All who receive our newsletter, promotional emails and learning information will have opted in with their consent. To be removed from our mailing list, please email safeguardingpartnership@swindon.gov.uk at any time.

How do we process your personal data?

Swindon Safeguarding Partnership complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

The SSP Business Team will need to process your data to undertake the administrative process to support any training you undertake through the SSP.

Why do we need your personal information?

The SSP has a legitimate interest in processing personal data to support the training of SSP partner agencies.  Processing delegate data enables the SSP Business Team to manage the administration and evaluation of training.

The SSP may process special categories of data, such as attendance information, agency attendance at courses and evaluation information.  We do this to monitor training attendance and to report to partners training statistics and evaluations.  If we do not need personal information, we will keep you anonymous and provide only statistics and anonymous comments

We may need to use some information about you:

  • to deliver training and learning resources to support you
  • to evaluate the quality of the training delivered
  • to train and manage workers and volunteers who deliver services
  • to monitor spending on services
  • help with research and planning of new training materials
How the law allows us to use your information?

Swindon Safeguarding Partnership is committed to delivering a high quality multi-agency training programme which supports professionals, volunteers and the independent sector in their work to safeguard and promote the welfare of children and adults.  In order to do this the SSP needs to collect delegate’s personal data to administer and evaluate Swindon Safeguarding Partnership training courses.

The SSP Business Team will need to process your data to undertaken the administrative process to support any training you undertake through the SSP.

The SSP has a legitimate interest in processing personal data to support the training of SSP partner agencies.  Processing delegate data enables the SSP Business Team to manage the administration and evaluation of training.

The SSP may process special categories of data, such as attendance information, agency attendance at courses and evaluation information.  We do this to monitor training attendance and to report to partners training statistics and evaluations.  If we do not need personal information, we will keep you anonymous and provide only statistics and anonymous comments.

Who do we share your information with?

Your data may be shared internally for the purposes of the SSP training and learning opportunities.  This includes members of the SSP Business Teams, SSP trainers and the employee’s line manager.  Personal attendance data and statistics may also be shared with the delegate’s employing agency.

Please note - a delegate list of those registered to attend the course will be used as a sign in sheet at each course.  If you do not wish us to include your name in the delegate list, please email safeguardingpartnership@swindon.gov.uk 

How do we protect your information?

The SSP takes the security of your data seriously. The SSP Business Team are hosted by Swindon Borough Council, which is our Data Controller and we use their guidance and policies for information protection and retention of information. Your employing agency will have their own policies for data protection and processing, contact your own safeguarding lead for further information.

How long do we keep your personal information?

The SSP will hold your training information for a minimum of 2 years and a maximum of 3 years.

What you can do with your information?

The law gives you a number of rights to control what personal information is used by us and how it is used by us.

You can ask for access to the information we hold on you.  We would normally expect to share what we record about you with you whenever we assess your needs or provide you with services. However, you also have the right to ask for a copy of all the information we have about you and the services you receive from us.

When we receive a request from you in writing, we must give you access to everything we have recorded about you, however, we cannot let you see any parts of your records that contain: 

  • confidential information about other people
  • data a professional thinks will cause serious harm to you or someone else’s physical or mental wellbeing; or
  • if we think that giving you the information may stop us from preventing or detecting a crime

This applies to personal information that is in both paper and electronic records. If you ask us, we will also let others see your record (except if one of the points above applies).

If you cannot ask for your records in writing, we will make sure there are other ways that you can.  If you have any queries about access to your information contact DataProtection@Swindon.gov.uk.

You can ask to change information you think is inaccurate.

You should let us know if you disagree with something written on your file.
We may not always be able to change or remove that information but we will correct factual inaccuracies and may include your comments in the record to show that you disagree with it.

You can ask to delete information (right to be forgotten).

In some circumstances, you can ask for your personal information to be deleted, for example: 

  • Where your personal information is no longer needed for the reason it was collected in the first place
  • Where you have removed your consent for us to use your information and where there is no other legal, legitimate or lawful reason for us to keep it
  • Where there is no legal reason for the use of your information
  • Where deleting the information is a legal requirement
  • Where your personal information has been shared with others, we will do what we can to make sure those using your personal information comply with your request for erasure

Please note that we cannot delete your information where:

  • we are required to have it by law
  • it is used for freedom of expression
  • it is used for public health purposes
  • it is used for, scientific or historical research, or statistical purposes where it would make information unusable
  • it is necessary for legal claims

You can ask us to limit what we use your personal data for. You have the right to ask us to restrict what we use your personal information for where:

  • you have identified inaccurate information, and have told us of it
  • we have no legal reason to use that information, but you want us to restrict what we use it for rather than erase the information altogether

When information is restricted, it cannot be used other than to securely store the data and with your consent to handle legal claims and protect others, or where it is for important public interests of the UK.

Where restriction of use has been granted, we will inform you before we carry on using your personal information.

You have the right to ask us to stop using your personal information for any council service. However, if this request is approved this may cause delays or prevent us from delivering that service to you.

Where possible we will always seek to comply with your request, but we may need to hold or use information because we are required to by law.

You can ask to have your information moved to another provider (data portability).

You have the right to ask for your personal information to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.

However, this only applies if we are using your personal information with consent (not if we are required to by law) and if decisions were made by a computer and not a human being. 

It is likely that data portability will not apply to most of the services you receive from the Council. 

You can ask to have any computer made decisions explained to you, and details of how we may have 'profiled' you.

You have the right to question decisions made about you by a computer, unless it’s required for any contract you have entered into, required by law, or you have consented to it.

You also have the right to object if you are being 'profiled'. 'Profiling' is where decisions are made about you based on certain things in your personal information. For example, your health conditions.

If the Council uses your personal information to profile you, in order to deliver the most appropriate service to you, you will be informed.

If you have concerns regarding automated decision-making, or profiling, please contact our Data Protection Officer who will be able to advise you about how we are using your information. 

Your right to complain

In the event that you wish to complain about the way that your personal data has been handled by Swindon Safeguarding Partnership, you should write to the Data Protection Officer at Swindon Borough Council and clearly outline your case. Your complaint will then be investigated in accordance with our customer complaint procedure.

If you remain dissatisfied with the way your personal data has been handled, you have the right to complain to the Information Commissioner’s Office at www.ICO.org.uk. You may refer the matter to the Information Commissioner’s Office whose contact details are below:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Email: casework@ico.org.uk

This website also contains information on data protection and your rights and remedies.
 

What if you do not provide personal data?

You are under no statutory obligation to provide personal data to Swindon Safeguarding Partnership for training purposes and during the booking process. However, if you do not provide the data, we may not be able to process your application properly or at all.

How will we ensure compliance?

A yearly audit will take place on personal data to ensure that we remain legally compliant in accordance with current data protection legislation.

This policy will be regularly reviewed to ensure that the SSP remains legally compliant in accordance with current data protection principles.

Main privacy notice

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