Safe Places for Children UK
Privacy Notice
Last Updated: 05.12.2024
Welcome to Safe Places for Children and thank you for reading our Privacy Notice.
Safe Places respects your privacy and is committed to protecting your personal data and being transparent about how we collect, use, and share your data with our processing partners. We will comply with any data protection legislation. This Safe Places Privacy Notice adheres to the Data Protection Act 2018 and the UK General Data Protection Regulation. .
Our Privacy Notice will explain how we use your personal information that you provide, or which is provided to us by a third party. By visiting our website or using any of our systems, or services you are accepting and consenting to the practices described in this notice, so please read it carefully.
Name and Contact Details of the Organisation
Safe Places is the trading name of Safe Places for Children UK. We are registered with the company’s house under number 10152838 and a registered charity under charity number 1172481.
The Registered Office:
Name Safe Places for Children UK
Postal Address: First Floor, Triad House Mountbatten Court, Worrall Street, Congleton, Cheshire, United Kingdom, CW12 1DT
Tele Number: 01260 228 388
Email address: enquiries@safeplacesforchildren.co.uk.
Name and Contact Details of the Data Protection Officer
Safe Places Data Protection Officer (DPO) is responsible for answering any questions you have about this Privacy Notice.
Name Cieran McAuley
Postal Address: First Floor, Triad House Mountbatten Court, Worrall Street, Congleton, Cheshire, United Kingdom, CW12 1DT
Tele Number: 01260 228 388 or 07592127037
Email address: DPO@safeplacesforchildren.co.uk
Changes to Privacy Notice
We may update, modify, or remove this policy at any time without prior notice. Any changes we make to this Privacy Notice will be posted and updated on our website: www.safeplacesforchildren.co.uk. Remember to check back again if you are a regular user. If you have any comments on the policy, please contact the Data Protection Officer.
Young People who use our Services (Outreach and Residential within the United Kingdom)
This section explains what information Safe Places for Children collects, keeps, and stores about you and / or your family if you receive one of our services. This privacy notice applies to all personal information that identifies a living data subject. In broad terms, 'personal information' is information relating to a living individual who can be identified.
What kind of Information do we collect and hold?
We may collect and hold personal information about you, which may include:
Special category personal data; racial or ethnic, religious, physical and mental health and sexual orientation.
contact information;
Name
Address
Contact details, including email address and telephone number
Date of birth and gender
Copies of identification documents
Marital status, next of kin, dependants, and emergency contact details
Bank account details
National Insurance Number
Information about your criminal record and offences
Information about your medical or health conditions
Employment arrangements and history;
Education details;
Disability
Emergency contact details;
any other personal information required to engage you into the service.
Why do we collect your information?
Under the GDPR and the UK DPA 2018, we have a legal reason to keep data and process it. When Safe Places for Children UK provides you with a service, we will process your data under legitimate interest, legal obligation or public task. We do this because we cannot provide a service to you without your personal information.
Who do we share information with?
We share your data within Safe Places with people who need to see it to provide you with a service. We may also share it with the organisation that pays for your service or with external agencies in respect to our work with you. We may be required to share your data with other agencies for legal reasons (courts, police service, etc) or other organisations such as probation, etc.
There may be occasions when we will ask you for consent to use or share your data. If this is the case, we will explain exactly what your data will be used for. You can withdraw your consent at any time; however, there will be situations where we have the legal needs or grounds to share your information to keep you or others safe.
How long do we keep your data?
Safe Places will keep your data for a specified period once we have finished working with you. Depending on the nature of the service and the legal obligations, children and young person’s case records
Document - Records relating to children and young adults
Minimum Retention Period - 75 years from the date of birth of the child, or if the child or young person dies before the age of 18, for 15 years from the date of their death
Safe Places is sometimes required to transfer your data to the relevant authority who have commissioned us to provide your service or to another organisation providing you with a service. This process is undertaken in a confidential and safeguarding manner to ensure that your data is securely protected.
How can you access your data? (Data Subject Access Request – DSAR)
Young People have the right to access their own personal information if they are competent to do so. Young people can complete a DSAR request that is outlined within this Privacy Notice.
Competence is assessed depending upon the level of understanding.
A child will not be competent if it is evident that he or she is acting against their own best interests. If a young person is deemed not competent, it will be appropriate to let the holder of parental responsibility exercise the child’s rights on their behalf; this could be a parent, relative, or relevant authority.
If it is decided that a young person is competent to provide their own consent, it will be reasonable to assume they are also competent to exercise their own data protection rights. If a child is competent then, just like an adult, they may authorise someone else to act on their behalf. This could be a parent, another adult, or a representative, such as a child advocacy service, charity, or solicitor.
Job Applicants
As part of our recruitment process within Safe Places, we collect and process personal data relating to job applicants. If you apply for a role within Safe Places, we will only use the information you supply to us to process your application and monitor recruitment statistics.
What information do we collect?
We will collect a range of information about you, including:
Name;
Contact information;
Date of birth;
Employment arrangements and history;
National insurance number;
Licence details;
Employment history with the organisation;
Education details;
Driving history;
Banking details;
Equality Opportunities Monitoring information, such as ethnic origin, sexual orientation, health, and religion or belief. We will only collect this sensitive information with your explicit consent, which can be withdrawn at any time;
Details of qualifications, skills, and experience;
Information about your ability to work in the UK; and
Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process.
How do we collect information?
Safe Places will collect your personal information in a variety of ways. An example of how this can be collected is through you submitting your CV.
You may have also provided your passport details or other identification documents, or we may have collected it through interviews. We may also collect information about you from third parties, such as a reference supplied by your former employers. Safe Places will only seek information about you from third parties once we have made you an offer.
Why do we need your personal data?
Safe Places need to process your data before entering into a working contract / agreement with you. In some cases, we need to access your data to ensure we are complying with our legal obligations, such as checking an individual’s employment history. Safe Places have a legitimate interest in processing your personal data during the recruitment process and for keeping records of this process.
We may also need to process data from applicants to respond to and defend against legal claims. Where we are relaying on legitimate interest as a reason for processing data, we have considered whether those interests override the rights and freedoms of the applicant and have concluded they do not. For roles within Safe Places, it is a legal requirement that we seek information about criminal convictions and offences. This is necessary to carry out our obligations and exercise specific rights in relation to employment and police checks.
Safe Places will not use your personal information for any purpose other than recruitment.
How long will we keep your data?
Personal information about unsuccessful candidates will be held for one year after the recruitment exercise has been completed; it will then be destroyed. The exception to this is in Northern Ireland where we have a legal obligation to retain the data for Fair Employment reporting purposes for three years.
Interview notes for all unsuccessful applicants are destroyed after six months.
If your application is successful, personal data gathered during the recruitment process will be transferred to your personnel file and will be retained in accordance with our retention policy.
Who has access to your data?
Your information will be shared for the purposes of the recruitment exercise. This includes members of the operations and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy, and IT staff, if access to the data is necessary for the performance of their roles. As part of the recruitment process, we may need to share your data with third parties in order to conduct any necessary background checks and vetting processes, such as contacting previous employers/referees to obtain a reference; and/or the Disclosure and Barring Service to conduct criminal record checks.
What if you don’t provide personal data?
You are under no statutory or contractual obligation to provide us data during the recruitment process. However, if you do not provide Safe Places with the information, we may not be able to process your application properly, or at all. You are also under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences on your application if you choose not to provide such information.
Our Current and Former Employees & Trustees
This section explains what information Safe Places collects, keeps, and stores about you as an employee or a trustee with the organisation. This policy applies to personal information. In broad terms, 'personal information' is information relating to a living individual who can be identified.
What information do we collect?
Safe Places collects and processes a range of information about you that is appropriate to the role you perform with us. This will vary depending on whether you are an employed member of staff, casual worker, trustee, contractor, or agency worker, and may include:
Name
Address
Contact details, including email address and telephone number
Date of birth and gender
Copies of identification documents
Marital status, next of kin, dependants, and emergency contact details
The terms and conditions relating to the work you are doing for Safe Places
Information about your salary
Information about entitlement to pensions
Bank account details
National Insurance Number
Information about your entitlements and eligibility to work in the UK
Information about your criminal record and offences
Details of periods of leave taken by you, including holiday, sickness, absence, family leave, and extended leave, and the reasons for the leave
Details of your qualifications, skills, experience, and employment history, including start and end dates with previous employers and with us
Details of any disciplinary or grievance procedures
Performance Assessments, supervisions, and PDPs as well as appraisals
Training information and certifications that you have completed
Information about your medical or health conditions
Equal Monitoring Information, including ethnicity, health, religion, and sexual orientation
How do we collect your personal data?
We collect your information in a variety of ways. For example, you would have submitted a CV at the application process of the recruitment stage. You may have provided your passport details or other identity documents from forms completed by you at the start or during your work with us, from correspondence with you, or through interviews, meetings, or other assessments.
We may also collect information about you from third parties, such as recruitment agencies, references supplied by former employers, and information from criminal records checks as permitted by law.
Why do we need your personal data?
Safe Places needs to process your data to enter into a working relationship with you and meet our contractual obligations under any agreement with you. For example, if you are an employee, we need to process your data to provide you with an employment contract, pay you in accordance with that contract, and administer any benefits.
In some cases, Safe Places needs to process data to ensure that we are complying with our legal obligations (e.g., to deduct tax or comply with health and safety laws). For all positions, it’s necessary to carry out criminal records checks to ensure that individuals are permitted to carry out the role in question. Where Safe Places is relying on legitimate interest as a reason for processing employee data, we have considered whether, by collecting the data, the charity is over-riding the rights and freedoms of our employees and workers and has concluded that we are not.
Some special categories of personal data, such as information about health or medical conditions, are processed to carry out employment law obligations. Where we process other special categories of personal data, such as information about ethnic origin, sexual orientation, health, religion, or belief, this is done for the purposes of equal opportunities monitoring.
Who has access to the data?
Your information will be shared internally, with members of the Finance Team, Operational Team, your line manager, managers in the business area where you work, and any other members of staff for whom access to the data is necessary for the performance of their roles.
Safe Places shares your data with third parties in order to obtain pre-employment references from other employers and, if applicable to your role, to obtain necessary criminal records checks from the Disclosure and Barring Service and AccessNI. The services we provide to children and young people are subject to external regulation, so if you work in a service, your personal data will be shared with inspectors, and commissioned service data may be shared with the commissioner.
Safe Places also shares your data with third parties that process data on our behalf, in connection with payroll, the provision of benefits, the provision of occupational health services, and the off-site archiving of personal data once you have left Safe Places employment.
Safe Places may transfer your data to countries outside the European Economic Area.
How long will we keep your data?
Safe Places has a legal obligation to retain data from all current or previous employees, board members or other that work within and for the organisation. The retention periods for some documentation can be 6 months while other documents are required to be retained for a maximum of 40 years. The reasons for retention of data, the types of data and the length of retention are outlined in more detail within Safe Places retention policy.
Working with Third Parties
Safe Places will never sell your personal data; however, we may share your information with third parties in order to provide services or employment to you. Your data may be accessible to some of the IT support companies who manage our business-critical systems; however, this is strictly governed by our contractual arrangements with them.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Some of our partners run their operations outside of the EEA (European Economic Area) and this may include countries who have different Data Protection Laws. We will always take steps to make sure appropriate protections are in place (in accordance with UK Data Protection Law) and that information is safeguarded.
We can share your personal information with selected third parties as our Data Processor’s; Business partners, suppliers, and sub-contractors for the performance of any contract we enter with them: Safe Places for Children Australia and OSS / SPO Online based in the Philippines.
We will keep your personal information confidential, and where we provide it to other third parties, we will only do so under processor agreement contracts, on conditions of confidentiality and security, and only for the purposes for which you have provided your information to us.
We take the security of your personal information very seriously. We have internal policies, controls, and appropriate data collection, storage, processing practices, and security measures in place to ensure that your data is not lost, accidentally destroyed, misused, or disclosed, and is not accessed except by our employees in the proper performance of their duties.
Where we have given you (or where you have chosen) a password, which enables you to access certain parts of the site, you are responsible for keeping this password confidential. We ask you not to share that password with anyone.
Data Controller: ‘Controller' means the natural or legal person, public authority, Agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Name Safe Places for Children UK
Postal Address: First Floor, Triad House Mountbatten Court, Worrall Street, Congleton, Cheshire, United Kingdom, CW12 1DT
Tele Number: 01260 228 388
Email address: enquiries@safeplacesforchildren.co.uk.
Data Processor/s: Processor' means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Name Safe Places for Children Australia
Postal Address: Level 5, 241 Adelaide Street, Brisbane Qld 4000
Tele number: 1300 993 483
Email address: enquiries@safeplaces.com.au
Where we store and process your information?
The information that we collect from you may be transferred to, and stored in, a location outside the United Kingdom, but only where we are satisfied that it has an adequate level of protection with regards to the technical and organisational measures have been implemented. It may also be processed by staff operating in these locations who work for us or for our service providers. This includes staff engaged in, among other things, the hosting of the site for the provision of support services.
By submitting your personal information, you agree to this transfer, storing, or processing. Our approach to holding personal information also includes holding that personal information:
physically, at our premises;
electronically, on secure servers; and
in a private cloud.
We also secure the personal information we hold in numerous ways, including:
using security systems to limit access to premises outside of business hours;
using secure servers to store personal information;
using unique usernames, passwords, and other protections on systems that can access personal information;
holding certain sensitive documents securely; and
Restrictive Access levels.
Safe Places will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Notice.
How do we manage the personal information we collect?
We manage the personal information we collect in numerous ways, such as by:
implementing procedures for identifying and managing privacy risks;
implementing security systems for protecting personal information from misuse, interference, and loss from unauthorised access, modification, or disclosure;
providing staff with training on privacy issues;
appropriately supervising staff who regularly handle personal information;
implementing mechanisms to ensure any contractors and agents who deal with us comply with the United Kingdom Privacy Principles;
implementing procedures for identifying and reporting privacy breaches and for receiving and responding to complaints; and
appointing a privacy officer within the business to monitor privacy compliance.
Who is responsible for your data?
The Data Controller is responsible for your data while you are engaging in our services or employed by the organisation. Your information can be sourced from Safe Places for Children UK; contact details are outlined within this Privacy Statement. However, it is important that the information we hold about you is up-to-date. You should contact us if your personal information changes.
Your Legal Rights
Under the UK General Data Protection Regulation (GDPR), you have the following rights:
The right to be informed
You have the right to be informed about the data we hold and share about you. This will be described to you in the service specific information leaflet if you are a service user, through your line manager if you are a member of staff or a volunteer, or through our privacy notice above.
The right to access your personal information
You have a right to access your personal data. This can be done through a Data Subject Access Request (DSAR); this process is outlined within this privacy notice.
The right to edit and update your personal information
The accuracy of your personal information is important to us. You can edit your personal information including your address and contact details at any time. It is important that the information we hold about you is up-to-date. You should contact us if your personal information changes.
The right to request to have your personal information deleted
You have the right to request the deletion of your personal information, which we will review on a case-by-case basis.
The right to restrict processing of your personal information
You have the right to ‘block’ or suppress processing of your personal data. However, we will continue to store your data but not further process it. Please note, this is not an absolute right and it only applies in certain circumstances.
The right to data portability
You have the right to get your personal data from us in a way that is accessible and machine- readable (e.g., as a csv file). You also have the right to ask us to transfer data you have provided us to another organisation where technically feasible.
The right to object
You have the right to object to your personal information being processed for marketing (including automated decision making and profiling) and for research purposes. This is a process that Safe Places does not currently undertake.
Right to Access (DSAR)
You may request a right to access your own personal data, but not to information relating to other people. To access your own personal data, you must complete a data subject access request. You can make a DSAR verbally or in writing to the Data Controller. The Data Controller may ask you to complete the Data Subject Request Form to assist with getting the required information together for your DSAR. Please note that there could be an administrator fee that will need to be paid prior to the DSAR being actioned.
You will be asked for a minimum of 2 types of Identification Documents to confirm the identity of the person that has submitted the DSAR, before the Data Controller will undertake the data request. The Data Controller will respond back to each DSAR within the legal requirements of 30 days, after the request has been made in writing, verbal, or through electronic methods. The Data Controller will provide the personal information in a clear suitable formatted version.
The Data Controller reserves the right to refuse to comply with a DSAR if it is manifestly unfounded or excessive, considering that the request is repetitive in nature. If the Data Controller refuses to comply with the request, it will notify and provide you with a rationale for why this request will not be undertaken.
If you wish to exercise your rights, please contact us, providing as much information as possible about the nature of your contact with us to help us locate your records, this might be easier for yourself if you complete the Data Subject Access Request Form, that can be obtained from the Data Controller.
Complaints
If you want to complain about any interference with your privacy, you can first make a complaint to us in writing, using the contact details in this section. We will respond to the complaint within a reasonable timeframe.
Name Cieran McAuley
Postal Address: First Floor, Triad House Mountbatten Court, Worrall Street, Congleton, Cheshire, United Kingdom, CW12 1DT
Tele Number: 01260 228 388 or 07592127037
Email address: cieran.mcauley@safeplacesforchildren.co.uk
If the privacy issue cannot be resolved, you may take your complaint to the Office of the Information Commissioner Office (ICO).
Information Commissioner’s Office, Wycliffe House Water Lane, Wilmslow, Cheshire, SK9 5AF, Telephone: 0303 123 1113
Safe Places for Children UK are registered with the ICO,