How we might use your information

HOW WE STORE AND USE YOUR PERSONAL DATA 

PRIVACY NOTICE FOR PEOPLE ACCESSING POSITIVE STEPS AS A SERVICE USER

Positive Steps is committed to protecting the privacy and security of your personal data. This document outlines how we collect and use information about you.

The law states that any personal information that we hold about you must be:

  • Used lawfully, fairly, and in a transparent way;
  • Collected only for valid purposes that we have clearly explained to you, and not used in any way that is incompatible with those purposes;
  • Relevant to the purposes that we have told you about, and limited to those purposes only;
  • Accurate and up to date;
  • Kept only for as long as necessary for the purposes that we have told you about.
  • Kept securely. 

Positive Steps is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We do not share your information without consent unless the law allow us to do so. Your information will not be transferred or stored outside the EU.

As a multi-agency support service, we hold personal data on the service users who we are working with. This could relate to one or more of the following services – Careers Guidance Service (Oldham, Rochdale, Bury and Tameside), Oldham Youth Offending Service, Oldham Missing from Home Service, Oldham Young Carers Respite Service, Oldham Early Help Service (including stop smoking support, Health Checks and MOTS, and access to the two-year-old Child Care offer), and Oldham Integrated Health Services (Young People’s sexual health and young people’s drugs service).

This document applies to current and former service users – as we are required to retain data for specified periods after people have stopped using our services.

WHY WE COLLECT AND PROCESS YOUR PERSONAL DATA

We use your personal data to:

  • enable us to carry out specific functions for which we are responsible 
  • derive statistics which inform decisions such as the allocation of resources and support (you cannot be identified in these statistics)
  • assess performance and to set targets for our staff (you cannot be identified in this data)

WHAT SORT OF DATA DO WE HOLD?

The type of information that we collect, process, hold, and share include:

Personal information which could identify you (such as name, DOB, address and contact information, and unique identifier numbers). 

Characteristics (such as ethnicity, gender, special educational need, and assessment information)

Ongoing notes about our work with you (such as interview notes, telephone calls made, appointments booked, contact with other professionals on your behalf etc)

Additional data may be held on you depending on which service you are accessing – see the next section for more information. 

THE LAWFUL BASIS ON WHICH WE USE THIS INFORMATION

We will only use your personal information when the law allows it to do so. We will only use personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason, and that the reason is compatible with the original purpose. 

The lawful basis for holding personal data for each of our service areas is as follows;

IF YOU ARE ACESSING CAREERS GUIDANCE IN OLDHAM, ROCHDALE, OR TAMESIDE: 

On behalf of each local authority we collect and use information about young people attending schools (year 7-11) in the relevant local authority area. We also hold information about young people living in each area, but who went to school outside the local authority in question (clients aged 16 and 17 – and up to 25 for those with special needs).

This data is collected and held in accordance with section 507B of the Education Act 1996, and enables us to provide an impartial career guidance and support service in each local authority area. The data remains the property of each local authority.

Under parts 1 and 2 of the Education and Skills Act 2008, education institutions and other public bodies (including the Department for Education (DfE), police, probation and health services) may pass information to us to help us to support this provision.

We share children and young people’s data with the Department for Education (DfE) on a statutory basis under section 3 of The Education (Information About Individual Pupils) (England) Regulations 2013. This data sharing underpins school funding, educational attainment policy and monitoring - and enables them to; produce statistics, assess our performance, determine the destinations of young people after they have left school or college, and to evaluate Government funded programmes.

IF YOU ARE ACCESSING CAREERS GUIDANCE IN SPECIFIC BURY SCHOOLS: 

In Bury we collect and use information about young people attending specific schools (clients in years 7-11) for whom we are providing an impartial career advice and guidance service - under section 507B of the Education Act 1996. The data is the property of Positive Steps and the schools we work with are Bury C of E School, Parrenthorn High School, St Gabriel’s RC High School, St Monica’s RC High School and The Derby.

Under parts 1 and 2 of the Education and Skills Act 2008, education institutions and other public bodies (including the Department for Education (DfE), police, probation and health services) may pass information to us to help us to support this provision.

IF YOU HAVE BEEN REFERRED TO OLDHAM YOUTH OFFENDING SERVICE:

Under the 1998 Crime and Disorder act, we collect, use and share information on behalf of Oldham Local Authority, to enable us to deliver the statutory Youth Offending Service in Oldham. 

We hold information about young people who are involved with the service, including their offending history. 

Other public bodies (including the Department of Justice (DoJ), police, probation and health services) may pass information to us to help us to support these provisions.  

We share children and young people’s data with the Department of Justice (DoJ) on a statutory basis. This data sharing underpins policy and monitoring and enables them to; produce statistics and assess our performance, 

IF OLDHAM MISSING FROM HOME SERVICE HAVE BEEN TOLD ABOUT YOU: 

We collect and use information on behalf of Oldham Local Authority (via The Fostering Services (England) Regulations 2011. SI 2011 No 581. Regulation  13 (3),  to enable us to deliver the independent Missing from Home interview function in Oldham. We receive children and young people’s data from agencies who have identified a ‘missing from home incident’ – EG the police or social services. 

We hold information about young people who are involved with the service, including details of occasions when they went missing from home and notes from our subsequent contacts with them.

We share anonymised statistics with Oldham Local Authority.

IF YOU HAVE ASKED TO BE A PART OF THE OLDHAM YOUNG CARERS RESPITE SERVICE: 

We collect and use information on behalf of Oldham Local Authority to enable us to deliver a respite service for Young Carers living in Oldham. We hold information about young people who are involved with the service – including details of respite activities provided.

We share anonymised statistics with Oldham Local Authority.

IF YOU HAVE SIGNED UP TO THE OLDHAM EARLY HELP SERVICE (INDLUDING STOP SMOKING SUPPORT, HEALTH CHECKS AND MOTS, AND ACCESS TO THE TWO-YEAR-OLD CHILD CARE OFFER):

We collect and use this information on behalf of Oldham Local Authority to enable us to deliver contracted elements of the Oldham Early Help offer. Written consent for all elements of this service is required for people accessing Early Help, Stop Smoking Support and Health Checks/MOTs. This consent explains what data we will collect and hold on them, why we hold it, and how long we will hold it for. 

IF YOU ARE INVOLVED WITH OUR INTEGRATED HEALTH SERVICES (YOUNG PEOPLE’S SEXUAL HEALTH AND YOUNG PEOPLES DRUGS SERVICE). 

We collect and use information on behalf of Oldham Local Authority to enable us to deliver a young person’s substance misuse service. This data includes details of substance misuse and support offered. We share anonymised statistics with Oldham Local Authority.

We also share some treatment data with NDTMS, which is part of Public Health England (PHE).

What NDTMS is and does: NDTMS is the National Drug and alcohol Treatment Monitoring System (NDTMS). It is used by PHE to collect information about drug and alcohol treatment in England. If you consent, your treatment service will share some of your treatment information with NDTMS.

What information NDTMS uses and why: PHE collects some personal information about people in treatment including your initials, date of birth, gender, the local authority area in which they live and the first part of your postcode. This reduces the risk of you being counted twice. This information is only shared with PHE if the people using treatment services agree and PHE never contact service users:

 your full name and address are NOT passed on to PHE

 no identifiable information held on NDTMS is passed on to the police or any other organisation

 your information is held on NDTMS to support ongoing trend and other research analysis1

The information is used to understand how many people are using these treatment services, how good the services are at helping people with substance misuse issues, to help improve them and produce statistics and research about drug and alcohol use and treatment. PHE never publish NDTMS information that could be used to identify individuals.

How NDTMS will protect your information: the security of the data you provide to NDTMS is of utmost importance and PHE staff are bound by law to protect the confidentiality of the information they collect and use. The personal information held is kept to a minimum and PHE makes sure that staff can only see the information that is required to do their job.

Sharing and linkage of NDTMS information: some information from NDTMS is cross referenced with data from other government departments and reports are sent back to them so that they can monitor the effectiveness of the national drug and alcohol strategies. Any data matching with other government departments is undertaken by PHE. At no point is your personal information shared with the police or any other organisation. In addition, sometimes you may be seen by more than one agency and to assist with treatment outcomes profiles (TOP), NDTMS may share TOP information about you between the agencies from which you may have received treatment.

Withdrawal of consent: if you do not want information about you to be passed on to NDTMS then you have the right to say this and/or ask for your treatment information at your current service to be removed. This will not have any impact on the treatment you receive. You can ask your service or your keyworker for a copy of the NDTMS patient information leaflet for more information.

We collect and use information on behalf of Oldham Local Authority to enable us to deliver a young person’s sexual health service. This data includes details of sexual health needs and support offered. This element of our service is delivered by Brook – their client data is not shared with Positive Steps. We are supplied with anonymised statistics by Brook and share this data with Oldham Local Authority. 

IF WE ARE CARRYING OUT A DBS CHECK FOR YOU

We carry out Disclosure and Barring Checks (DBS) on behalf of other organisations and for potential staff and volunteers working for us. No one is DBS checked without their knowledge. For the sole purpose of verifying ID information, we use an external agency (TransUnion). Their privacy policy can be found here https://www.callcredit.co.uk/legal-information/bureau-privacy-notice

HOW WE KEEP YOUR DATA SAFE, AND HOW LONG WE KEEP IT FOR 

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to people who have a business need to see it.

Positive Steps has put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

We hold client data for time periods that they have specified in our contracts. These are;

  • Careers Guidance Service (Oldham, Rochdale and Tameside). Records are destroyed on the clients 22nd birthday – or 26th birthday for clients with identified special needs 
  • Careers Guidance Service (Bury) – Our service runs in: Bury C of E School, Parrenthorn High School, St Gabriel’s RC High School, St Monica’s RC High School and The Derby. Records are destroyed on the clients 22nd birthday – or 26th birthday for clients with identified special needs 
  • Oldham Youth Offending Service – Management of restorative justice & reparation measures"Retention period starts from Date of Birth or * End of supervision order or licence if offender is aged over 18 & case cannot be transferred. Retain records 25 Years from Date of Birth or * Retain records 6 years from end of supervision of order or licence (aged over 18)" Destroy Limitation Act 1980, Youth Justice Board national standards 2009 & Youth Justice Board Case Management Guidance 2011

Assessment & management of young offenders risk posed to the public "Retention period starts from Date of Birth or * End of supervision order or licence if offender is aged over 18 & case cannot be transferred

Retain records 25 Years from Date of Birth or * Retain records 6 years from end of supervision of order or licence (aged over 18)" Destroy Limitation Act 1980, Youth Justice Board national standards 2009 & Youth Justice Board Case Management Guidance 2013

Intensive supervision & surveillance of young offenders "Retention period starts from Date of Birth or * End of supervision order or licence if offender is aged over 18 & case cannot be transferred

Retain records 25 Years from Date of Birth or * Retain records 6 years from end of supervision of order or licence (aged over 18)" Destroy Limitation Act 1980, Youth Justice Board national standards 2009 & Youth Justice Board Case Management Guidance 2010Oldham Young Carers – Three years after the contacts to deliver this service has eneded

  • Oldham Early Help (including stop smoking support, Health Checks and MOTS, and access to the two-year-old Child Care offer) -  Ten years after the service users last contact with Positive Steps
  • Integrated Health Services (Young People’s sexual health and young people’s drugs service) - 

WHO WE SHARE YOUR INFORMATION WITH

We routinely share your data with organisations who can help you, or if we are required to do so by law. EG:

  • Schools – We share statutory career destination information on ex-pupils immediately after leaving school, and ongoing destination information during Ofsted inspections.
  • Training and Further Education providers – with your knowledge and on your behalf, we may share some of your data as part of our support work through the Careers and Early Help contracts (EG – as part of the application process for college places). 
  • Potential employers - with your knowledge and on your behalf, we may share some of your data as part of our support work through the Careers and Early Help contracts (EG – Job application data/CVs). 
  • Support services - we may share some of your data as as part of our support work with you (EG sharing information with benefit providers to arrange claims, sharing details with specialist service providers such as mental health support services etc). This data is shared with your knowledge and on your behalf for all contracts except Youth Justice – where we have a statutory requirement to share data, or if there is a safeguarding concern. 

REQUESTING ACCESS TO YOUR PERSONAL DATA

Under data protection legislation, you (or your parents if you are under 16) have the right to request access to the information that we hold on you. To make a request contact us Here

You also have the right to:

  • object to processing of personal data that is likely to cause, or is causing, damage or distress
  • prevent processing for direct marketing (we do not do this – but we may contact you with information relevant to the service we are providing. EG details of college open days for school leavers or details of respite activities for young carers)
  • object to decisions being taken by automated means (we do not make decisions on you using automated means)
  • in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed;

FURTHER INFORMATION

If you would like further information about this privacy notice, or how we handle your personal information, please do not hesitate to contact our Data Protection Officer (DPO) PHIL COLLINGE – Here

If you have a concern about the way we are collecting or using your personal data, we request that you raise your concern with our DPO in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/

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