Rationale

Doorway recognises and respects a young person’s right to privacy and to have information about them kept confidential. This policy has been updated to reflect new guidance and legislation introduced by the Data Protection Act 2018 (DPA 2018) and the General Data Protection Regulation 2018.

Policy Users

This policy is intended for the use and guidance of young people, team members, volunteers and upon request to other interested parties such as funders and external auditors.

Scope

All information obtained about a young person via our work is kept confidential to Doorway and will be shared within the organisation on a need to know basis. The team will only have access to information that they genuinely need in order to carry out their job.

When you interact with us by visiting our Drop-in centre, calling us, filling in a form and so on, we may collect your:

• name
• current and previous addresses (in the last three years)
• email address
• (mobile) telephone number
• employer
• bank account details
• date of birth
• current housing status
• housing history

 We may also collect sensitive personal data such as information about your:

• racial or ethnic origin
• religious or philosophical beliefs
• physical or mental health
• sexual life or sexual orientation
• actual or alleged criminal offences

 We will let you know before collecting whether it is compulsory to give us your personal information and the consequences of not providing the information.  

Information we collect from other sources:

We may receive your personal information from other sources, such as public databases, a friend, relative or member of the public who is concerned about you, or an organisation which has your permission to share your information with others. We may also receive information from Children's Services or Social Services from a local authority or other professionals such as health practitioners, teachers, employers.

How Information is Used

Depending on the specific purpose, we may process your information on the following bases:

• with your consent
• in order to enter into or perform a contract with you
• to protect your vital interests
• for our legitimate business interests
• where necessary to perform a task in the public interest
• for compliance with our legal or social protection obligations

We may use your personal information for the following purposes:

• to provide you with Doorway services you have requested (including advice, support, health and wellbeing services)
• to respond to your enquiries
• to further our charitable aims
• for administration purposes
• as required by law
• to provide you with shelter in one of our hostels
• to facilitate further education or training
• to carry out risk assessments and manage your activities/behaviour
• to contact other professionals eg the housing office to secure your benefits
• to contact emergency services if there is an immediate risk to life

We may also anonymise personal information to improve our services or for research. You cannot be personally identified from such data.

Information Sharing

Doorway may need to share your information with the following parties for the following reasons:

• Service providers: in order to provide you with the services or information you requested, for example hosting providers to host our website, cloud storage providers, printers for our marketing materials, criminal records check providers.
• Grant makers: to report on statistics and outcomes on work that they have funded or to use your case study (usually anonymised) with your explicit consent.
• Associated organisations: to further our charitable aims, for example with other homelessness charities and partner organisations. For the purposes of external audit to assess the quality of our work, for example our Advice Quality Standard quality mark.
• Organisations who are supportive of our aims:  to further our charitable aims or for fundraising purposes.  We only share your information for these purposes when we have your permission to do so. You can change your mind at any time by contacting your Doorway contact or a Doorway manager.
• Local councils: to provide our statistics on homelessness and outcomes for young people. We only share your information for these purposes when we have your permission to do so. You can change your mind at any time by contacting us. 
• Police or Social Services: we are under various legal obligations to share certain data for the prevention and detection of crime, for example the sexual offenders register or to prevent benefit fraud.

Disclosure

Information about you is only disclosed to others under the following circumstances:

With Informed Consent

This will only be done by you signing a consent form for information to be released to, or obtained from, the relevant agency, such as local authority housing departments or benefits agencies.

In all circumstances you will be fully informed of what information is to be disclosed or obtained and why this is necessary. Doorway team members will help you to understand the implications of both giving and withholding consent in any particular circumstance so that the choice to allow a disclosure of information to any third party is an informed choice.

Verbal Consent

In some exceptional circumstances it may only be possible to get verbal consent. This will be recorded on your file and followed up by asking you to sign a consent form as soon as possible.

Without Consent

There may be instances where Doorway is legally obliged to disclose to prevent or to detect a crime. Information may be disclosed where there is a serious health and safety risk to:

• You
• Another person or persons and/or the service user is not able to give consent
• Where a child is believed to be at risk

Disclosure Information

Doorway will check the identity of the person to whom information may be disclosed and where possible find out how the information will be used and how it will be stored. Information disclosed on the telephone will only be given to the person authorised to receive it. Confidential information sent electronically will be sent from secure e-mail addresses. Information sent by post will be addressed to the person designated to receive it and marked “private and confidential” or “addressee only.” All disclosures of information with or without consent will be recorded on your file.  

Retention of Information

Doorway takes appropriate technical and organisational measures to ensure that we keep your information secure, accurate and up to date.  We will retain your personal information for the period necessary to fulfil the purposes in this policy or as required by law. 

Advice & Support Services

Note books:                 all identifying information is shredded each month.

Case Records:             Paper records are stored securely in locked cabinet, then scanned at the end of the financial year in which there has been no additional contact for at least 6 months and then shredded. Records are then retained electronically

for seven years against civil litigation then deleted from the server. This includes financial records re housing costs.    

Most paperwork about you is uploaded to our In-Form database which is a cloud based system managed by Homeless Link through Salesforce. This is then shredded immediately to minimise paper records held in the office. Salesforce has field audit trails and a daily backup system. They archive and delete data after 5 years. 

Development Service

Lifewise records:         Paper records are held securely in a locked filing cabinet for duration of course. After the course, paperwork is uploaded onto In-Form and shredded. For accreditation purposes Centrepoint have a separate consent form for registering you and coursework submitted.

Other courses/projects:

                                    Paper records are held securely in a locked filing cabinet for duration of course. After the course, paperwork is uploaded onto In-Form and shredded.

YPG:                             Your attendance at sessions is recorded on In-form for statistical monitoring purposes.

 

Your Rights

You have the following rights and the Doorway team will help you to understand them. We will aim to respond within one month unless we need to extend the timeframe for certain reasons.

To be informed: we must provide fair processing information as described in this policy.

Access: you can ask for a copy of the information we hold about you.

Correction: we will use all reasonable endeavours to ensure the accuracy of your personal information. It is your responsibility to ensure that you submit true, accurate and complete information to us. Any inaccuracies in your information can be corrected by you.

Deletion: you can ask us to delete all your personal information in certain circumstances (for example, if the information is no longer necessary).

Objection/marketing: You can object to us processing your data in certain circumstances (for example, profiling). You can complain to Doorway or the Information Commissioner's Office (details below).

Restriction: you can ask us to pause processing your information in certain circumstances (for example, if you are disputing its accuracy).

Portability: in certain circumstances you can ask us to transfer your information electronically to another organisation.

Automated decision making/profiling: you can ask for access to information about the reasoning behind any decisions taken by automated means. You have the right to ask us to reconsider a decision taken by automated means.

Withdrawal of consent: you can withdraw your consent at any time.

As mentioned above you have the right to have a copy of the information we hold about you. The only exception to this will be any confidential information received from another agency. This information remains the property of that agency and you will need to contact that agency for written consent to share such information.

You have the right to privacy and the right to choose the environment for meeting Doorway

staff although support workers will need to see your accommodation at least once a fortnight

to undertake property inspections. Doorway has outreach drop in sessions which are private and

secure. If you wish to meet at an alternative venue this can be always arranged. Support sessions

are always carried out in a private environment, usually the young person’s accommodation.

 

Other Information

Changes to this notice: from time to time, we may revise this notice. Updated versions will be posted on our notice boards. If we make any significant changes, we will draw attention to them.

Transfers of your personal information: at all times, we intend to store and process your personal information within the European Economic Area. Should this ever change, we would take steps to ensure your personal information is only transferred once adequate safeguarding is in place.

Children: our services are aimed at young people aged 16-25, however our Advisors occasionally receive contacts from under 16 year olds.  We ask young people if an adult with parental responsibility can provide consent for us to hold/use the young person’s personal data but if this is not possible, we will make a professional judgement.  If it can be justified to be in the public interest to share the personal data, we will lawfully share it to protect the child from significant harm and promote the welfare of the child.  

Consent: to process your information for certain purposes we require your consent.  You have the right to decline to provide or withdraw your consent at any time.  You should note that we may not be able to provide you with Doorway services without your consent.

Policy Responsibility

All policy users have individual responsibility to comply with this policy. However, it is the CEO’s responsibility to ensure that all users are aware of the policy and trained as necessary. The CEO is also responsible for reviewing the policy and complying with legislative changes.

Policy Review Date

This policy will be reviewed for relevance and effectiveness in August 2019.

Contact details:

If you have any concerns about how your personal data is used or you wish to make any changes.

In accordance with your rights above, please speak to your Doorway worker. If you wish to raise a

concern about how your personal information has been used please contact Doorway’s CEO at

25/27 Dugdale Street, Nuneaton, CV11 5QJ or by email at [email protected] .

You may also contact the Information Commissioner’s Office at : https://ico.org.uk/.