This notice explains what information we collect, when we collect it and how we use this. During the course of our activities, we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will process your personal data.
Who are we?
Carr Gomm is a not-for-profit company and a Scottish Charity which provides services to people with a wide range of reasons for needing our support. Our philosophy of support is based on the fact we are all human beings who naturally have a lot to contribute to each other and wider society.
We are a Company limited by guarantee in Scotland: SC 236436 Scottish charity: SC 033491
Our National and Registered Office is based at Space, 11 Harewood Road, Edinburgh EH16 4NT. All enquiries should be direct to info@carrgomm.org.
How we collect information from you and what information we collect
We collect information about you:
- When you ask for a care and support service from us, or another person or organisation (such as a council or legal representative) asks for a service on your behalf, or when you otherwise provide us with information about you
- When other people or organisations involved in your life (such as family members, social workers, legal representatives, other support providers, landlords, health professionals, or advocacy services) provide us with information about you
- When you contact us by email, either through our website or directly, or by post, to request a service, e.g. to report any issues about your service from us, or to make a complaint
- When you tell us how you feel about our services by completing our surveys and questionnaires
- In a small number of settings CCTV is in operation, where this is the case appropriate signage is in place to make you aware, your image may be captured by this
We may collect the following information about you:
- name
- address
- telephone number
- e-mail address
- National Insurance Number
- Next of Kin
- Date of birth
- Signature
- Details of people involved in your life, such as your family members, friends, carers, Social Workers, Health Professionals, advocates, landlords, etc
- Copies of relevant legal orders or documents such as Guardianship and Intervention Orders, Powers of Attorney, and Section 47 medical certificates
- Information about offences which are relevant to the service which we provide, such as Antisocial Behaviour Orders, and MAPPA Orders
- Protected characteristics data, as defined by the Equality Act 2010
- Health Information, such as your diagnosis (e.g. learning disability), mental health, details of your prescribed medications, illnesses, pregnancy, NHS number, and Hospital Passport
- Your benefits information
- CCTV Imagery, and
- Information we need to know in order to support you to make sure you, or others, are safe
We may also record factual information whenever you contact us or use our services, as well as information about other action we take, so that we have an accurate record of what happened.
We may receive the following information from third parties:
- Information about your care and support, including what you would like to achieve with your support
- Information about your finances, including benefits information
- Information about your health and any needs that you have for support
- Information about any relevant legal orders in place to support you
- Information about your housing arrangements, your past and present living situation
- Your skills, interests and strengths
This information may come from:
- Care Managers
- Social Workers
- GP/Health Workers
- CPN
- Speech and Language Therapists
- Other professionals who are part of your multidisciplinary care team, or
- Directly from yourself
Why we need this information about you and how it will be used
- To meet our obligations and duties to you (such as to support you with your health, finances, relationships and activities), following the terms of our contract with you (or our contract with the relevant council on your behalf)
- In connection with the last point, to develop, review and maintain relevant support planning materials, including support plans, risk assessments and support reviews
- To meet our legal obligations by providing information to the Police, when we are asked to do this
- To help us to review and improve the service we provide to you, e.g. by sending you newsletters and surveys, according to Carr Gomm’s legitimate interests, unless you tell us that you do not want to receive these
- To give you information that you ask for
- To respond to any complaints you make or are made on your behalf
- To meet our regulatory and legal obligations, such as reporting information to the Care Inspectorate, Scottish Social Services Council, Adult Support and Protection, Scottish Public Services Ombudsman, Health and Safety Executive, and Duty of Candour;
- To use the information we collect to help us to run and develop our business and the services we offer
- To contact you to send you information about our services and details of any changes to our services which may affect you
- For all other purposes consistent with the proper performance of our operations and business and
- To contact you for your views on our products and services
Sharing of your information
We may disclose your personal data to any of our employees, this will only happen where the information needs to be shared to provide you with support and care. Sharing only takes place in accordance with data protection legislation.
We may also disclose your personal data:
- With a legal representative acting on your behalf, according to their powers
- If you ask any other person to act for you, such as a family member or advocacy worker
- With the Local Authority which commissions and/ or oversees your support service;
- Information about your care and support, activities and health, with relevant carers (including other service providers), friends or family members. This is so we can provide the best service possible to you, according to our legitimate interests, unless you tell us that you don’t want us to share this information
- If you receive support to manage your health, with the relevant health professionals who provide a service to you
- If you ask for our support to make an application for benefits, or if we become your Corporate Appointee for benefits, with the relevant benefits agency or agencies
- If we are required by law to provide information, with the relevant solicitor, Sheriff Officer, or the Police, as appropriate
- If we support you with your housing or maintaining your tenancy, with your landlord, people you live with, utility companies, and with any relevant contractors hired by your landlord to provide you with a service in your home
- If we need to conduct an investigation, for example about a complaint, Health and Safety related incident, whistleblowing or disciplinary action etc. information may be given to the Scottish Public Services Ombudsman, Police Scotland, Local Authority departments, the Care Inspectorate, Scottish Social Services Council, Scottish Fire & Rescue Service, the Health and Safety Executive, and others involved, whether investigating or otherwise
- If we need to instruct an agency to provide staff to support us to deliver your service, with the relevant agency or agencies
- If we need to archive any of the records relating to your support, during the period that we are providing a service to you, with the organisation which provides archiving services on our behalf
- With the relevant regulators and auditors who ask us to disclose information to them about the services we provide to you
- If we are investigating payments made or otherwise, your information may be given to payment processors, such as the Local Authority and the Department of Work & Pensions and
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.
What are the legal bases for us processing your personal data?
We will only process your personal data on one or more of the following legal bases:
- Contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract. This includes where you apply for support from us;
- Consent: where you have given us clear consent for us to process your personal information for a specific purpose. This will only apply in limited circumstances where we have clearly asked for your consent;
- our legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests) For example sending out questionnaires to find out peoples opinions
- vital interests: where our use of your personal information is necessary to protect you or someone else’s life;
- the performance of a task carried out in the public interest and / or with official authority; where our use of your personal information is necessary for us to perform a task in the public interest or for our official functions and the task or function has a clear basis in law. Carr Gomm undertakes no public tasks which require the processing of personal data so this is unlikely to apply.
- legal obligation: where our use of your personal information is necessary for us to comply with the law. This includes where we may have to share information with the Care Inspectorate or the Police
Special categories of personal data
Special categories of personal data means information about your racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; health; sex life or sexual orientation; criminal convictions, offences or alleged offences; genetic data; or biometric data for the purposes of uniquely identifying you.
The “special categories” of sensitive personal information referred to above require higher levels of protection. We need to meet additional legal requirements for collecting, storing and using this type of personal information.
Transfers outside the UK
Your information will only be processed within the UK, except where international transfers are authorised by law.
Security
When you give us information, we take steps to make sure that your personal information is kept secure and safe. All information is kept in line with our data protection policies and procedures, which are available on our website.
How long we will keep your information
We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law / best practice and as detailed in our Data Protection and Confidentiality Policy.
Your rights
You have the right at any time to request us to exercise your data subjects’ rights in relation to the following:
- the right to be informed: covered by this privacy notice
- the right to access
- the right to rectification: there may be instances where it is not appropriate to rectify information, for example, if something was done incorrectly but identified and the correct cause of action taken, the record would show the full picture so would be accurate
- the right to object to processing
- rights in relation to automated decision making and profiling: this is unlikely to apply as we do not carry out automated decision making or profiling
- the right to be forgotten: if there is a legal obligation to keep the information then this does not apply, for example, where there is a contractual obligation to keep the information
- the right to data portability; this is unlikely to apply to Carr Gomm
- the rights to restrict processing: this is not an absolute right and only applies in certain circumstances, for example, where the processing is unlawful or we no longer need the data for the purpose of the processing.
If you would like to exercise any of your rights above, please contact us on 0131 659 4777 or info@carrgomm.org
Queries and Complaints
Carr Gomm has appointed a Data Protection Officer (DPO). Our DPO is provided by RGDP LLP, who can be contacted either by phone on 0131 222 3239 or by email: info@rgdp.co.uk
Any questions relating to this notice and our privacy practices should be sent, in the first instance, to our registered office or by telephoning 0131 659 4777 or by e-mail at info@carrgomm.org
You have the right to complain to the Information Commissioner’s Office in relation to our use of your information. The Information Commissioner’s contact details are noted below:
Telephone: 0303 123 1113
Online: Make a complaint | ICO
The accuracy of your information is important to us – please help us keep our records updated by informing us of any changes to your email address and other contact details.
This Privacy Notice was last updated in August 2024.