Privacy Policy

In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our foster carers, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that allows us to do so, how long we keep your data for and your rights regarding your data.

‘Processing of data’ means:

· Collection and recording of information

· Use of that information or data

· Organising and retrieving data

· Adapting, altering or modification of the data

· Transmitting that data

· Making the data available (eg on a website)

· Destroying, blocking or erasing data

Data Protection Principles

Under GDPR, all personal data obtained and held by TFF must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

· Processing is fair, lawful and transparent 

· Data is collected for specific, explicit, and legitimate purposes

· Data collected is adequate, relevant and limited to what is necessary for the purposes of processing

· Data is kept accurate and up to date.  Data which is found to be inaccurate will be rectified or erased without delay

· Data is not kept for longer than is necessary for its given purpose

· Data is processed in a manner that ensures appropriate security including protection against unauthorised or unlawful processing, accidental loss, destruction or damage 

· We comply with the relevant GDPR procedures for international transferring of personal data.

Types of Data Held

We keep several categories of personal data on you in order to carry out effective and efficient processes.  This data is held in a Database, and your foster carer electronic file, but some archived information may still be held on paper files which are kept securely in locked cabinets. 

Specifically, we hold the following types of data:

· personal details such as name, address, phone numbers

· your photograph

· your gender, marital status, race, religion, 

· your medical information and information of any disability you have 

· information gathered via your application form, your full Form F assessment report and annual reviews

· references 

· details of your education and employment history etc

· health and safety checks, including driving licence

· National Insurance numbers

· bank account details (not held by TFF once this has been sent to the accountant)

· details of allowances and expenses 

· outcome of your DBS check

· your foster carer agreement

· placement history

· supervision notes

· details of allegations, complaints

· training undertaken.

Collecting your Data

You provide several pieces of data to us directly during the assessment period and subsequently upon the start and duration of your registration with TFF. 

We will also collect data about you, with your consent, from third parties, such as your GP, the local authority, the police, former employers, former partners, family members, friends and other relevant people, when gathering references and information for your assessment.

Lawful Basis for Processing

The law on data protection allows us to process your data for certain reasons only.  In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the fostering contract we have with you, including ensuring you receive effective support and supervision, and are paid correctly.

Special Categories of Data

GDPR identifies special categories of data as data relating to your: 

· health

· sex life

· sexual orientation

· race

· ethnic origin

· political opinion

· religion

· trade union membership 

· genetic and biometric data.

We carry out processing activities using special category data for the purposes of assessment and matching (complying with our legal obligation, for the performance of our contract with you and with your consent).

Failure to Provide Data

Your failure to provide us with data may mean that we are unable to fulfil our requirements to assess you as foster carers. 

Data for the purpose of a DBS check

We only collect this data where it is appropriate given the nature of your role and where the law permits us. This data will be collected at Stage 1 of your assessment, and also routinely during your registration as a foster carer. We use this data to determine your suitability, or your continued suitability for the foster carer role.  We rely on the lawful basis of legal obligation to process this data.

Sharing your Data 

Employees within TFF, and independent reviewing officers and panel members, who have responsibility for recruitment, assessment and approval, administration of payment, delivering of support, training, and supervision, and monitoring, will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processed in line with GDPR. 

Data is shared with third parties for the following reasons: for payment of fostering allowances, with specific local authority staff for the matching of placements, or other specific reason for which you have given consent such as the provision of a reference. 

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

Protecting your Data

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction or damage, and implement appropriate technical or organisation processes to guard against such possibility.  

Retention Periods

We only keep your data for as long as we are required to. This will at least for the duration of your registration, and for 10 years after de-registration. Information about unsuccessful foster applications will be kept for 3 years as legally specified. 

Automated Decision Making 

Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision in TFF is made on the basis of automated decision making.

Your Rights 

You have the following rights in relation to the personal data we hold on you:

· The right to be informed about the data we hold on you and what we do with it.

· The right of access to the data we hold on you. More information on this can be found in our separate policy on Subject Access Request.

· The right for any inaccuracies in the data we hold on you, however they come to light, to be corrected or ‘rectified’. 

If you wish to have any data corrected, or incomplete data completed, you need to put your request in writing to your SSW or team manager. Usually your request will be dealt with within one month unless the request is particularly complex, in which we will inform you of the need for an extension, for a maximum period of two months. 

· The right to have data deleted in certain circumstances. These include: when we no longer need to keep the data; where we have unlawfully processed your data; where we are required by law to erase it; where we relied on your consent to process the data and you subsequently withdraw your consent (and there is no other legal basis for our continued use of that data); where you object to the processing of the data and TFF has no legitimate interest to continue the processing. 

If you wish to make a request for data deletion, you should put your request in writing to your manager. We will consider each request individually, however, you must be aware that processing may continue under one of the permissible reasons. Where this happens, you will be informed of the continued use of your data and the reason for this.

· The right to restrict the processing of the data. If you wish to make a request for data restriction, you should contact your manager in writing. 

Where data processing is restricted, we will continue to hold the data but will not process it unless you consent to the processing or processing is required in relation to a legal claim.

· The right to transfer the data we hold on you to another party, or ‘portability’. Data which may be transferred is data which:

a) you have provided to us; and

b) is processed because you have provided your consent or because it is needed to perform the fostering contract between us.  

If you wish to exercise this right, please speak to your SSW or team manager.

The right to data portability relates only to data defined as above. You should be aware that this differs from the data which is accessible via a Subject Access Request.

· The right to object to the processing of data. If you wish to object, you should contact your SSW or team manager in writing. 

In some circumstances, such as there are legitimate reasons to do so, which are believed to be more important than your rights, or the processing is required in relation to legal claims made by, or against, we will continue to process the data you have objected to. 

If the response to your request is that we will take no action, you will be informed of the reasons.

· The right to regulate any automated decision-making and profiling of personal data.

Consent

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data. 

Making A Complaint

If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.

Data Protection Compliance

Our appointed compliance officer in respect of our data protection activities is:

Mandy Perry: Tel: 07841 342113  
Email: mperry@fosteringfoundaiton.co.uk