Your Privacy

Some of these are classified as personal information. Others are classified as special category personal information, which implies they are more sensitive and require a higher degree of confidentiality and protection.

• Name and title
• Physical address and email address
• Mobile and telephone numbers
• Financial and economic data
• Gender, Date of Birth, Place of Birth and Age
• Sexuality and marital status
• Health records
• Criminal convictions, record of allegations and other law enforcement information
• Education, academic and home schooling information
• Religious, political or philosophical information
• Genetic and Biometric information
• Employment information
• Family relationships
• Audio, video, CCTV and still photograph images

The Trust may collect personal information directly from you through:

• Electronic or paper forms
• Email or letter correspondence
• Documents and records you share with us
• During in-person, telephone or virtual interviews
• When you visit our office location

Your personal information may also be collected indirectly through:

• Specialist partner organisations. For example child adoption agencies
• Local authorities
• Law enforcement services
• Educational institutions
• The NHS
• A General Practitioner (GP)

Data Protection Impact Assessment

The Trust has published it’s Data Protection Impact Assessment which you can download by clicking the link below:

Data Protection Impact Assessment Summary Table

Before we process personal information, we must stand on a valid legal footing. These legal footings are called Lawful Basis. A valid lawful basis will be required for processing personal information or special category personal information as the case may be.

• Where you give us Consent
• Where we have to process personal information to comply with a legal obligation in which you are the subject
• Where we have to protect your vital interests or the interests of another living person
• Where we have to act in the public interest or in exercising our official authority as a Children’s Trust

• Where you give us explicit Consent
• When we provide social protection and welfare for you and others
• To protect your vital interests or the interests of another living person
• Where we have to establish or defend legal claims or when a competent Court gives us an order
• Where is significant public interest in processing the personal information
• For assessing someone’s working capacity and facilitating the provision of social care
• For facilitating scientific and historical research and statistical purposes

There are a host of laws that regulate our approach to service delivery. They include:

• Children Act 2004
• Children and Adoption Act 2006
• Children and Families Act 2014
• Children and Social Work Act 2017
• Children and Young Persons Act 2008
• Foster Service Regulations 2011
• Safeguarding Vulnerable Groups Act 2006
• Care Planning, Placement and Case Review and Fostering Services (Miscellaneous Amendments) Regulations 2013
• The Care Act 2014
• The Mental Health Act 1983
• The Mental Capacity Act 2005
• The Human Rights Act 1998
• The Disability Discrimination Act 1995
• The Health and Social Care Act 2015
• The General Data Protection Regulation 2016
• The Privacy and Electronic Communications Regulations 2003
• The Data Protection Act 2018
• The Employment Relations Act 1999
• The Race Relations Act 1976
• The Recognition of Trusts Act 1987

This list is in no way exhaustive and significant inclusions by Parliament can happen in the future

Please refer to the Records Retention Schedule documentation

To ensure we can provide you with the best possible service, we may have to share personal information with partner organisations and public authorities. Here is a comprehensive list of them.

Public Authorities we Share Personal Information with:

• The Cabinet Office, with Members of Parliament and other Elected Representatives
• The Office for Standards in Education, Children’s Services and Skills (Ofsted)
• Police Forces and the Fire Service
• The National Health Service and General Practitioner Services
• Her Majesty’s Revenue and Customs and the Department for Work and Pensions
• Local Authorities
• Some Schools and Educational establishments
• The Home Office
• The Disclosure and Barring Service
• Members of Parliament and other Elected Representatives
• The Courts and the Children and Family Court Advisory and Support Service
• The Information Commissioner’s Office (ICO)
• Other Public Authorities and Government Departments

Other Non-Public Authority Organisations we Share Personal Information with:

• The National Society for the Prevention of Cruelty to Children (NSPCC)
• Citizens Advice
• Child Adoption Services
• Legal Practices
• Interpreting Services
• Other Specialist Service Provider and Partner organisations

The Right to be Informed

You have the right to be told what, why and how the Trust use your personal information. This Privacy Notice communicates to the public, the right to be informed.

The Right of Access

You have the right to know what personal information we hold about you. We will normally process your right of access within one calendar month, depending on the scope, complexity and volume involved. Not to worry, we will always keep you informed.

The Right to Rectification

If you have cause to believe the information we hold about you is inaccurate, you have the right to request that we correct it. Of course we will investigate and determine the validity of your claim and if we uphold it, we will correct it without delay.

The Right to Erasure

Where the purpose for processing your personal information has lapsed, you may have the right to request that we securely dispose of it. Not all records are subject to this right. Whatever the case may be, we will provide you with an explanation.

The Right to Restrict Processing

In certain circumstances, you have the right to request that we limit the use of your personal information. We will usually carry out an investigation to determine whether your claim is valid or not. During this period, we will keep you updated about our investigation and eventually our conclusion.

The Right to Data Portability

Sometimes you may be able to request that your personal information be securely and electronically passed on to another organisation, to ease transition of a service.

The Right of Object

You may have cause to disapprove of certain uses for your personal information. For example where you consider the processing not to be aligned with the original purpose for which it was collected, for direct marketing or for research. You can ask us to stop processing and we will respect your wishes where the objection is valid.

The Right to Object to Automated Processing

Where your personal information is automatically manipulated by computers without human intervention, and the result has an impact on decisions we make about you, you have the right to request that this process be manually conducted.

The Right to Withdraw Consent

Where it is established that the lawful basis for processing your personal information is consent or explicit consent, you have the right to withdraw your consent at any time.

For administrative purposes, when you exercise any of your rights, we refer to the process as a Subject Access Request (SAR). Although we encourage you to make your request in writing, you do not have to. You can make your request verbally and in person.

If your personal information is under the Trust’s control, 99% of the time you will have the right of access.

To exercise your right of access, please follow the steps below:

Step 1 – Decide what records you seek. For example, supervision, review or assessment records

Step 2 – As much as possible, be specific about the timeframe. For example, the last one year or 2010 – 2015

Step 3 – Note the service and Trust officers involved, if you have that information. This is not essential requirement

Step 4 – Check that you are eligible to make a valid request

Step 5 – Complete the Subject Access Request (SAR) form which you can download by clicking here

Step 6 – Forward the completed SAR form to us at info_governance@sandwellchildrenstrust.org

For a request to be valid, it must be submitted by someone with the appropriate authority to do so. Here you will find a list of eligible individuals and those with the authority to make a valid request for access on their behalf:

Clarification Requests

Here at the Sandwell Children’s Trust, we have a high ranking officer whose responsibility is to independently advocate for your information rights. The designation for this individual is Data Protection Officer (DPO). The law grants the occupant of this office, certain powers to make independent assessment for your information rights. It is advised that you contact the Trust’s DPO, to give them an opportunity to review your case, before making any complaint to the ICO.

The Information Governance team at the Trust answer to the DPO.

You can contact the DPO directly at:

Office of the DPO
Sandwell Council House
Freeth Street
Oldbury
B69 3DE

Email: dp_officer@sandwell.gov.uk

The Information Commissioner Office (ICO) is our Supervisory Authority for Information Rights. You have the right to lodge a complaint with the ICO if you feel we have infringed your right of access.

You can contact the ICO at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Email: casework@ico.org.uk