Flying Start Privacy Notice
This privacy notice covers how Pembrokeshire County Council (as a Data Controller) will collect, use and share your personal data for the purposes of the Flying Start. Flying Start is a Welsh Government funded programme which is targeted at children under 4 years of age and their families, who live in certain areas of Pembrokeshire, with their agreement. The service is delivered jointly by Pembrokeshire County Council and Hywel Dda University Health Board.
Why we need your information (purpose of processing)
We collect and use your personal information so that we can provide the following services:
· High quality part time child care for 2 year olds (term after their second birthday)
· An enhanced health visiting service
· Parenting support
· Language and communication support
When visiting the Flying Start Centre CCTV is in place, this is for the prevention and detection of crime and for staff safety.
The information that you provide will be processed according to the UK General Data Protection Regulation, the Data Protection Act 2018 and Social Services and Well-being (Wales) Act 2014, the Well-being of Future Generations (Wales) Act 2015.
We will also make any disclosures required by law and we may also share this information with other bodies responsible for detecting/preventing fraud/crime or auditing/administering public funds to ensure money is targeted and spent in the most appropriate and cost effective way. In order to achieve this, information will be shared with our Audit Service within Pembrokeshire County Council and with The Auditor General for Wales (Audit Wales Privacy Notice).
We will not make any disclosures to third parties for marketing purposes.
Your data will be secure and confidential at all times and we will only collect the personal information that is required to provide you with our service.
What personal data is being collected?
The categories of personal data being collected are:
· Child’s name and address
· Child’s date of birth
· Child’s NHS number
· Child’s gender
· Parents/carers name and address
· Telephone number
· Preferred language
· Health professionals
· Childcare setting
· Image (CCTV)
What is our lawful basis for processing your personal data?
The UK General Data Protection Regulations (GDPR) requires specific conditions to be met to ensure that the processing of your personal data is lawful. These relevant conditions are below:
Article 6 (1)(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
Article 6 (1)(f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. We rely on this lawful basis in relation to our use of CCTV.
Some types of personal data are more sensitive than others, and need more protection. This is classed as ‘special category data’ and could include information about your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership and the processing of genetic or biometric data, health and sex life and sexual orientation
We process this type of special category data as it is necessary for reasons of:
Article 9 (2)(h) Preventative or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services.
(The relevant Data Protection Act 2018 condition is – Schedule 1 Part 1: Health or social care purposes)
Who will we share your information with?
We may need to share your personal data with internal departments, other organisations and third parties, this will include:
· Children’s Services.
· Adult Safeguarding Team
· Mental Health Team
· Community Drug and Alcohol Team
· Education, including Inclusion Team
· Environmental Health
· Learning Disabilities and Transitions
· Joint Discharge Team
· Community Care including Occupational Health Team
· Dyfed Powys Police and other Police Forces
· Health Boards
· Private/Voluntary run Childcare Settings/Playgroups
· Independent Childminders
· General Practitioners
· Pembrokeshire Association for Voluntary Services
· Carefirst/Eclipse systems who are our Data Processors
Pembrokeshire County Council has a duty to protect the public funds it manages. Therefore, the information that you have provided to us may be used for the prevention and detection of fraud and for auditing purposes both internally and externally.
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by visiting https://www.cifas.org.uk/fpn
How long do we keep hold of your information?
Pembrokeshire County Council will only keep your information for as long as is necessary, we will retain the information provided to us for 75 years from 18th Birthday or for a period of 15 years after date of death for Looked after Children, Children and Young People Subject to Supervision Orders or in relation to Child Protection, for those who do not fall under the above, information will be held for 3 years after closure. CCTV footage is retained for 30 days.
Under the UK General Data Protection Regulation and Data Protection Act 2018, you have rights as an individual including:
- The right to Rectification – you have the right to ask to have your information corrected.
- The right to Restrict processing may apply – you may request that we stop processing your personal data however, this may delay or prevent us delivering a service to you. We will seek to comply with your request but may be required to hold or process information to comply with our legal duties.
- The right to Object – this is not an absolute right and will depend on the reason for processing your personal information.
- The right to Erasure - you may request that we erase your personal data however, this may delay or prevent us delivering a service, or continuing to deliver a service. We will seek to comply with your request but may be required to hold or process information to comply with our legal duties.
- The right to not be subject to Automated decision making and profiling.
- The right of Access – you have the right to ask us for copies of your personal data. To make a request, please contact:
Access to Records
Pembrokeshire County Council
Email: email@example.com Telephone: 01437 764551
Complaints or Queries
Pembrokeshire County Council endeavours to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this seriously. We encourage people to bring to our attention if they believe that our collection or use of information is unfair, misleading or inappropriate.
This privacy notice does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below:
Data Protection Officer
Pembrokeshire County Council
Telephone: 01437 764551
If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office as the statutory body which oversees data protection law:
Information Commissioner’s Office
Telephone No: 0303 123 1113
Our Contact Details as Data Controller are:
Pembrokeshire County Council, County Hall, Haverfordwest, Pembrokeshire, SA61 1TP.
Telephone number: 01437 764551 or firstname.lastname@example.org
Our Data Protection Officer’s information is detailed above in the Complaints and Queries section.
Changes to this privacy notice
We keep our privacy notice under regular review.