Adoption@Heart Regional Adoption Agency – Privacy Notice

March 2019

1. Overview

The following privacy notice applies to the Adoption@Heart Regional Adoption Agency hosted by the City of Wolverhampton Council.

Adoption@Heart Regional Adoption Agency collects, holds and processes personal information about enquirers, prospective and approved adopters, children for whom adoption is the plan, adoptive families accessing adoption support, birth families accessing adoption support and adopted adults wishing to access their adoption records, to allow it to provide adoption services as required by statutory guidance on behalf of the four Local Authorities /Trust (City of Wolverhampton Council, Dudley Metropolitan Borough Council, Walsall Metropolitan Borough Council and Sandwell Children’s Trust).

This privacy notice tells you what to expect when the organisation processes your personal information, how it is used, shared and secured. Your privacy is important to us and we are therefore committed to handling your personal data in accordance with the provisions of the Data Protection Act 2018 and the General Data Protection Regulation 2016/679.

2. Why we process data

We collect and use your personal data for several reasons depending on how you interact with us. Some of the reasons given below are things we must collect for compliance with a legal obligation or associated statutory obligations, these include but are not limited to:

  • Education and Adoption 2016
  • Adoption and Children Act 2002
  • The Local Authority Adoption Service (England) Regulations 2003
  • Adoption Agencies Regulations 2005
  • The Adoption Support Agencies (England) and Adoption Agencies (Miscellaneous Amendments) Regulations 2005
  • (Data Protection Act 2018) (General Data Protection Regulation 2016/679

This allows us to:

  • Provide a full range of adoption services to local people
  • Provide support to children who require an adoption service
  • Provide support to adoptive families, including adopted adults and the family members of adopted people

In addition, we will also process your information where you have signed up to receive a service Adoption@Heart offers or where you have given your consent for us to use your details, this enables us to:

  • understand your needs to provide the services that you request
  • promote the services we provide
  • ensure that all those affected by adoption are aware of our services and how to access them
  • carry out surveys and get your opinion on our services
  • undertaking research

We may not be able to provide you with a service unless we have enough information, or your permission to use your information. We aim to keep your information accurate and up to date at all times.

3. Categories of Data that we collect

Personal, or special category data of a more sensitive nature, may be collected about you depending on your service requirements and may include but is not limited to:

  • personal details (name, date of birth)
  • identification numbers (e.g. NHS number, National Insurance Number)
  • financial details
  • family details and family history
  • lifestyle and social circumstances
  • services received
  • economic / financial details
  • employment and education details
  • housing needs
  • visual images, personal appearance and behavior
  • licenses or permits held
  • student and pupil records
  • business activities
  • case file information
  • birth/death data provided by/to the office of national statistics
  • physical or mental health details
  • social care needs
  • racial or ethnic origin
  • trade union membership
  • political affiliation
  • political opinions
  • offences (including alleged offences)
  • religious or other beliefs of a similar nature
  • criminal proceedings, outcomes and sentences
  • genetic or biometric data
  • sex life or sexual orientation
  • proof of citizenship/residence
  • personal or work-related references

Equalities information
Adoption@Heart may use information for statistical reasons about the take up of the organisation’s services by various groups, such as your:

  • ethnic background
  • first language
  • gender
  • sex life or sexual orientation
  • age

This is to help comply with our legal obligations and to plan the provision of future services. Such analysis will not identify individuals, nor will it have impact to an individual’s entitlement to organisation services and facilities.

4. Who your data is shared with

Your personal information may be shared with

  • Other local authorities who have children with adoption plans
  • Individuals and agencies who are required to provide reference checks.
  • Foreign embassies if living abroad for application checks.
  • Voluntary agencies who work closely with the regional adoption agency.
  • Providers of adoption support services.
  • National Adoption Register.
  • Courts
  • Other statutory services according to your assessed need e.g. health and housing

The detection and prevention of fraud
We are required by law to protect our public funds; therefore, we may use any of the information you provide to us for the prevention and detection of fraud or to comply with the law.

5. How we collect your data and from where

Face to face:

We may keep a record of your contact in order to assist on the delivery and improvement of the services we provide to you and others. Any such records that include any personal information will be kept securely.

Telephone calls:

Ordinarily we will inform you if we record or monitor any telephone calls you make to us. This is to increase your security, for our record keeping of the phone call and for training and quality purposes.

Emails:

If you email us we may keep a record of your contact and your email address for our record keeping. We will not include any confidential information about you in any email we send to you unless sent securely or you have agreed to us contacting you with this information. We would also suggest that you keep the amount of confidential information you send to us via email to a minimum.

On paper:

You may complete assessment forms or request forms on paper that you send to us. You may write us letters and send these in on paper.

Online:

You may complete online forms, make requests, or make online payments to us.

We employ cookie technology to help log visitors to our website. A cookie is a string of information that is sent by a web site and stored on your hard drive or temporarily in your computer’s memory. The information collected is used for the administration of the server and to improve the service provided by the web site. No personal information is collected this way. You can reject the use of cookies but you may be asked for information again, e.g. to participate in a survey.

Google Analytics cookies

  • Function-based – this type of cookie is used to remember information about how you use a website, and provide analytical information to site administrators.
  • Third-party – this type of cookie is created by a third-party.

Purpose – Analytical information is captured in some areas of the main site, to help us improve services and better understand user requirements. This information is captured through a free service provided by Google (Google Analytics), using multiple cookies. See specific information on the cookies used by Google Analytics.

How to block – Google Analytics cookies can be blocked in a number of different ways. Google offers an opt-out browser add-on for most modern web browsers, or cookies can be disabled directly within your browser. What would happen – Blocking Google Analytics cookies will provide no reduced service to you, but we will be unable to capture detailed information about your experience online.

The City of Wolverhampton Council’s privacy and cookies notice can be found here: www.wolverhampton.gov.uk/privacy-policy
Information about the Adoption@Heart privacy and cookies policy can be found here: www.adoptionheart.org.uk/privacy-policy

On systems:

We may log any information you provide to us on a computer system to help us keep track of your application, or any actions we need to complete. We may add your information to systems where we are required to by laws.

From other sources:

We may receive information about you from other organisations or agencies such as:

  • Providers of goods and services
  • Local and central government (e.g. Department of Work and Pensions, HMRC)
  • Health bodies (NHS Trusts, GPs)
  • The Police
  • The Disclosure and Barring Service (DBS)
  • Courts, prisons
  • Other Local Authorities and Regional Adoption Agencies
  • Voluntary Adoption Agencies and Adoption Support Agencies.

We will receive information about you either for a legal reason or because you have asked for your information to be shared with us. Information can be provided to us by any of the other formats described in this section. We may add this information to our systems to record and hold it as part of your record with Adoption@Heart.

6. How your data is used

Information which you have provided Adoption@Heart will be stored securely. It will be used for the purposes stated when the information was collected, and not reused for different purposes or sold on to others.

Your data will be placed on an appropriate system, such as the Adoption@Heart’s case management system, the National Adoption Register and other systems to support family finding activity, and used to provide or administrate that service. We may cross reference this data between systems to keep your information as accurate and up to date as possible in line with Data Protection best practice.

All adoption records are kept for 100 years in line with legislative requirements. If prospective adopters are unsuccessful or withdraw an application or resign their approval, records will be kept for 10 years. Please note: all stated retention periods will be subject to any legal holds imposed under the Inquiries Act 2005 that may concern the information and override standard retention.

7. Our responsibilities

Everyone working for Adoption@Heart has a legal duty to keep information about you confidential and secure, for specific purposes and only for as long as necessary. This is all in accordance with the following legislation and best practice guidance:

  • Data Protection Act 2018/ General Data Protection Regulation 2016/679
  • Education and Adoption 2016
  • Adoption and Children Act 2002
  • The Local Authority Adoption Service (England) Regulations 2003
  • Adoption Agencies Regulations 2005
  • The Adoption Support Agencies (England) and Adoption Agencies (Miscellaneous Amendments) Regulations 2005
  • Computer Misuse Act 1990
  • Human Rights Act
  • Caldicott Principles relating to confidentiality.
  • Lord Chancellors Code of Practice on Records Management

Where we share information with other bodies or agencies, we will ensure the confidentiality and security of your data. This will normally be done by having a contract and confidentiality clauses in place in addition to any information sharing agreements, where required. We also carry out data privacy impact assessment each time we start a new project, to help us build in security and privacy to protect your information. We will keep your information in line with legislation and guidance on records retention periods. We will not keep your information longer than it is needed. We will dispose of paper records or delete any electronic personal information in a secure way.

For more detail on how we work within these guidelines please reference our Information governance policies here: www.wolverhampton.gov.uk/igov

8. Your Data Rights

Under the Data Protection Act 2018 and General Data Protection Regulation 2016/679 you have rights of how your personal information is used.

  • You have the right to be informed of how Adoption@Heart processes your data. This Privacy Notice explains this. Where you have signed up to a service which relies on your consent alone (i.e. those services not covered by a statutory duty) you have the right to withdraw your consent.
  • The right for your information to be rectified or restricted.

You have do not have any other information rights.

For further information about your rights to how your personal information is used please see the ICO guidance here: https://ico.org.uk/for-the-public/

Please see the City of Wolverhampton Council’s full privacy notice for further details on our core data protection obligations: City of Wolverhampton Council Full Privacy Notice

If you wish to raise a concern with us in relation to your data/information, please contact us at DPO@wolverhampton.gov.uk

For access to your personal information – please contact Adoption@Heart at https://www.adoptionheart.org.uk/im-adopted if you need access to your adoption records.

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