Privacy Policy

​​​

Welcome to Support Networks, a project delivered by Windmill Torbay ("we", "our", or "us").

This Privacy Policy explains how we collect, use, and protect your personal information when you:

​

• Use our website

• Contact us for support

• Are referred to our service

• Engage with us to find or become a Personal Assistant (PA)

We are committed to protecting your privacy and handling your data in a transparent and secure way

​

1. Information We Collect

We may collect information in the following ways:

​

a. Contact Form

When you contact us via our website or email, we may collect:

• Your full name

• Email address

• Phone number (optional)

• Details of your enquiry

​

b. Referral & Support Information

Support Networks works with people who are referred to us by Adult Social Care, community partners as well as people who contact us directly. Where you are referred by Adult Social Care, we expect the referring team to confirm that you have agreed to the referral and to the sharing of relevant information with us. 

Where you contact Support Networks directly, we will explain how your information will be used and ask for your consent before we create a support record, contact other organisations on your behalf, or provide ongoing support.

Depending on the support you receive, we may collect:

• Full name and contact details

• Date of birth

• Information about your support needs and preferences

• Details relating to your Direct Payment

• Information about your goals and  desired outcomes

• Communication preferences 

​

c. Recruitment & Matching (Personal Assistants and Individuals)

If you are:

• Looking for a Personal Assistant, or

• Registering as a Personal Assistant

​

We may collect:

• Employment or work preferences

• Experience, skills, and training

• Availability

• References (where applicable)

• Right to work confirmation

• DBS status (where relevant)

​

d. Special Category Data

Some information we collect may be considered sensitive (special category data), including:

• Health conditions

• Disability or access needs

• Support requirements

This data is only collected where necessary and is handled with additional safeguards in line with UK GDPR.

​​

​

2. How Your Information is Controlled and Used

Support Networks works with individuals in different ways. The organisation responsible for deciding how your personal information is used will depend on how you come into the service.

​

Individuals referred by Adult Social Care

Where you are referred to Support Networks buy Torbay Adult Social Care, Torbay Council is the Data Controller for the personal information shared as part of your referral.

Support Networks processes relevant information on behalf of Torbay Council in order to deliver the services we have been commissioned to provide.

This may include information about:

​​

• your care and support needs;

• Direct Payment arrangements;

• agreed outcomes;

• communication preferences;

• risks and safeguarding information where appropriate;

• Micro Provider/PA recruitment or support requirements.

Torbay Council may use anonymised or aggregated information gathered through the service to:

• understand local demand;

• improve Direct Payment services;

• monitor commissioned services;

• support market development;

• plan future services

Where possible, this information will be anonymised so individuals cannot be identified.

​

Torbay Council may also use information to identify where a person may need additional or more bespoke support. For example, if a person has experienced a high turnover of Micro Providers or Personal Assistants over a six-month period, Support Networks or Adult Social Care may contact them to better understand what is happening and offer appropriate support.

Wherever possible, information used for wider service planning, market mapping and reporting will be anonymised or aggregated so that individuals are not directly identified. 

​

Individuals who contact Support Networks directly

Where you contact Support Networks directly and are not referred by Adult Social Care, Support Networks (Windmill Torbay) is the Data Controller for the personal information you provide.

This commonly applies to people who are self-funding or who approach us independently.

Support Networks may collect and use relevant information to:

• respond to your enquiry;

• understand what support you are looking for;

• provide information, guidance and practical support;

• support you to recruit Micro Providers and Personal Assistants;

• keep appropriate records of the support provided;

• manage safeguarding, risk, complaints or service quality issues.

We will not share your information with Torbay Council unless:

• you have given your consent;

• sharing is necessary for safeguarding;

• we are legally required to do so; or

• another lawful basis under UK GDPR applies.​

 

3.Lawful Basis for Processing (UK GDPR)

We process your personal data only where we have a lawful basis to do so. Depending on the circumstances, this may include:

• "Consent - where you ask us to support you and agree to us using your information for that purpose."

• "Legitimate interests - where we need to keep appropriate records, respond to enquiries, manage the service, or provide support you have requested."

• "Legal obligation - where we are required to keep or share information by law."

• "Vital interests or safeguarding necessity - where information needs to be shared to protect someone from serious harm."

​

Some information we collect may be special category data, such as health, disability, care and support needs, or safeguarding information. Where we process this type of information, we will identify an additional lawful condition under UK GDPR. This may include your explicit consent, or another condition where required for safeguarding, social care, or legal reasons. 

​

4. How We Use Your Information

We use your information to:

• Respond to enquiries and provide guidance

• Support you to understand and manage Direct Payments

• Assist with recruitment and matching of Micro Providers and Personal Assistants

• Support you throughout the recruitment process, including preparing job adverts and interview guidance

• Facilitate communication between individuals and potential Micro Providers and PAs

• Maintain appropriate records for safeguarding and service delivery

• Improve and develop our services

We do not sell your data or use it for marketing purposes without your consent.

​

5. Who Has Access to Your Data

Your data is only accessed by authorised individuals involved in delivering the Support Networks service, including:

• Support Networks staff

• Project coordinators

• Safeguarding leads, where necessary

We may with your consent, work alongside partner organisations or professionals involved in supporting you. Information will only be shared where it is necessary, appropriate and lawful to do so

​​

We do not share your personal data with third parties unless:

• You have given explicit consent

• It is required for safeguarding

• It is required by law

 

6. How Long We Keep Your Data

We retain your data only for as long as necessary to:

• Provide support and deliver the service

• Meet safeguarding and legal obligations

• Maintain accurate records

After this, your data will be securely deleted or anonymised in line with our data retention policy.

​

7. Data Security

We take data security seriously. Information collected through:

• Website forms (Wix)

• Email communication

• Secure system

is stored securely with:

• Restricted access

• Password protection

• Encryption where appropriate

We take all reasonable steps to prevent unauthorised access, misuse, or disclosure.

​

Complaints about your personal information

If you are unhappy about how we have handled your personal information, please contact us in the first instance so we can try to resolve your concerns.

If you remain dissatisfied, you have the right to complain to the Information Commissioner's Office (ICO).

Website: https://ico.org.uk

Telephone: 0303 123 1113

 

8. Your Rights Under UK GDPR

Under UK data protection laws, you have the following rights:

• Access the personal data we hold about you

• Correct inaccurate or incomoplete data

• Request deletion of your data

• Restrict processing in certain circumstances

• Object to how your data is used

• Withdraw consent at any time (where applicable)

• Request data transfer to another provider

To exercise any of these rights, please contact us at:

📧 manager@windmilltorbay.org.uk

 

9. Safeguarding

As a service working with individuals who may be vulnerable, we may share information without consent where necessary to protect someone from harm, in line with safeguarding laws and guidance

​

​

10. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page, and the effective date will be updated.

 

11. Contact Us

If you have any questions or concerns about this Privacy Policy or how we handle your personal data, please contact us at:

📧 manager@windmilltorbay.org.uk
🌐 01803 314876