Privacy Policy

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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:

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• 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

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1. Information We Collect

We may collect information in the following ways:

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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

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b. Referral & Support Information

Where you are referred to Support Networks by Adult Social Care, we expect the referring team to confirm that you have agreed to the referral and to relevant information being shared with us. 

Where you contact Support Networks directly, we will explain how your information will be used and ask you to confirm your consent before we open a support record, liaise with other organisations, or support you to use UKCIL.

If you are referred to Support Networks or engage with our service, 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 outcomes

• Communication preferences 

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c. Recruitment & Matching (Personal Assistants and Individuals)

If you are:

• Looking for a Personal Assistant, or

• Registering as a Personal Assistant

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We may collect:

• Employment or work preferences

• Experience, skills, and training

• Availability

• References (where applicable)

• Right to work confirmation

• DBS status (where relevant)

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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

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e. Use of UKCIL

Support Networks may support individuals to access the UKCIL platform to advertise for, identify, or communicate with potential Personal Assistants. 

Where UKCIL is used, the way information is controlled and processed may depend on the type of user and how the account has been created:

• "For individuals/employer information entered onto UKCIL through a supporting organisation, the supporting organisation is usually the Data Controller and UKCIL acts as Data Processor."

• "For Personal Assistants data, UKCIL has its own responsibilities as Data Controller and/or Processor, and PAs are required to agree to UKCIL's own privacy and data protection terms."

Support Networks will only support access to UKCIL with your knowledge and consent. 

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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.

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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 your client information.

This means Torbay Council is responsible for deciding why and how your personal information is used. Support Networks will use relevant information to provide support under UKCIL pilot and Direct Payment support arrangements. 

This may include information about your support needs, Direct Payment arrangements, agreed outcomes, risks, safeguarding information, preferences, location, and PA recruitment/support needs.

Torbay Council may also use information gathered through the UKCIL pilot to understand how Direct Payments and PA support are working locally. This may include using information for service planning, contract monitoring, market mapping and understanding local need. 

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Examples may include:

• the number of people using UKCIL;

• general location of clients requiring support;

• types of support being requested;

• expected visit length or support hours;

• numbers of people with particular support needs, such as dementia;

• patterns in PA availability or recruitment difficulties;

• areas where there may be gaps in the local PA market.

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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 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. 

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Individuals who contact Support Networks directly

Where you contact Support Networks directly and are not referred by Adult Social Care, Support Networks is the Data Controller for the information you provide to us as part of the support we offer.

This will usually apply to self-funding individuals or people who approach Support Networks 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;

• help you consider PA recruitment options;

• support you to access or use the UKCIL platform;

• keep appropriate records of the support provided;

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

 

If Support Networks creates your UKCIL login or supports to you access the UKCIL platform, your information will also be handled in line with UKCIL's own privacy policy and data protection terms.

As part of the UKCIL contract arrangements, Torbay Council may have access to relevant UKCIL data for contract monitoring, service planning and market mapping purposes. This may include information about local demand, types of support being requested, general location, support hours or visit patterns, and PA recruitment trends. 

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For individuals who come to Support Networks directly, Torbay Council will not routinely use your information for bespoke individual follow-up unless this has been agreed, is necessary for safeguarding or risk reasons, or another lawful basis applies. 

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Individuals who access UKCIL independently

You may choose to access UKCIL independently without support from Support Networks.

If you choose to access UKCIL directly, this may involve an additional cost to you. In that situation, UKCIL will be responsible for explaining how your information is collected, used and stored under its own privacy policy and data protection terms.

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Support Networks will not be responsible for your UKCIL account or the information you provide directly to UKCIL unless you separately ask Support Networks for support.

 

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."

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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. 

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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 Personal Assistants

• Help you prepare job adverts and recruitment processes

• Facilitate communication between individuals and potential 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.

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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 also support you to use external platforms such as UKCIL for advertising roles. Where this happens:

• You remain in control of your account

• We will only support access with your knowledge and consent

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.

 

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

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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