Privacy notice relating to the processing of personal data by Rhondda Cynon Taf County Borough Council for the purpose of Independent Living Sensors
Introduction
This privacy notice is intended to provide information about how Rhondda Cynon Taf County Borough Council (referred to as ‘RCTCBC’, ‘Council’, ‘Local Authority’, ‘we’) will use (or ‘process’) personal data about individuals for the purpose of Independent Living Sensors.
Whilst we have tried to make this privacy notice as clear and concise as possible, the categories of personal data we process may vary depending on service user needs. Should you require further information relating to Independent Living Sensors please do not hesitate to contact us using the contact information below.
This notice should be read in conjunction with;
The Data Controller
The Council is the data controller for the personal data processed for the purposes of Independent Living Sensors.
The Council is registered with the Information Commissioner’s Office (ICO) as a controller under reference Z4870100.
Queries relating to this privacy notice
If you have any questions or queries relating to this privacy notice please contact the Support @ Home Team
By email : Alison.Field@rctcbc.gov.uk
By telephone : 01443 425070
In writing : Ty Elai, Dinas Isaf, Williamstown, Rhondda, CF401NY
Who we are what we do
The Support @ Home team provides people with support where required to help them live independently at home, one support tool we use is Independent living sensors.
Independent living sensors can be installed into the homes of service users with a memory problem or dementia diagnosis.
The following sensors can be installed based on individual needs as determined by your social worker or occupational therapist, but is not limited to:
- Door Sensors
- Bed Sensors
- Chair Sensors
- Activity Sensors placed on objects such as toilets, kettles, toaster, medication boxes etc
- Heat & Light Sensors
As a service user goes about their daily life, the sensors are triggered creating data which helps us to determine the level of care required to maintain independent living for as long as possible.
Whose personal data we process
We may process personal data relating to the following individuals when independent living sensors are installed:
- Service Users
- Family Members of the Service Users who has requested access to the sensor data for the wellbeing of family members
The categories of personal data we process
When independent sensors are installed we process the following data:
Service User
- Name
- Address
- D.O.B
- WCCIS Number
- Health, such as illness details and the stage of your illness
Family Member
- Name
- Address
- D.O.B
- Email Address
Why we process the personal data
We use independent living sensors and process the personal data for the following but not limited to activities:
- To provide Independent living Sensors to aid living independentely for as long as possible.
- To monitor activity and movement, to help us to determine the level of care required
- To provide us with alerts for any change in behaviour or habits allowing us to respond quickly and effectively to any potential emergency.
- To provide family members with access to the data created through the sensors.
Our lawful basis for processing the personal data
Under the General Data Protection Regulation (GDPR), our lawful basis for processing the personal data for Independent Living Sensors is:
- Public Task - Article 6 (e) – processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
- Schedule 1, Part 1, Paragraph 2 - Data Protection Act 2018
- Health or Social Care - Article 9 (2) (h) - processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care systems and services on the basis of Domestic Law or pursuant to contract with a health professional and subject to conditions and safeguards referred to in Paragraph 3.
The primary legislation, regulations and guidance that supports this includes, but is not limited to;
- The Social Services and Well-being (Wales) Act 2014
- The Mental Capacity Act 2005.
- The Care Standards Act 2000
- The Regulation and Inspection of Social Care (Wales) Act 2016.
Who or where we get the personal data from
We obtain the personal data directly from service users through activity and monitoring sensors.
Who we share personal data with
We may share the personal data with the following key organisations for Independent Living Sensors
When sharing the personal data, we only share the minimum amount necessary in relation to the purpose.
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Who
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Purpose
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Family Members
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To have access to the activity and movement data for the wellbeing of their family members.
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Cwm Taf Morgannwg Health Board
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Data is shared with Colleagues employed by health, working in RCT CBC’s mulit disciplinary teams to determine the level of care and support required.
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Data Processors
A data processor is a company or organisation that processes personal data on our behalf. Our data processors act only upon our instruction. They cannot do anything with the personal data unless we instruct them to do so. They will not share the personal data with any organisation apart from us or use it for their own purposes. They will hold it securely and retain it for the period we instruct.
- IT System Suppliers / Service Providers
How long we retain the personal data
We retain the personal data contained within Independent Living Sensor records for:
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Length of time
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Reason
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Sensor data is retained for 7 years
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Business Need in line with Council Policy.
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In keeping with the General Data Protection Regulation storage limitation principle, records are periodically reviewed. Not all personal data is retained. Only personal data that is relevant to the record is retained for the entire retention period Information that has no long term or evidential value is routinely destroyed in the normal course of business.
Your data protection rights
The General Data Protection Regulation (GDPR) gives individuals important rights, including the right of access to the personal data that the Council holds about you.
Click here for further information on your information rights and how to exercise them.
Your right to make a data protection complaint to the Council
You have the right to complain to the Council if you believe we have not handled your personal data responsibly and in line with good practice.
You can do this by contacting the Support @ Home Team directly via one of the following communication methods. Most concerns can be resolved relatively quickly through a simple phone call or email;
- Email : supportathome@rctcbc.gov.uk
- Telephone : 01443 425070
- In writing : Ty Elai, Dinas Isaf, Williamstown, Rhondda, CF401NY
Alternatively, you can raise a formal complaint via the Council’s Customer Feedback Scheme using the following link (Make a comment, compliment or complaint online) or you can contact the Council’s Data Protection Officer at Information.management@rctcbc.gov.uk.
Your right to make a data protection complaint to the ICO
You also have the right to complain to the ICO if you are unhappy with how we have used your data. However, we encourage you to contact us first and provide us with an opportunity to look into your concern and put things right.
The ICO can be contacted:
- Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- Helpline number: 0303 123 1113
- Website: https://www.ico.org.uk