Advice and Advocacy Service Privacy Policy

Information to help us provide you with advice

When you contact us for advice by phone, webchat, email or online enquiry form we will ask you for information that is relevant to the situation that you are contacting us about. The lawful basis on which we will seek to collect this information from you is ‘legitimate interest’. However, if when describing the situation that you need help with, you share with an adviser relevant but especially sensitive information (e.g. about your health, race, ethnic origin, religion – known as ‘special category data’) then we will usually be processing this information on the basis of ‘social protection’ unless the information shared indicates an immediate threat to life and limb, in which case the basis will be the ‘vital interest’.

The information that an adviser may ask you for will include:

• Your name and contact details so that we can:
  • Send you advice materials (e.g. advice sheets)
  • Identify the record relating to any previous contact with the advice and advocacy service which will help our advisers understand the background and the advice you have previously been given.
• Relevant personal information that will help us to provide you with the right information and advice for your situation.

We keep this information in a case record. We will explain this to you at an early stage of your enquiry and ask you to confirm if you agree to a record being created (there is further information about how we use case records in the ‘if we are concerned about your safety or the safety of someone else’ tab below).

We will only ask for the personal information that we need and we will:

• Always let you decide what you’re comfortable telling us about your situation
• Explain to you why we need the information that we ask you for and how we use your information
• Treat your information as confidential.

If there is certain information that you don’t want to give to us, you don’t have to. For example, if you inform us that you want to stay anonymous we’ll only record information about the problem you are contacting us about and make sure you’re not identified.

Information to help us understand who is using our service

When you contact us for advice we will usually also ask you for some additional monitoring information. Collecting this monitoring information helps us to understand more about who is using our advice service. If there is certain information you don’t want to give us, then you do not have to share this with us and can state that you ‘prefer not to say’ when we asked you any monitoring question.

The lawful basis on which we collect and use monitoring information is ‘legitimate interest’. If, however, the monitoring information being sought is about whether you have a disability, or is about your ethnicity, this is a more sensitive type of information. It is known as ‘special category data’.

The lawful basis on which we collect and use that kind of more sensitive information is ‘explicit consent’. We will ask, and formally record, whether you consent to us collecting and recording that information about you. It is up to you whether you give your consent or not. You do not have to.

Information to help us understand more about children involved with, or in need of help from, children’s services

We will also usually ask you for some additional monitoring information about the child/ren whose situation you have contacted us about.

The information about the child/ren that we may ask for is their:

• Age
• Ethnicity
• And whether they have a disability.

Information about a child’s ethnicity and disability is considered especially sensitive. It is known as ‘special category data’. Collecting this kind of sensitive data helps us to understand more about which children it is that social workers become involved with. The lawful basis on which we collect and use this information is ‘legitimate interest’ and on the condition of ‘substantial public interest – equality of opportunity or treatment.’

If there is certain information that you do not want to give us about the child or children, then you do not have to share this with the adviser.

When we record and use your personal information we:

• Only access it when we have a good reason
• Only share what is necessary and relevant
• Don’t sell it to anyone.

The main reason we ask for your information is to help us to provide the most accurate information and advice to help you with your situation.

We will however also access your information so that we can use information for:

• Training and quality assurance purposes to help us to provide a high quality service
• Looking into complaints.

We will also access your information in order to help us understand more about families involved with the child welfare system and the difficulties that they face. This includes creating statistics and case studies about:

• Who is contacting us for advice and help
• What problems families most commonly face.

This information is always anonymised. This means you can’t be identified. We share this kind of information with funders and government departments. And publicly in Family Rights Group reports, articles and presentations, press releases, social media and blogs. The statistics also inform our policy research, campaigns, or other media work.

If we are providing you with advice as part of a specific indirect or self-advocacy project that Family Rights Group is running, then we might also need to share some of your information with other organisations.

For example:

• Within a letter to a children’s services department social worker or manager that you have asked us to write to on your behalf
• In order to refer you to another organisation for specialist advice on an issue that we cannot assist you with.

We would only share your information in this way if you have given your permission for this to happen.

Any organisation we share your data with must store and use your data in line with data protection law.

During an advice telephone call, advisers may take notes to assist in the conversation. These notes are shredded afterwards.

When you receive advice and information from us by telephone, webchat, letter or email our adviser will enter information about your situation and the help you need into our secure case management system. We will keep the information you provide to us and be able to see:

• The history and main details of your case
• The advice that has been given to you.

Doing this helps us to provide accurate information and advice and support to you including if you receive advice from us on a number of occasions.

Some of your information might also be kept within our secure email and IT systems.

With your permission, we may contact you so that you can provide feedback on our service, for example via a survey.

When you call our national telephone advice line, from time to time another member of the advice service team (e.g. a manager) or representative of an external accreditation body may listen in to a call. This is for training or quality assurance purposes.

Very occasionally external representatives from funder or policy organisations are invited to listen in to calls to the advice line. This is to promote the work we do, and influence policy and funding decisions to meet the needs of the families we work with.

You will always be informed if someone wants to listen in to your call. You will be told about this before any personal data collection takes place. Listening in to a call will then only happen if you give your permission.

From time to time, an adviser may ask you if you agree to your call being recorded. This is for the purposes of induction and training of a new adviser. You will always be informed if an adviser wants to record your call. And you will be told about this before any personal data collection takes place. Recording a call will then only happen if you give your permission.

If you agree for your call to be recorded then:

• The recording will be securely and electronically stored
• Only the adviser you have spoken to and the managers involved in their induction and training will have access to the recording, and
• Once the induction and training of the new adviser is concluded, the recording will be permanently deleted by the adviser’s manager.

If something you’ve told us makes us think that either:

• A child is suffering or is likely to suffer significant harm and that the relevant statutory agencies are unaware; or
• You or another adult is at serious risk of harm then we will consider whether there is a need to breach confidentiality and share that information with a statutory agency (e.g. children’s services, adult social services).

You can find full information about this in our Confidentiality and Protection of Children and Vulnerable Adults Policy.

If you make a complaint, we collect personal information from you so we can help deal with your complaint. We collect your information from you via phone, email, online form or letter – depending on how you complain. For further information about making a complaint and how we deal with complaints please see our Complaints, Comments and Compliments Policy.

You have a number of rights in relation to your personal information. You have the right to:

• Be informed – which is what this privacy notice is for
• Request access to the personal information that we hold about you
• Object to processing carried out on the basis of legitimate interests
• Request erasure of your personal information when certain conditions apply
• Data portability in some circumstances
• Request rectification of your personal information – which means you are able to have inaccurate personal information corrected without undue delay
• Restrict processing under certain circumstances
• Object to processing.

If you have any concerns or questions about the way in which we have used your data, please get in touch with us by:

Email: office@frg.org.uk
Telephone: 020 7923 2628
Post: Family Rights Group, 101 Pentonville Road, London N1 9LG.

If you are not happy with the way we have handled your data, and are unable to resolve the issue with us personally, you can complain to the Information Commissioners Office.