Privacy

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Privacy Statement for Parents/Carers of Children with Day Placements (Education)

At East Park we are committed to protecting your child’s privacy and to complying with our responsibilities under data protection legislation.  We will always keep your child’s data safe and secure.

This privacy statement will explain the following:

1. Who we are
2. How we collect information
3. Why we collect this information
4. What we use this information for
5. When and why we share your child’s information
6. How to complain if you are unhappy about how we use your child’s information
   1. Who we are:

• East Park is a registered charity which provides a range of services for children and young people with additional support needs.
• We provide education, residential care for school age children and day opportunities for young people up to age 25.
• Our residential school receives a grant from the Scottish Government.

1 How we collect information

• When your child starts to receive a service from East Park we collect information from you about your child.
• We will also receive information from the local authority Social Work or Education Department about your child.
• If your child has used a similar service previously e.g. another school; a respite service, we may also ask them for information about your child.

2. Why we collect this information

• We are legally required to hold this information about your child when they come to live at East Park.
• We need this information to ensure we can provide the best possible service for your child.
• We want to know all the things you as a parent /carer know about your child for example:
  • What makes them happy or sad?
  • What are their habits or routines?
  • Who are the important people in their life?
  • Do they need to take regular medicine?
  • The information we get from other professionals about your child e.g. Social Worker, previous teacher, also helps us to get to know your child and ensure he/she is safe, healthy and happy while at East Park.

3. What we use this information for

• We use this information to create a Personal Support Plan for your child. We sometimes call this a PSP.
• In the PSP we write everything we need to know about your child.
• When we write the PSP we will need your help to ensure that we have all the information we need and that it is all correct and accurate.
• We will also keep a daily record of your child’s activities and routines. This is called the daily notes.
• We will keep other records for your child e.g. medication records; behaviour support forms.

4. When and why we share your child’s information

• Certain professionals involved with you and your child may also visit your child while they are staying at East Park e.g. Social Worker; Educational Psychologist; health professionals. We will only share information with them about your child which is directly appropriate to their role.
• We will not give out any information about you or your child to any other person unless we are legally required to do so.
• We will keep all this personal information safe and secure and will ensure it is not accessible to anyone who should not see it.

5. How to complain if you are unhappy about how we use your child’s information

• If you are unhappy about how we use your child’s information please contact:

Catriona Campbell
Head of Education
East Park
Tel. 0141 946 2050

Email: Catriona.Campbell@eastpark.org.uk or dataprotection@eastpark.org.uk

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Privacy Statement for Parents/Carers of Young People in Workmates (Education)

At East Park we are committed to protecting your young person’s privacy and to complying with our responsibilities under data protection legislation.

We will always keep your young person’s data safe and secure.

This privacy statement will explain the following:

1. Who we are
2. How we collect information
3. Why we collect this information
4. What we use this information for
5. When and why we share the young person’s information
6. How to complain if you are unhappy about how we use the young person’s information
   1. Who we are:

• East Park is a registered charity which provides a range of services for children and young people with additional support needs.
• We provide education, residential care for school age children and day opportunities for young people up to age 25.
• Our residential school receives a grant from the Scottish Government.

1. How we collect information

• When the young person starts to receive a service from East Park we collect information from you about the young person.
• We will also receive information from the local authority Social Work or Education Department about the young person.
• If the young person has used a similar service previously e.g. another school; a respite service, we may also ask them for information about the young person.

2. Why we collect this information

• We are legally required to hold this information about young people when they come to East Park.
• We need this information to ensure we can provide the best possible service for young people.
• We want to know all the things you as a parent /carer know about the young person for example:
  • What makes them happy or sad?
  • What are their habits or routines?
  • Who are the important people in their life?
  • Do they need to take regular medicine?
  • The information we get from other professionals about the young person e.g. Social Worker, previous teacher, also helps us to get to know the young person and ensure he/she is safe, healthy and happy while at East Park.

3. What we use this information for

• We use this information to create a Personal Support Plan for each young person. .
• In the Plan we write everything we need to know about a young person.
• When we write the Plan we will need your help to ensure that we have all the information we need and that it is all correct and accurate.
• We will also keep a daily record of activities and routines. This is called the daily notes.
• We will keep other records for young people e.g. medication records; behaviour support forms.

4. When and why we share young people’s information

• Certain professionals involved with you and the young person may also visit the young person while they are at East Park e.g. Social Worker; health professionals. We will only share information with them about the young person which is directly appropriate to their role.
• We will not give out any information about the young person to any other person unless we are legally required to do so.
• We will keep all this personal information safe and secure and will ensure it is not accessible to anyone who should not see it.

5. How to complain if you are unhappy about how we use your young person’s information

• If you are unhappy about how we use your young person’s information please contact:

Catriona Campbell
Head of Education
East Park
Tel. 0141 946 2050

Email: Catriona.Campbell@eastpark.org.uk or dataprotection@eastpark.org.uk

Privacy Statement for Colleagues/Staff

1. Collection and use of personal data

East Park is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

East Park collects and processes personal data relating to its staff (which would include employees, workers, temps and those who are self-employed contractors) and also relating to candidates or applicants for work opportunities in order to enter into and perform their contractual relationship with East Park.

2. What information does East Park collect?

East Park collects and processes a range of information about you. This includes:

• your name, address and contact details, including email address and telephone number, date of birth and gender;
• the terms and conditions of your contract;
• details of your qualifications, skills, experience and work history, including start and end dates with previous employers and with East Park, and references;
• information about your remuneration, including tax status information, entitlement to benefits such as pensions or insurance cover, and payroll records;
• details of your bank account and national insurance number;
• information about your marital status, next of kin, dependants and emergency contacts;
• information about your nationality and entitlement to work in the UK;
• details of your schedule (days of work and working hours) and attendance at work;
• details of periods of leave taken by you, including holiday, sickness absence, family leave and sabbaticals, and the reasons for the leave;
• details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence;
• assessments of your performance, including performance reviews, training you have participated in, performance improvement plans and related correspondence;
• photographs;
• CCTV footage
• information obtained through electronic means, such as swipe card records;
• information about your use of our information and communication systems

We may also collect and use the following more sensitive types of personal information:

• information about medical or health conditions, including whether or not you have a disability for which East Park needs to make reasonable adjustments;
• details of trade union membership; and
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.
• In some situations, information about your criminal record (criminal offence data)

East Park collects this personal information in a variety of ways. For example, data is collected through application forms; obtained from your passport or other identity documents such as your driving licence; from forms completed by you at the start of or during employment or work contract (such as personal details form); from correspondence with you; or through interviews, meetings or other assessments. Also we collect personal information directly from you in the course of your work related activities throughout the time you are working with us.

East Park collects personal data about you from third parties, such as references supplied by former employers, information from employment background checks, such as PVG checks done via Disclosure Scotland.

Data is stored in a range of different places, including in your personnel file, in East Park’s HR management systems and in other IT systems (including East Park’s email system).

3. Why does East Park process personal data?

East Park needs to process personal data to enter into a work contract with you and to meet its obligations under your contract. For example, it needs to process your data to pay you in accordance with your contract and may need to administer pension and insurance entitlements.

Also, East Park needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an individual’s entitlement to work in the UK, to deduct tax, to carry out PVG checks to ensure individuals are entitled to work with East Park, to comply with health and safety laws and to enable staff to take periods of leave to which they are entitled.

In some situations, East Park has a legitimate interest in processing personal data before, during and after the end of the contractual relationship. Where East Park relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.

We may also use your personal information in situations, which are likely to be rare, where we need to protect your interests (or someone else’s interests).

Processing your personal data allows East Park to:

• run recruitment and promotion processes;
• maintain accurate and up-to-date work records and contact details (including details of who to contact in the event of an emergency), and records of your contractual and statutory rights;
• operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace;
• operate and keep a record of individual performance and related processes, to plan for career development, and for succession planning and workforce management purposes;
• operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that staff are receiving the pay or other benefits to which they are entitled;
• obtain occupational health advice, to ensure that it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law, and ensure that staff are receiving the pay or other benefits to which they are entitled;
• operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that East Park complies with duties in relation to leave entitlement, and to ensure that staff are receiving the pay or other benefits to which they are entitled;
• ensure effective general HR and business administration;
• provide references on request for current or former staff;
• respond to and defend against legal claims; and
• maintain and promote equality in the workplace.

Some special categories of personal data, such as information about health or medical conditions, are processed to carry out employment law obligations (such as those in relation to staff with disabilities and for health and safety purposes) and where it is needed in the public interest, such as in relation to our occupational pension scheme. Information about trade union membership is processed to allow East Park to operate check-off for union subscriptions.  We may also process special categories of personal information where it is necessary to protect you or another person from harm.

In limited circumstances, we use ‘special category’ personal information with your explicit written consent (for example in situations where you agree to provide access to medical records for an occupational health report).  Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Where East Park processes other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring. Data that East Park uses for these purposes is anonymised or is collected with the express consent of staff, which can be withdrawn at any time. Staff are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.

We will only collect information about criminal convictions (‘criminal offence data’) if it is appropriate given the nature of the role and where we are legally able to do so. Where applicable, we collect it as part of the recruitment process, and on occasion we may be notified of such information directly by you while working for us. We will use information about criminal convictions and offences to carry out our obligations in accordance with appropriate internal safeguards which we are required by law to maintain when processing such data.

4. Who has access to data?

Your information will be shared internally, including with members of the HR & Administration team and Finance team (including payroll), your line manager, managers in the business area in which you work if access to the data is necessary for performance of their roles.

We will share your personal information with external third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.  For example, East Park shares your data with third parties to obtain pre-contract references from other employers or organisations that you have worked for, obtain background checks from third-party providers and where necessary obtain criminal records checks from Disclosure Scotland. East Park also shares your data with third parties that process data on its behalf the provision of benefits and occupational health services.

East Park may also share your data with third parties in the context of a sale of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.

In any situation where East Park may transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring it is only transferred to countries deemed by the UK government to provide an adequate equivalent level of protection for personal data (such as other EEA countries).

5. How does East Park protect data?

East Park takes the security of your data seriously. East Park has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its staff in the performance of their duties.

Where East Park engages third parties to process personal data on its behalf they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

6. For how long does East Park keep data?

East Park will hold your personal data for the duration of your contract. The periods for which your data is held after the end of your work contract are set out in the GDPR Data Protection and Privacy Policy.

7. Your rights

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;
• require East Park to change incorrect or incomplete data;
• require East Park to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where East Park is relying on its legitimate interests as the legal ground for processing; and
• ask East Park to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override East Park’s legitimate grounds for processing data.

You can make a subject access request by completing East Park’s form for making a subject access request. Otherwise, send a request by post or email using the below details.

Maxine Glen
HR Manager
East Park

Tel. 0141 946 2050

Email: Maxine.glen@eastpark.org.uk or dataprotection@eastpark.org.uk

If you believe that East Park has not complied with your data protection rights, you can complaint to the Information Commissioner: https://ico.org.uk

8. What if you do not provide personal data?

You have some obligations under your contract to provide East Park with data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide East Park with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights.

Certain information, such as contact details, your right to work in the UK and payment details, have to be provided to enable East Park to enter a contract with you. If you do not provide other information, this will hinder East Park’s ability to administer the rights and obligations arising as a result of the relationship efficiently.

9. Automated decision-making

No decisions about your work at East Park are based solely on automated decision-making.

Privacy Statement for Supporters

At East Park, we are committed to protecting your privacy and to complying with our responsibilities under data protection legislation.  We will always keep your data safe and secure.

This privacy statement includes information on:

• Who we are;
• What personal data we collect and how we use it;
• Where we collect information about you from;
• How we keep your data safe and who has access;
• Keeping your information up to date;
• Right of access and correction of your information;
• Changes to this Policy.

Who we are:

• East Park is a registered charity, which provides a range of services for children and young people with additional support needs.
• We provide education, residential care for school age children and day opportunities for young people up to age 25.
• Our school receives a grant from the Scottish Government.

What personal data we collect and how we use it

The type and quantity of information we collect and how we use it depends on why you are providing it.

Supporters

If you support us, for example, make a donation, volunteer or sign up for an event or our newsletter, we will usually collect:

• Your name.
• Your contact details.
• Your bank or credit card details.

Where it is appropriate we may ask for your motivation for giving, including whether this relates to any personal experience of East Park. We will never make this question mandatory, and only want to know the answer if you are comfortable telling us.

We will mainly use your data to:

• Administer your donation or support your fundraising, including processing gift aid.
• Keep a record of your relationship with us;
• Manage your marketing preferences;

Replying to your comments on social media sites or contacting you regarding inappropriate or unwanted posts. Whatever it is about East Park you are interested in, we really want to be as tailored as we can in our communications to you. We also want to speak to you in the way you’d prefer – be it by email, on the phone or in writing. To help us do this, we will sometimes analyse things like what you are interested in and where you live to help us engage with you in a meaningful way. This is important because it cuts down on broad-ranging communications and helps us ask for donations or give information based on what we know you would like to hear about.

Direct marketing

With your consent, we will contact you to let you know about the progress we are making and to ask for financial and non-financial support. We make it easy for you to tell us how you want us to communicate, in a way that suits you. Our forms have clear marketing preference options and we include information on how to request no contact (Opt-Out) from us. If you do not want to hear from us, just get in touch to let us know and we will make sure your wishes are followed. You can contact us in the following ways:

Email us – fundraising@eastpark.org.uk

Call us –           0141 946 2050

Write to us – Fundraising, East Park, 1092 Maryhill Road, G20 9TD.

We do not sell or share personal details with third parties for the purposes of marketing. But, if you attend an event run in partnership with another named organisation your details may need to be shared. We will be very clear what will happen to your data when you register.

Where we collect information about you from

We collect information in the following ways:

When you give it to us DIRECTLY.

You may give us your information in order to make a donation, sign up to the East Park Patter, volunteer or communicate with us.

When you give it to us INDIRECTLY.

Your information may be shared with us by independent fundraising agencies, for example Virgin Money Giving. These independent third parties will only do so when you have indicated that you wish to support East Park and with your consent. You should check their Privacy Policy when you provide your information to understand fully how they will process your data.

WHEN YOU GIVE PERMISSION TO OTHER ORGANISATIONS TO SHARE IT.

Depending on your settings or the privacy policies for social media and messaging services like Facebook or Twitter, you might give us permission to access information from those accounts or services.

When we collect it as you use our WEBSITE.

Like most websites, we use ‘cookies’ to help us make our site – and the way you use it – better. For further information on cookies and how East Park uses them, please see our Cookies Policy.

How we keep your data safe and who has access

We ensure that there are appropriate technical controls in place to protect your personal details; for example, our online forms are always encrypted and our network is protected and routinely monitored.

We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff and contractors.

We may need to disclose your details if required to the police, regulatory bodies or legal advisors.

We will only ever share your data in other circumstances if we have your explicit and informed consent.

Keeping your information up to date

Where possible we use publicly available sources to keep your records up to date. We really appreciate it if you let us know if your contact details change.

Your right to know what we know about you, make changes or ask us to stop using your data.

You have a right to ask us to stop processing your personal data. If it’s not necessary for the purpose you provided it to us for (e.g. processing your donation) we will do so.

You have a right to ask for a copy of the information we hold about you. If you spot any mistakes, please let us know and we will correct them.

If you want to access your information, send a description of the information you want to see, and proof of your identity by post to:

Maxine Glen
Head of Resources
East Park
Tel. 0141 946 2050

Email: maxine.glen@eastpark.org.uk or dataprotection@eastpark.org.uk

Changes to this policy

We may change this Privacy Policy from time to time. If we make any significant changes in the way we treat your personal information, we will make this clear on the East Park website or by contacting you directly.