Author: Emma Simpson
Reviewer: Steve Williamson
The Clifton Children’s Society is committed to protecting your personal information. We want to be completely transparent about why we need the personal details we hold about you and how we use them. The aim of this policy is to help you understand how we collect and use your information, and how you can get in touch with us about your preferences.
If you have any questions about this policy or your personal information please contact our Data Protection Officer, Facilities & Administration on 0117 935 0005 or by emailing firstname.lastname@example.org.
You can also write to us at our registered address: CCS Adoption, 162 Pennywell Road, Easton, Bristol, BS5 0TX.
What this policy covers
- Data acquired through recruitment activity for prospective adopters.
- Data acquired once families are between the assessment and Adoption Order stage of the adoption journey (i.e. From when the Registration of Interest is submitted to when the Adoption Order is granted).
- Data acquired from families who are accessing Post Adoption Support i.e. those that provide data to CCS Adoption after the Adoption Order has been granted.
- Any data collected about adoptive families through their engagement with any activities at The Centre For Adoption Support and Education ( groups, workshops and courses)
- Any data collected through the adoptive family’s engagement with The Therapeutic Service.
Who are we?
The Clifton Children’s Society is a registered adoption charity with 117 years of experience finding and preparing families who are able to offer permanent, loving homes for children in care.
Our aim is to find homes for children who are waiting to be adopted and our Voluntary Adoption Agency, CCS Adoption is renowned for its success in finding families for the most vulnerable and hardest to place children, including older children, groups of brothers and/or sisters who need to stay together, children from minority ethnic groups, children with disabilities and/or medical conditions, and children suffering the emotional effect of early childhood adversity and trauma.
As well as finding permanent loving homes for vulnerable children, we also work hard to provide the specialist services and support that adoptive families need after they adopt. This is provided through our Social Work team, who provide advice and support to CCS Adoption families throughout their lives, as well as through our Adoption Support Service, The Centre for Adoption Support and Education (‘The Centre’).
Until April 2018 The Centre was a separate charity, and our close working partner, established in 1998 to provide services and support to adoptive families. It is now part of the Clifton Children’s Society and exists to improve the long-term outcomes for adopted children and their families by providing them with the support they need after they are adopted/adopt. Its activities include facilitating regular groups, activities and events for adopted children and their families; running specialist workshops and training for adoptive parents and professionals; and providing highly specialist therapeutic services for adopted children with additional and more complex support needs. These services are a unique offering in the region and are freely accessed by families from across our catchment area.
How do we collect information?
We obtain personal information from you when you enquire about our activities and services, ask a question, register to attend an activity or event, send or receive an email, make a donation or payment, or otherwise provide us with your personal information.
This data may be collected from you in numerous ways – via online forms that you have completed, via the telephone, face to face meetings/conversations, receiving communications in writing from you via email or post, and from other individuals and agencies where you have given specific consent for this (i.e. when you are within the assessment process, accessing the Sharing Stories Service, Post Adoption Support or accessing the Therapeutic service).
What information do we collect?
The type of information we collect and how we use it varies depending on why you are providing it. It may include:
- Your title, name, gender and date of birth
- Your address, telephone number, mobile number, email address, and your preferences as to how we should contact you in the future
- The information you give us when filling out one of our online forms
- Records of your correspondence with us
- Details about your relationships, i.e. your family, partner/spouse, relationships with other donors/adopters or organisations
- Non-identifying information about your visit to our website, including technical information such as your IP address
- Any other information provided by yourself that is relevant to your relationship with us, for instance, your motivations for supporting our work.
- Information that you may provide to us as part of your enquiry about becoming an adoptive parent, assessment or accessing Post Adoption Support may include a large amount of personal and sensitive data.
- Information that you may provide to us as part of your engagement with The Centre (including the Therapeutic service) may also include large amounts of personal and sensitive data.
Sensitive Personal Data
Data Protection Law recognises that certain categories of data are more sensitive than others. These are known as special categories of personal data and include information about a person’s health, racial or ethnic origin, political opinions, religious beliefs, and from 25 May 2018 genetic and biometric data.
The Clifton Children’s Society does ask you for some of this information that is classified as special categories of data, as this is needed as part of an assessment of prospective adopters. The legislation and guidance around adoption assessments guide our data collection on these matters. The purpose of this data collection is to enable robust assessments to be completed and are in line with adoption legislation and requirements.
When accessing services at The Centre, for example, a group, we will ask for some of this data such as ethnic origin or questions regarding your or your children’s health, this is to make sure we provide appropriate support and facilities, and to help us in an ongoing evaluation of our services, and to provide evidence for funding applications.
Why do we collect your information?
We collect personal information from you in order to:
- Respond to your enquiry, question or complaint
- Register your attendance at an ‘information evening’ or one of our events
- Update you on our work and the services, activities and events we offer
- Communicate with you about aspects of our work that are relevant to you or that you have expressed an interest in
- Process payments for goods and services
- Keep a record of your relationship with us
- Manage your communication preferences
- Comply with our legal obligations, policies and procedures
- Meet financial auditing requirements
- Understand how we can improve our services, products or information
- Gain anonymised evaluation data to support funding applications and for reporting purposes (Including ASGLB data being shared with Ofsted- Please speak to the CCS Data Protection Officer for more information about this)
We use the data you provide to build a positive and personal relationship with you, providing you with the information you want when you want it, and involving you in our work and the future development of our services in a way that is relevant to you.
Legal basis and Legitimate Interests
When we collect and use your personal information, we make sure we adhere to at least one of the legal grounds available to us under Data Protection Law.
We obtain your consent to collect and use your personal information for a previously notified purpose, such as to send you email or text marketing or provide you with the information or services you have requested. We rely on consent as the legal basis to communicate with our supporters and clients by email and/or text.
2. Legal obligation
In certain circumstances, we may process or disclose your information because we are legally obliged to do so – for instance where we are legally required to hold your transaction details for Gift Aid or tax purposes.
3. Legitimate interest
We believe that the people who support our work have an interest in receiving occasional updates from us, which is why we rely on the legitimate interest legal basis to send them direct marketing communications by post and to contact them by telephone (subject to checking against the Telephone Preference Service or any existing marketing preferences). We also rely on the legitimate interest legal basis to conduct research to better understand and target our supporters and those interested in our services, to monitor who we deal with and conduct due to diligence checks to mitigate against potential risks to our agency and service users, as well as to maintain and administer our fundraising database and systems.
We have a legitimate organisational interest in doing this which we balance against your rights, making sure we only use your personal information in a way and for a purpose that you would reasonably expect and that does not intrude on your privacy or previously expressed marketing preferences.
How we protect your information
- We aim to ensure that there are appropriate controls in place to protect your personal information. As part of our commitment to this, we continue to invest in appropriate technologies to secure and appropriately manage your personal information. We also work hard to ensure our network, on which we carry out all of our IT functions across the charity, and websites are protected and regularly monitored.
- Prospective adopters’ information is securely stored, this is done by saving your information on the “CHARMS” database which is fully GDPR compliant. socialcarenetwork.com
- As part of the Therapeutic service videos are made of assessment and therapeutic sessions (specific consent forms are signed by adoptive parents prior to this starting). Therapists are required to share these videos with their external specialist supervisors as part of their professional supervisory requirements. These videos are safely shared onto Microsoft OneDrive’s secure site, having been uploaded from our server. These external supervisors can view (they cannot download or transfer this data anywhere) for a limited period, as required, in order to fulfil their professional supervisory requirements.
- Your information at all other points of your adopter journey with CCS will be saved on our secure IT systems and our secure web-based database (CHARMS). This includes data received in the following ways: A) Between submitting an REI (Registration Of Interest form), throughout your assessment and up to the point of the Adoption Order being granted. B) If you access Post-adoption support. C) If you access any activities at The Centre D) or access The Therapeutic service.
- If you are accessing groups or activities at The Centre, your information will be securely stored, this is done through saving your information on the ‘CHARMS’ database which is fully GDPR compliant
Who we share your information with
We do not sell or share your personal details with third parties for either fundraising or marketing purposes. We take care to ensure that our third-party suppliers have appropriate policies and procedures in place to safely manage your data whilst working on our behalf.
- Inspection of Adoption Records
Adoption case records and indexes must be made available to:-
- the Secretary of State or Local Commissioner;
- the Reporting Officer and/or Children’s Guardian;
- the Court dealing with the adoption proceedings concerning the child;
- the persons and authorities referred to Adoption Agencies Regulations
- those holding an inquiry under a relevant Section of the Children Act 1989.
The Agency has the discretion to make case records available to such persons as it thinks fit and these are:-
- members of staff or advisers who need information for the purposes of CCS is carrying out its function as an Adoption Agency;
- persons authorised by the Secretary of State to carry out adoption research;
- representatives of the state engaged in the Inspection of Voluntary Adoption Agencies.
A written record must be kept of any access provided or disclosure made of the information from these records.
- Transfer of Case Records to another adoption agency
An Adoption Agency may transfer a copy of a case record to another Adoption Agency if this is considered to be in the interests of a child or prospective adopter to whom the record relates. Written records must be kept of any such transfer.
Transmitting information over the internet
Despite all of our precautions to protect our website and network, no data transmission over the internet can be guaranteed to be 100% secure. So, whilst we strive to protect your personal information, we cannot guarantee the security of any of the information you disclose to us online and wish to draw your attention that you do so at your own risk.
How long do we keep your information?
We store your information for only as long as is necessary and/or legally required for the relevant activity. If you decide to progress your enquiry to become an adopter, then the length of time your information is held changes and is determined by law. Detailed below:
1. Adoption Records
Indexes to all case records and the case records in respect of those cases in which an Adoption Order is made must be preserved in a place of special security for at least 100 years (from the child’s date of birth or 15 years after the child’s death whichever is the shorter period). The place of special security must, so far as is possible, preserve the files – and, in particular, minimise the risk of damage from fire or water.
Case records on prospective adopters whose file is closed during the adoption process (Pre Adoption Order), will be kept for 10 years. Information of those who are in contact with the Society Pre Stage 1 but don’t begin the adoption process, will be kept for 1 year after the last contact. Every manager, staff member, Panel Member, volunteer and student on placement having access to records of adoption cases must agree in writing to maintain confidentiality.
2) If you access any activities at The Centre:
If you register for groups or activities at The Centre, your information will be stored securely on the ‘Charms’ database for 6 years, and paper copies of registration forms will be destroyed once entered into the database.
All feedback forms or written write up of events/groups/workshops/training courses that take place at the Centre should be destroyed after 6 years.
3) If you access The Therapeutic service:
- A) Information gained from referrals/enquiries that do not proceed to assessment or therapy package are kept for one year only.
- b) Information gathered at an initial consultation, where the family does not then proceed to assessment or therapy package are kept for 6 years only.
- c) Information gathered at an assessment, where the family does not proceed to receive a therapy package, 6 years only.
- d) Information gathered through the provision of therapy, data will be kept for 6 years after the children’s 18th
Families accessing the Therapeutic Service can request for their data to be deleted prior to the above dates, requests must be put in writing.
4) If you access the STEP group:
If the EP Carer/adopters are not a CCS approved family or not registered with CCS/The Centre for other post-adoption support services then names and contact details will not be kept on the CCS Charms database. The contact details such as email addresses, telephone numbers and names will be kept separately on a password protected spreadsheet by the STEP group facilitator. Personal and private information may also be noted if it is relevant to be able to offer appropriate and good quality support.
These contact details will only be used for the purposes of the STEP meetings (i.e. to enable attendees to give and receive support from peers – other EP carers/adopters) and to inform them of future STEP meetings or to send them links or information to enable them to attend such meetings.
When participants at the STEP meetings are contacted by the group facilitator to inform them of a future meeting they will always be asked in the email if they wish for no further contact about the STEP groups then they should email the groups facilitator and they will be removed from the STEP spreadsheet.
The STEP group facilitator in conjunction with the CCS EP lead will conduct an annual review of the list in January each year, which will entail emailing everyone on the list to ask them to confirm that they still wish to be contacted about STEP meetings. The email will make it clear that if the CCS EP lead or the STEP groups facilitator does not receive this confirmation then their contact details will be removed from the list. However, it will also make it clear that should they wish to re-engage at a later date they can do this by emailing the CCS EP Lead and/or the STEP group facilitator directly.
How to change the way we contact you
You can change how we use the information you have provided to us at any time by letting us know, or amending, your communication preferences. If you do not want to hear from us that is also fine.
If you have any questions about this policy or your personal information please contact our Head of HR, Facilities & Administration on 0117 935 0005 or by emailing email@example.com.
You can also write to us at our registered address: CCS Adoption, 162 Pennywell Road, Easton, Bristol, BS5 0TX.
Your rights to your personal information
Under the Data Protection Act 2018, you have a right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. You also have a right to request us to erase your personal information, ask us to restrict our processing of your information or object to the processing of your information.
Should you wish to exercise these rights we ask you to prove your identity with two pieces of approved identification. Please address requests to the Data Protection Officer, CCS Adoption, 162 Pennywell Road, Easton, Bristol, BS5 0TX and we will respond within 40 days of receipt of your written request and confirmed ID. Please provide as much information as possible about the nature of your contact with us to help us locate your records.
Changes to this policy
This policy was last updated in May 2021. We may update the terms of this policy at any time, so please do check it from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address you have provided to us or by placing a prominent notice on our website(s)
Updated February 2022