WHAT IS THIS NOTICE FOR?
CATCH and Bounce are operated by Parents And Children Together (PACT). This privacy notice gives you information about the personal data that we collect and process when you sign up as a user to one of our digital hubs. We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on:
- the personal data we collect about you and why,
- what we do with your information,
- how long we store your information, and
- who your information might be shared with.
WHO ARE WE?
PACT is a registered charity, providing adoption and adoption support services as a Voluntary Adoption Agency registered with Ofsted and community projects supporting and empowering women facing multiple disadvantages and the recovery of children affected by domestic abuse.
Our registered address is PACT Head Office, 7 Southern Court, South Street, Reading RG1 4QS. While providing our services and running the charity, we gather information about individuals which means we need to comply with data protection legislation: the UK GDPR and the Data Protection Act 2018.
Our Role as a DATA Controller
If you are registering as a user with one of our digital hubs we will be acting as the ‘data controller’. This means we decide how your personal data is processed and for what purposes.
Our Role as Data Processor
If your Local Authority, or an organisation you are working for or receiving support from, has provided us with your details to provide you with a login for one of our digital hubs, we will be acting as a data processor. This means we are processing your data to deliver a service on behalf of a data controller (this may include but not be restricted to a Local Authority, Regional Adoption Agency, Voluntary Adoption Agency, virtual school and fostering service) and can only process it in accordance with their instructions. We cannot use your personal data for our own purposes.
WHAT IS PERSONAL DATA?
Personal data is any information that can be used to identify you. It covers obvious information such as your name and contact details, but also less obvious information such as identification numbers, electronic location data, and other online identifiers.
HOW MUCH PERSONAL DATA DOES PACT COLLECT?
PACT only collects personal data relevant to the involvement you have with us. For example, if you request a login, complete a survey, or contact us by telephone, email, social media, post, or text message, we will collect and process the personal information you have provided to ensure we can respond to your request. When collecting your personal data, we will explain to you what data is needed and why we need it. Further details about the information we collect when you sign up to one of our digital hubs, are below.
DOES PACT COLLECT SPECIAL CATEGORIES OF PERSONAL DATA?
Data Protection Law recognises that some categories of personal information are more sensitive. Special categories of personal data include information about ethnic origin, sexual orientation, and religious beliefs. We will only collect these special categories of personal data about you when you give us your explicit consent to do so.
HOW DOES PACT HANDLE YOUR PERSONAL DATA?
The data we gather is held in accordance with Data Protection Law, including the UK General Data Protection Regulation (the ‘UK GDPR’), the Data Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) 2003. PACT complies with its obligations under data protection law by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access, and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
WHAT PERSONAL DATA DOES PACT COLLECT THROUGH THE DIGITAL HUBS?
Registering your account
We need to collect and hold personal data about you to register you as a user on our digital hubs. This may include:
- Your email address
- Local Authority
- Adoption agency
- Fostering agency
- School name
- Family Status
- Username and Password
This information may be provided to us either directly by you, or indirectly by a third-party.
Personal information provided by you
Dependent on which digital hub you are accessing, as you progress through registration process, you will have to provide us with the personal data we need to give you access to the specific platform.
Personal information provided by third parties
If you are not an individual registering directly with one of our digital hubs, our partners (e.g., Local Authorities, Regional Adoption Agencies and Voluntary Adoption Agencies) will share your information with us to set up an account for you.
Personal information about other individuals
You may be providing information on behalf of another person who wishes to or requires access to one of PACT’s digital hubs. If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on their behalf and has agreed that you can give consent on their behalf to the processing of their personal data for the purposes outlined in this privacy notice.
Using PACT’s digital hubs
As you use one of PACT’s digital hubs, we will collect information about how you use and access the system so that we can improve our service, and where necessary or required, provide feedback to the agency/organisation funding your access, if you do not pay us directly. We will also include your usage information in aggregated data for analysis and reporting purposes.
We will also process communication data sent to you and sent by you, for example if you have access to the forum and post messages.
HOW DO WE USE THE INFORMATION ABOUT YOU?
We collect information about you so that we can:
- Set up and manage your digital hub account
- Send you payment instructions for your subscription (if applicable).
- Manage any concerns that arise relating to safeguarding, confidentiality, behaviour, or usage of one of our digital hubs.
- Use aggregated data to produce quarterly reporting on usage, for example, how many users have completed an eLearning course.
- Share usage and access data with an organisation that is funding your access to the digital hub (if applicable).
- Notify you of any changes to our websites or to our services that may affect you.
- Improve our services.
THE LEGAL BASIS FOR PROCESSING YOUR DATA
Data Protection Legislation requires that we process your personal data lawfully, which includes choosing an appropriate legal basis linked to the purposes we have identified. One of the following legal bases typically applies:
- the data subject has given consent to the processing of their personal data for one or more specific purposes.
- processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering a contract.
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, where the data subject is a child.
- processing is required to fulfil a legal obligation.
The table below details the legal basis we rely on for each of the purposes we have identified: