Comely Green Service Privacy Notice

Our Comely Green service provides supported accommodation for people affected by mental and physical health issues.  The majority of the people we support have spent a significant amount of time in long-term hospital care.  Our support enables the people we work with to live as independently as possible in their own home.

Info This notice was reviewed on 1 May 2024

What data we need

To allow us to provide the service you would expect from us, we process the following information about you:

  • name
  • address
  • date of birth
  • telephone numbers
  • swift number
  • next of kin
  • GP’s name, address and telephone number and the contact details of other health professionals involved in your care and support
  • health and disability information which helps us understand your care and support needs
  • Medical Administration Records (MARR)

Why we need it

We need your information and will use your information:

  • to undertake and perform our obligations and duties to you in accordance with the terms of our contract with you
  • to enable us to supply you with the services and information which you have requested or expect from us
  • to enable us to respond to any complaints made
  • so that we can support you according to your needs and provide a responsive service
  • to contact you in order to send you details of any changes to our services which may affect you
  • for all other purposes consistent with the proper performance of our operations and business
  • to contact you for your views on our services.

Where we store your data

We store your information in a computer system called the ‘LinkLiving Information Management System (LLIMS)’. We may also keep some information on paper-based forms and if we do, these are stored in lockfast filing cabinets in our offices.  It’s also possible, if you have contacted us by email, that some information will be held in the email system (Outlook).   

We also have an electronic filing system or document management system (SharePoint), where any forms or correspondence relating to your care and support are scanned and stored. 

How long we will keep your information

We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.

We will generally keep your information for the following minimum periods after which this will be destroyed if it is no longer required for the reasons it was obtained.

 

Document Type

Retention Period

Support plan

Five years from the last day you are supported by our service

Medical Administration Records (MARR)

Six years from the last day you are supported by our service

Letters we receive or send in relation to

your care and support

Five years from the last day you are supported by our service


 Our full retention schedule is available here. 

What's the legal justification?

The personal data that we collect from you is gathered and processed with your signed consent. We will ask for your signed consent during the initial assessment of your support needs. By receiving a copy and signing this Privacy Statement (or by signing a data consent agreement and being provided with a link to this Privacy Statement on our website), you are providing your consent under the Data Protection Act 2018 for your data to be used for the purposes and retained for the period(s) specified in this document. 

 There are certain circumstances when we have a legal requirement to record and retain personal data about you during the period we provide care and support. These circumstances relate to any adult or child protection concerns that come to light during the period we provide you with care and support. 

 Any special categories of personal data we will ask for will be provided with your explicit consent. The details of your next of kin will be processed in your vital interests. 

Sharing your information

The information you provide to us will be treated by us as confidential.

We may disclose your information to third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:

  • Medical Professionals, raising concerns or in a crisis
  • Social Work, raising concerns or in a crisis
  • Statutory Bodies for Adult Protection
  • Regulatory Bodies, Care Inspectorate

Receiving data about you

We may receive the following information from third parties:

  • Medical information, raising concerns or in a crisis situation
  • Social Work, raising concerns or in a crisis situation
  • Information relating to Adult protection
  • Funders, Edinburgh Council concerning contracts

Updating your information

If your details change, please contact Comely Green Office on 0131 652 6258 to inform us to ensure that all of the information we hold about you is up to date.

Data Protection Officer

You can also contact our data protection officer at datamanagement@linkhaltd.co.uk or by post to Link House, 2c New Mart Road, Edinburgh EH14 14L.

Your rights

Your right of access

You have the right to ask us for copies of your personal information. 

Your right to rectification

You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure

You have the right to ask us to erase your personal information in certain circumstances. 

Your right to restriction of processing

You have the right to ask us to restrict the processing of your personal information in certain circumstances. 

Your right to object to processing

You have the right to object to the processing of your personal information in certain circumstances. However, if Link can demonstrate that there is a compelling reason to process such personal data then we may refuse to stop processing your personal data.  

Your right to data portability

You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

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You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.  

Please contact us at datamanagement@linkhaltd.co.uk if you wish to make a request.  

How to complain 

If you have any concerns about our use of your personal information, you can make a complaint to us at Link House, 2c New Mart Road, Edinburgh EH14 1RL or by email at   datamanagement@linkhaltd.co.uk  

You can also complain to the ICO if you are unhappy with how we have used your data.  

The ICO’s address:              

Information Commissioner’s Office 

Wycliffe House 

Water Lane 

WILMSLOW

Cheshire 

SK9 5AF 

Helpline number: 0303 123 1113  

ICO website:  https://www.ico.org.uk