Close
Recovery Steps Cumbria Menu

Privacy Notice

Who we are

Recovery Steps Cumbria is a service Waythrough provide in Cumbria. We are funded by Cumberland Council and Westmorland and Furness Council to provide this service.

Our website address is: https://recoverystepscumbria.org.uk

What personal data we collect when you use this website and why we collect it

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Analytics

We use a company called Google to collect and analyse information about the use of our website. This information helps us to measure understand how visitors use our website. If you have an account with Google, manage your advertising settings, otherwise you can manage these settings through your web browser.

Full Privacy Notice

This privacy notice is for Recovery Steps Cumbria service users. Recovery Steps Cumbria is a service Waythrough provide in Cumbria. We are funded by Cumbria County Council to provide this service.  

Waythrough adheres to the Data Protection Act 2018 in relation to how we collect and process information that identifies you as an individual. This type of information is called personal data.   

Managing Your Information  

Waythrough is the Data Controller for the Recovery Steps Cumbria service which means that we decide how data is processed and the purpose for the processing. We are accountable for ensuring that your rights are respected and that the data is processed lawfully. Should a breach occur, it is our responsibility to report it to the Information Commissioner’s Office (ICO) if there is a high risk to your rights or freedoms as per the UK General Data Protection Regulation (UK GDPR).  

What We Use and Why  

We use personal data like your name, address and contact details so that we can provide you with a service.  

We also use more sensitive data about your health; and demographic data such as your gender, sex life (specifically relationships), sexual orientation, race and ethnicity and religious beliefs. This is called Special Category Data which requires extra protection.  

If you are an offender or ex-offender, we may process some criminal offence data about you so that we can provide you with our service and so that we can manage risks to you, to our team and to the public.  

How We Collect Your Data  

We receive your data from you and sometimes from other people like your GP, Cumbria County Council, Primary Care Services and housing services. Anyone can refer you into our service.  

If we are not sure that you want our service, we will check with you. If you do not want our service then we will erase this information at the point of referral.  

Lawful Reasons for Processing  

The lawful reasons (known as lawful bases) for processing are set out in the UK General Data Protection Regulation (UK GDPR). At least one of these must apply whenever we process personal data.   

We use the lawful basis of Legitimate Interests to process your data, to provide you with the Recovery Steps Cumbria service..  

We process your health data under the Health or Social care condition of the UK GDPR. We only process what is necessary for the purpose; and processing is overseen by a health professional bound by the common law duty of confidentiality.  

In addition to health data, we process a minimal amount of other special category data such as; data about your racial or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation/relationships and we use this data for demographic purposes and statistical analysis and to meet individual health and social care needs.  

Where we are processing criminal offence data, we rely on special conditions under the Data Protection Act 2018 relating to health and social care, preventing or detecting unlawful acts and safeguarding.  

Sharing Your Information with Others (also known as ‘Third Parties’)  

There are times when it is our Legal Obligation to share your information with third parties and we do not require your consent to be allowed to do this. Sometimes we do not need to make you aware that we are sharing. We will only share the information that is needed; and we only share the minimum information for the purpose.  

Examples of this are:  

  • to report a crime to the police (this includes driving under the influence)  
  • to report to the police if you have gone missing  
  • to report abuse or neglect to social services  
  • to let mental health crisis services know if you are at serious risk  
  • any other request where we are obliged to share data as per a legal obligation which is laid down in UK law.  

Where we deliver community orders (such as ATR, DRR, CBO or civil injunctions) we may also process your data upon a Public Task and Legitimate Interests when we share with the authorities. In all cases there is a legal requirement for us to use and share your data.  

We rely on the lawful basis Legitimate Interests to share your personal data with:  

  • The Individual Placement and Support (IPS) service. Please see the IPS privacy notice for more details on how your information is shared by the IPS service.  
  • Cumbria County Council social care team to provide you with support through partnership working, where risks and vulnerabilities require us to do so in your best interests or in the best interests of others (particularly children, families and adults at risk).   
  • The Well, an organisation that give support to people recovering from drug and alcohol addiction, including counselling, peer mentoring, employment training and social activities. We contract the Well to act as a Data Processor for us.  
  • your GP, in order to prescribe you medication.  
  • pharmacies, in order to prescribe you medication.  
  • we may share information to your GP where we make the decision that your life or someone else’s is at risk and we believe strongly that the GP is in a key position to help you/others. If we make this decision we will make all reasonable attempts to inform you.   
  • the prison, probation services, courts and police to share prescribing information and/or arrange ongoing support, if you have recently been released or are going into custody.  
  • research organisations and funders who carry out evaluation and statistical work. Your data is only shared for research and planning purposes with Caldicott Guardian Approval following our National Data Opt Out Policy. Please see the section below ‘You Can Opt Out of Your Personal Data Being Used For Research and Planning’ which explains this in more detail.  
  • we must share data with the Care Quality Commission (CQC) who are a regulatory body. Wherever possible we anonymise data, but sometimes we are required to share personal data when a serious incident has occurred.  

We share some data with our funder who is Cumbria County Council. When we share for statistical/research purposes, the data we share will not identify you.  

All other third-party personal data sharing is decided by you with your explicit consent. You provide us with this information on the Sharing Consent Form. You should update us at any point if you wish us to change these consents.  

You Can Opt Out of Your Personal Data Being Used For Research and Planning  

National Data Opt Out is a government policy overseen by the NHS. Waythrough Charity is one of many organisations working in the health and care system to improve care for patients and the public. Whenever you use a health or care service, such as a Waythrough health or social care service, attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment.  

The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, You can find out more about these purposes and opting out here  

Most of the time, anonymised data is used for research and planning so that you cannot be identified, in which case your confidential patient information isn’t needed. Where your data cannot be anonymised and Waythrough is not confident that you are aware that your personal data may be used for research or planning, Waythrough will generally seek to obtain your explicit consent.  

Where Waythrough has your NHS number, we can check to see if you have applied an NHS Opt  

Out to your data being used for this purpose. Patients apply their Opt Out via the NHS National Data Opt Out process. If you have Opted Out, Waythrough will not use or share your data for purposes other than your treatment and care (i.e. Waythrough will not use or share your data for research or planning).  

You have a choice about whether you want your confidential patient information to be used for research and planning. If you are happy with this use of information you do not need to do anything. If you do choose to Opt Out of your data being used for research or planning, your confidential patient information will still be used to support your individual care.  

To find out more or to register your choice to Opt Out, please visit the NHS website www.nhs.uk/your–nhs–data–matters.   

You can also find out more about how patient information is used at:  

https://www.hra.nhs.uk/information–about–patients/ (which covers health and care research); and https://understandingpatientdata.org.uk/what–you–need–know  

Confidentiality  

Information about you may be shared between team members; and recorded on your file and in other records to enable us to give you the best service that we can and get the best possible support for you.   

Only what is necessary and proportionate is shared and we are bound by the common law duty of confidentiality. In some circumstances we may share your data in order to keep you or other people safe which is a legal obligation this is explained in the section above titled Sharing Your Information with Third Parties .  

Transferring Your Data Outside of the UK  

We do not transfer your data outside of the UK unless with your explicit consent to do so (right to portability).  

Keeping Your Information Safe  

Your data is held securely on a third-party management system and only those who need access, have access to it. This includes staff that support you and staff who maintain the system. We have policies in place which our staff follow to ensure your data is only accessed appropriately and when necessary.   

We store some of your personal data on our secure network drives which is restricted to our service team and may be accessed under policy by our IT Team should there be a technical issue. All Waythrough’s workforce abide by data management policies, processes and training.  

We cannot offer you a service without storing your details on these systems. 

We have a number of people who oversee that data is used safely (see ‘Relevant Contacts’).  

Should an incident occur where we breach your data, causing a high risk to your rights or freedoms, we will inform you of this without delay and using the primary contact details you have provided. We will also report this to the Information Commissioner’s Office (ICO), who supervise organisations that handle data.   

Retaining Your Information  

We keep your personal data for the period stated in our records retention policy. The policy currently states that we will keep your information for 10 years from the date that you stop using our service; and for no longer than this.  

In the event that we change the retention period in our policy, we will update our privacy notice and notify you of this change.  

Your data will be securely destroyed at the end of our retention period. 

Keeping in Touch With You  

As part of your treatment we will contact you at various stages to discuss your progress, deliver interventions and provide reminders around upcoming appointments.   

This is usually via the following methods; however this is not an exhaustive list:  

  • letters   
  • online platforms such as Zoom or WhatsApp  
  • phones calls   
  • home visits (when applicable)  
  • e-mails*   
  • text messages*  

If you do not wish to be contacted via one or all of these methods or have specific communication needs then please tell us using the Sharing Consent form. You can request this from your Recovery Steps Cumbria worker.  

*e-mail & text Messages should be used for non-urgent contact only. Recovery Coordinators have e-mail accounts and mobile phones but will not routinely access them throughout the day. We always recommend phoning the service if you require assistance urgently (for example cancelling / rearranging upcoming appointments).  

Your Data Rights   

Under the Data Protection Act 2018 and UK GDPR, you have the following rights:     

  • to be informed about the collection and use of your personal data.     
  • to access your personal data (known as Subject Access Request).     
  • to have inaccurate personal data rectified; or completed if it is incomplete.     
  • to have personal data erased (known as the right to be forgotten).     
  • to request the restriction or suppression of your personal data.      
  • to data portability, which allows individuals to obtain and reuse their personal data for their own purposes across different services.     
  • to object to the processing of your personal data in certain circumstances.     

We do not use any automated decision making (decisions made by a computer) or profiling (when an automated system is used to assess certain things about you) when we use your data.  

Please note that some of these rights only apply in certain situations and we may not be able to fulfil every request. Where we say no to a request, we will always explain our decision in full, within the timeframe that the law says. Should you request that your data is erased please be aware that we will be unable to continue offering you a service as we require your personal data to do this effectively and safely.  

To request access to your data or to contact us about any of the rights we have listed, you can request this through the service or contact our Caldicott Guardian (see below; Relevant Contacts).  

How To Complain   

If you are unhappy about an issue relating to your data you can complain to us through the service you attend; or if you would feel more comfortable, you can contact the Waythrough Caldicott Guardian (see below; Relevant Contacts).   

To make a formal complaint to the independent regulator for personal data in the UK about the way we have used your data, contact the Information Commissioner’s Office (ICO):     

https://ico.org.uk/make–a–complaint/ or call ICO on  0303 123 1113     

Relevant Contacts  

You can write to us at Waythrough, Inspiration House, Unit 22 Bowburn North Industrial Estate DH6 5PF.  

Our Data Protection Officer (DPO) is Mark Burnett. You can contact our DPO by email dpo@Waythrough.org.uk or by phone 01325 731 160.  

Our Caldicott Guardian is Leesa Howes. You can contact our Caldicott Guardian by email caldicott.guardian@Waythrough.org.uk or by phone 01325 731 160.