Last Updated on August 20th, 2024 at 4:15 pm

INCLUDEM PRIVACY POLICY

Our privacy policy

Includem (charity number SC030233) prioritise the secure handling and processing of personal data, safeguarding your privacy whether you are a prospective employee, service user or business partner.

When we obtain and use your personal data, this privacy policy explains how we use it and how we keep it safe. Includem will regularly review this privacy policy. If we make any changes, they will be updated on this page which you should check regularly to stay up to date.

Includem take the responsibility for protecting your personal data very seriously and are committed to being transparent about how we handle your personal data, to protecting the privacy and security of your personal data, and to meeting our data protection obligations.

If you have any queries or concerns about how we use your personal data, please contact the Data Protection Officer at:

Data Protection Officer Includem

Unit 6000, Academy Office Park Gower Street

Glasgow G51 1PR

or email us at: enquiries@includem.co.uk

The following sections provide further privacy information – different parts might apply to you depending on your relationship with us.

Why we collect your data

In providing support to young persons and families, we need to process certain data. We only process personal data where we need to do so for the purposes of providing these services. We use this information to:

Get a clear picture of your needs or anything that might be a risk for you or your family, and how this might affect you
Create a suitable support plan for you, focused on your needs
Make sure we are focusing our support in the right areas, and to track progress, whether the service is working for you as well as it can.
Record information about the time you and your family spend with Includem staff, including discussions, activities, reviews and any contact we have with you or discussions about you.

We also process personal data of our employees (and prospective employees) for the purpose of our employment relationship (or prospective employment relationship).

We may also process the personal data of third parties who we interact with in the course of our activities.

How we collect your data

Includem record and hold personal data where:

You tell us information directly – for example when you interact with us on any social media platforms, apply for a vacancy, use our services, or otherwise provide us with your personal data
You use our website – we gather information about how people use our website and which services they may use
You are referred to us from other services, for example by a local

Information we hold

Young people and families who use our services

We collect or use the following personal data in order to provide support to children and families:

Name
Date of birth
Gender
Marital status
Social work information

We may also collect health and wellbeing data, known as special category data, as well as details of any criminal convictions.

Our lawful bases for collecting or using personal data as part of the support offered to children and families are:

Legitimate interest (we have a legitimate interest in processing personal data to assist with counselling and safeguarding children and individuals at risk and safeguarding of economic wellbeing of certain individuals); or
Consent (as relevant)

2. Employees

We collect or use the following personal data as part of staff administration and management, and managing staff health and wellbeing:

Contact details (e.g. name, address, email address and telephone number)
Date of birth
National Insurance number
Gender
Copies of other photo ID
Marital status

Next of kin or emergency contact details
Employment history (e.g. job application, employment references or secondary employment)
Education history (e.g. qualifications)
Job role and employment contract (e.g. start and leave dates, salary, changes to employment contract or working patterns)
Time spent working (e.g. timesheets or clocking in and out)
Expense, overtime or other payments claimed
Leave (e.g. sick leave, holidays or special leave)
Maternity, paternity, shared parental and adoption leave and pay
Pension details
Bank account details
Payroll records
Tax status
Trade Union membership
Right to work information
General health and wellbeing information
Occupational health referrals and reports
Sick leave forms or fit notes (e.g. Statement of Fitness for Work from a GP or hospital)
Accident at work records
Access needs or reasonable adjustments

We may also collect the following data, known as special category data:

Racial or ethnic origin
Political opinions
Religious or philosophical beliefs
Trade union membership
Genetic information
Biometric information
Health information
Sex life information
Sexual orientation information

We may also collect details of any criminal convictions (e.g. Disclosure Scotland or Protecting Vulnerable Groups (PVG) checks).

Our lawful bases for collecting or using personal data for this purpose are:

Contract
Legitimate interest (We have a legitimate interest in protecting and promoting the safety, health and wellbeing of our staff)
Legal obligation
Vital interests

3. Prospective employees

We collect or use the following personal data as part of staff recruitment:

Contact details (e.g. name, address, email address and telephone number)
Date of birth

National Insurance number
Gender
Copies of other photo ID
Marital status
Next of kin or emergency contact details
Employment history (e.g. job application, employment references or secondary employment)
Education history (e.g./ qualifications)
Right to work information
Details of any criminal convictions (e.g. Disclosure Scotland or Protecting Vulnerable Groups (PVG) checks)

We also collect the following data, known as special category data, for staff recruitment:

Racial or ethnic origin
Political opinions
Religious or philosophical beliefs
Trade union membership
Genetic information
Biometric information
Health information
Sex life information
Sexual orientation information

Our lawful bases for collecting or using personal data as part of staff recruitment are:

Contract
Legitimate interest (we have a legitimate interest in processing personal data of prospective employees for the purpose of communicating with those individuals and managing their application)

4. Professional contacts and business partners

We may collect names and professional contact details of various people who we encounter for business purposes, such as:

individuals who work at our suppliers
individuals who work in local council social work department, the Scottish Government, or with other organisations and charities that we work in partnership with
individual MSPs, MEPs and MPs that we work with in connection with lobbying activities
our professional advisors and consultants (such as our lawyers, accountants and auditors)

Our lawful bases for collecting or using personal data of professional contacts and business partners who we encounter for business purposes is:

Legitimate interest (we have a legitimate interest in processing personal data of for the purpose of our daily operations)

How we store your data

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure or destruction. Your information will be processed and stored on our secure IT systems, which are supported by our third-party IT providers.

We will generally only keep your information for as long as necessary for the purpose for which it was collected, or where we have a legal obligation to keep information for a certain period of time. For further information on our retention periods, please refer to our [retention policy] or contact our Data Protection Officer.

How we share your data

We only share your information with others where we have a lawful basis for doing so. We may need to share personal data with third parties, such as:

Local authorities
Police or emergency services
Social worker services
Schools
Health agencies
Courts
Children’s Hearings
Employers, colleges or training centres

Your rights

Under data protection law, you have certain rights including:

Your right of access – You have the right to request a copy of all information we hold about you.

Your right to rectification – You have the right to ask us to rectify personal data which 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 data in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal data in certain circumstances.

Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.

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

Your right to withdraw consent – When we use consent as our lawful basis for processing your personal data, you have the right to withdraw your consent at any time.

You can speak to your Includem worker or the Data Protection Officer if you would like to exercise any of these rights

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the UK Information Commissioner’s Office, using the details below.

Information Commissioner’s Office Wycliffe House

Water Lane Wilmslow Cheshire SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Privacy policy