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Senior Living Privacy Notice

Please read this in conjunction with the general privacy notice which explains how Waverley Borough Council processes data, including how you can access your information, your data rights, how to raise your concerns, or contact our Data Protection Officer.

Why do we need to process your personal data?

When you become a Senior Living tenant, it is necessary to provide some personal data so that we know how to provide you with an accessible and appropriate service. The information you provide helps us make sure that we meet our legal duties and responsibilities and our contractual obligations.

What information do we collect?

The categories of personal data we are processing are:

  • Name
  • Date of birth
  • Address, telephone number, email
  • Marital status
  • Nationality
  • Gender and sexual orientation
  • Some financial information (such as bank account details)
  • National Insurance number
  • The names, addresses, and telephone numbers of any person, next of kin, or other care provider nominated by you
  • The name, address, and telephone number(s) of anyone who is registered as someone who has Power of Attorney (PoA) and can act on your behalf
  • Some physical and mental health information about you, necessary and relevant to the provision of the service. You can choose what medical information you would like to share.

How do we collect your personal data?

We collect your information in several ways including:

  • When you move into your flat, you are required to provide us with certain information such as contact details
  • You or your nominated representative may contact us to advise us of changes in your circumstances
  • Any other third party organisation (such as Social Services, NHS, wellbeing teams etc.) may refer you to us where you have agreed to that referral.

How do we use your personal data?

We use your personal data to maintain your tenancy and inform the provision of our service, including signposting you to further support when necessary and supporting you in an emergency.

For the purposes of our public duty or to meet our contractual obligations we may also share information with others, in particular: nominated family members and neighbours. This third party sharing will typically be with your consent, though in an emergency your information may be shared to protect your vital interests.

Who do we share data with?

To carry out our role we may share information with:

  • Careline Resolution Centre (PPP Taking Care)
  • Other departments within Waverley Borough Council
  • Contractors and subcontractors so that they can carry out necessary work within the Senior Living Scheme
  • Other contacts indicated by you including contacts nominated by persons who we believe you have authorised to make those decisions
  • Your care agency/agencies
  • Adult Social Care
  • Emergency services, including the police
  • NHS and GPs/Clinical Commissioning Groups (CCGs).

This list is not exhaustive and we may share with other third parties where there is a lawful basis to do so.

All information held in respect of clients may be provided to the police, social services, and healthcare professionals either to comply with the local authority public duties or as reasonably required for the protection of the vital interests of clients and other persons.
Where police request information under their criminal investigative role, that request will be processed in accordance with the relevant information exchange protocols.

We will not share your data with third parties for marketing purposes.

How do we store your personal data?

Senior Living tenants’ personal data is stored on our secure database contained within a secure environment. The personal data provided by organisations other than Waverley Borough Council is stored on our secure database. Some data is stored on paper files, and these are kept securely within a locked office or a locked safe box at the Senior Living Schemes.

How long will we keep your personal data?

Personal data will not be retained for longer than six years after your tenancy ends, in line with the Waverley Borough Council Data Retention Policy. Senior Living Officers follow a process to ensure that all data is deleted at the appropriate time.

Lawful basis and withdrawal of consent

The lawful basis upon which we process personal data is:

  • Part of the performance of a contract
  • Consent - Where we process sensitive information such as medical data (referred to by GDPR as special category data). Where this is the basis, you have the right to withdraw that consent. Withdrawal of consent may affect the ability of Waverley Borough Council to provide this service.
  • Vital interests - Where, in the event of an emergency, personal data is processed to protect your vital interests, for example.

Your rights and how to find out more

You have a number of rights under data protection law. For information about these, how the council uses personal information and how to get in touch if you have a query or complaint, please see our main privacy notice.