Privacy notice

1. About this Privacy Notice

Davigdor House Supported Living (DHSL) respects your privacy and is committed to protecting your personal information.

This Privacy Notice explains what information we collect about you, why we need it, how we use it, where it may come from, who we may share it with, how we keep it secure, how long we keep it, and your rights in relation to your personal information.

We handle personal information in accordance with UK data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This notice applies to people who:

are referred to DHSL by a Local
Authority, NHS organisation or other professional;
make a private or self-funded
referral;
are considering moving to DHSL;
live at DHSL;
receive support from DHSL while
living in a private or self-contained flat; or
are a family member,
representative, advocate, appointee or other person whose information is
recorded as part of providing someone's support.

2. Who is Responsible for Your Information?

Davigdor House Supported Living is responsible for deciding how and why personal information relating to people using our service is collected, used, stored and shared.

If you have any questions about this Privacy Notice or how we use your information, please contact DHSL using the details shown at the beginning of this notice.

3. What Information Do We Collect?

The information we collect depends upon your circumstances and the support you require.

Personal and Contact Information

name and preferred name
date of birth
address, telephone number and
email address
NHS number and Local Authority
reference number
emergency contact and next of
kin details
family and representative
details
information about advocates,
deputies, attorneys or appointees

Referral and Assessment Information

referral forms
Care Act assessments
needs assessments
care and support plans
risk assessments
hospital discharge information
previous placement information
professional reports
reasons for referral
accommodation needs
support requirements
information about whether DHSL
or a private one-bedroom flat is being considered

Health and Social Care Information

physical and mental health
diagnoses and medication
allergies and medical history
GP, psychiatrist and other
professionals
hospital admissions and
treatment
appointments
disabilities and mobility
personal care needs
diet and nutrition
communication needs and other
health or social care requirements
Health information is particularly sensitive information and
receives additional protection under data protection law.

Mental Health Information

mental health diagnoses
current presentation and
relapse indicators
previous hospital admissions
Mental Health Act status
Community Treatment Orders
Section 117 aftercare
arrangements
crisis and safety plans
information supplied by mental
health professionals

Risk and Safeguarding Information

self-harm and suicide risk
vulnerability and self-neglect
exploitation and safeguarding
concerns
substance or alcohol use
aggression or violence
missing-person incidents
fire and environmental risks
hoarding
accidents and incidents
emergency intervention

Criminal Offence and Forensic Information

previous convictions or
offences
probation involvement
licence conditions
MAPPA arrangements
court orders
restrictions or exclusion areas
information provided by police,
probation or forensic mental health services
We will only process this information where there is a lawful reason
for doing so.

Financial and Funding Information

care funding
Local Authority, NHS or ICB
funding
Section 117 funding
Universal Credit and Housing
Benefit
Personal Independence Payment
and Employment and Support Allowance
rent and service charges
arrears and payment
arrangements
private or self-funded care
financial representatives and
DWP appointees
invoices and payments
We will only collect financial information that is reasonably
required to arrange or administer your accommodation, care and support.

4. Where Do We Get Your Information From?

Where possible, we collect information directly from you. We may also receive information from other people or organisations involved in your care, support, accommodation or funding.

Brighton & Hove City
Council and other Local Authorities
NHS organisations and
Integrated Care Boards
hospitals and mental health
services
social workers and care
managers
psychiatrists, GPs and
community mental health teams
crisis teams, occupational therapists
and psychologists
pharmacies and previous care or
supported-living providers
probation services, police and
safeguarding teams
the Department for Work and
Pensions and benefits services
family members, advocates,
attorneys, deputies and appointees
other professionals involved in
your care or support
For private referrals, information may initially be provided by you,
a family member, representative, advocate or another person assisting you to
find suitable accommodation and support.
We will take reasonable steps to ensure you understand what
information we hold about you and why.

5. Why Do We Use Your Information?

We use personal information so that we can provide safe, effective and person-centred support. This may include using information to:

consider referrals and carry
out assessments
determine whether DHSL can
safely meet your needs
plan your care and support
prepare risk assessments and
support plans
support medication, healthcare
and appointments
support independence and
community access
respond appropriately during a
crisis or emergency
protect you and other people
from harm
manage safeguarding concerns
communicate with professionals
involved in your care
arrange and review funding
administer rent and service
charges
manage private funding
arrangements
maintain accurate care records
investigate incidents, concerns
or complaints
manage the safety and security
of the service
meet contractual obligations
and legal or regulatory requirements
monitor and improve the quality
of the service we provide

6. Our Legal Reasons for Using Your Information

We do not rely upon consent for every use of your personal information. Depending upon why we are using your information, our lawful basis may include:

Contract: We may need to use information in order to enter into or carry out an agreement with you, including arrangements relating to accommodation or care and support.

Legal Obligation: We may need to use or share information because the law requires us to do so.

Vital Interests: In an emergency, we may use or share information where this is necessary to protect your life or the life of another person.

Legitimate Interests: We may use information where this is reasonably necessary for the legitimate operation of our service, provided that your rights and interests do not override those interests.

Public Task / Legal Functions: In some circumstances, particularly where we are working with Local Authorities, NHS bodies or statutory services, information may be processed as part of functions carried out in the public interest or under statutory authority.

7. Health and Other Sensitive Information

Information concerning your physical or mental health is known as special category personal data and receives additional protection.

We may process this information where it is necessary for providing health or social care, managing health or social care services, protecting vital interests, safeguarding individuals, complying with social protection obligations, establishing or defending legal claims, or other substantial public interest purposes permitted by law.

Where required, appropriate safeguards are put in place. We will only collect and use sensitive information that is relevant and necessary for the care and support we provide.

8. Consent

There may be some circumstances where we specifically ask for your consent, for example before sharing information with a family member where there is no other lawful reason to do so, taking or using photographs for unrelated purposes, publishing testimonials, or using information for another optional purpose.

Where we rely upon consent, you can withdraw your consent at any time. Withdrawing consent will not affect information that was lawfully used before consent was withdrawn.

There are also circumstances where we may lawfully use or share information without consent, particularly where this is necessary to provide care, meet a legal obligation, respond to an emergency or safeguard somebody from harm.

9. Who May We Share Information With?

We will not routinely share your personal information with people who do not have a legitimate reason to receive it. Where necessary and lawful, information may be shared with:

Local Authorities and NHS
organisations
Integrated Care Boards,
hospitals, GPs and psychiatrists
community mental health teams,
social workers and care managers
pharmacies and emergency
services
safeguarding authorities,
police and probation services
courts or other legal
authorities
the Department for Work and
Pensions
housing or benefit authorities
funding and commissioning
bodies
advocates, deputies, attorneys
and appointees
family members or
representatives where appropriate
professional advisers,
insurers, auditors and regulators
companies providing secure IT,
care-record, payroll, accounting or other services to DHSL
We only share information that is necessary and appropriate for the
purpose concerned. Where another organisation processes information on our
behalf, we expect appropriate confidentiality and data-protection safeguards to
be in place.

10. Safeguarding and Emergencies

Your privacy is important to us, but confidentiality is not absolute. We may share relevant information without your consent if we reasonably believe this is necessary to protect you or another person from serious harm, investigate or report abuse or neglect, comply with safeguarding responsibilities, prevent or detect serious crime, comply with a court order or other legal requirement, or respond to a medical or other emergency.

Where appropriate, we will tell you when information has been shared and explain why.

11. CCTV

CCTV may be used at DHSL for safety, security and the prevention or investigation of incidents and crime.

appropriate signs will be
displayed
access to recordings will be
restricted
footage will only be used for
legitimate purposes
footage will only be retained
for as long as necessary, unless required in connection with an incident or
investigation
footage may be provided to the
police or another authorised organisation where there is a lawful reason to do
so
CCTV is not used to routinely monitor residents in private areas
such as bedrooms or bathrooms.

12. How We Keep Your Information Safe

We take reasonable organisational and technical measures to protect personal information against unauthorised access, accidental loss, inappropriate disclosure, alteration, destruction and misuse.

password-protected systems
access controls
secure storage
staff confidentiality
requirements
staff training
secure email and
information-sharing arrangements
controlled access to records
appropriate disposal of
confidential information
Staff should only access information when they have a legitimate
reason to do so as part of their role.

13. How Long Do We Keep Your Information?

We do not keep personal information indefinitely simply because we have collected it. Information is retained for as long as it is reasonably required for the purpose for which it was collected and to meet applicable legal, regulatory, contractual, safeguarding, insurance and record-keeping requirements.

Different types of information may therefore be retained for different periods. When information is no longer required, it will be securely deleted, destroyed or anonymised in accordance with DHSL's records-retention arrangements.

14. If Your Referral Does Not Proceed

If you are referred to DHSL but do not subsequently move into the service, we may retain appropriate referral and assessment information for a limited period.

This allows us to maintain an appropriate record of the referral, respond to queries or complaints, demonstrate why a placement was or was not offered, and meet legal, safeguarding and contractual requirements.

Information that is no longer required will be securely disposed of in accordance with our retention arrangements.

15. Your Rights

Data protection law gives you a number of rights in relation to your personal information. Depending upon the circumstances and the legal basis on which information is being processed, these may include:

Right to be Informed: You have the right to understand how your personal information is being used.

Right of Access: You can ask us whether we hold personal information about you and request a copy of that information. This is commonly known as a Subject Access Request.

Right to Rectification: You can ask us to correct personal information that is inaccurate or incomplete.

Right to Erasure: In some circumstances, you may ask us to delete personal information. This right does not apply in every situation.

Right to Restrict Processing: In certain circumstances, you may ask us to temporarily restrict the way in which your information is used.

Right to Data Portability: In certain circumstances, you may be able to request that information you have provided to us is supplied in a structured electronic format or transferred to another organisation.

Right to Object: You have the right to object to certain uses of your personal information. If you object to the way in which we are using your information, please contact us and explain your concerns.

Rights Concerning Automated Decisions: DHSL does not normally make decisions about an individual's care, support or accommodation solely by automated means. Important decisions should involve appropriate human assessment and professional judgement.

16. Asking to See Your Records

If you would like to see the personal information DHSL holds about you, please contact us. You do not have to use any particular wording.

We may need to confirm your identity before providing information. There may be limited circumstances where information cannot be disclosed in full, for example where disclosure would adversely affect another person's rights or where a legal exemption applies.

17. Family Members and Representatives

Living at DHSL does not automatically mean that we can disclose all information about you to your family. Where you have capacity to make the relevant decision, we will take your wishes into account when deciding what information may be discussed with family members or representatives.

Different rules may apply where you have given permission, someone holds an appropriate Lasting Power of Attorney, a Court-appointed Deputy has relevant authority, an appointee is dealing with appropriate financial matters, information needs to be shared to protect somebody from harm, or another lawful basis permits or requires disclosure.

18. Mental Capacity

Where a person may lack capacity to make a particular decision about the use or sharing of their information, DHSL will consider the Mental Capacity Act 2005 and other relevant legal requirements.

Capacity is decision-specific and should not be assumed simply because somebody has a mental health condition, disability or receives supported living services. Where appropriate, decisions will be made in accordance with the person's best interests and with appropriate involvement of representatives and professionals.

19. Information About Other People

Sometimes information in your care or support records may also relate to another person, such as a family member, another resident or a member of staff. We have responsibilities to protect their privacy as well as yours.

This may mean that some third-party information needs to be withheld or redacted if you request a copy of your records.

20. Information Transferred Outside the UK

Where possible, DHSL seeks to use systems and service providers that process information within the UK or other territories offering appropriate data protection. If personal information needs to be transferred internationally, we will ensure that an appropriate legal mechanism and safeguards are in place where required by data protection law.

21. Complaints About the Use of Your Information

If you are concerned about how DHSL has collected, used, stored or shared your personal information, please contact us in the first instance using the details at the beginning of this notice.

We will ensure that your complaint is considered appropriately and that you receive a response. You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent regulator for data protection.

Making a complaint will not affect the care or support you receive from DHSL.

22. Changes to this Privacy Notice

We may update this Privacy Notice from time to time, for example because the law changes, regulatory guidance changes, our services change, we introduce new systems, or the way we use information changes.

The latest version will be made available to residents and can be requested from DHSL.

Our Commitment

At Davigdor House Supported Living, we recognise that the information people share with us is often personal and sensitive. We will aim to:

treat your information
respectfully and confidentially
only collect information that
we genuinely need
explain why we need it
keep it as accurate as
reasonably possible
share it only where appropriate
and lawful
keep it secure
respect your information rights
use your information in a way
that supports your dignity, safety, independence and wellbeing