1st October 2019

Welcome to Star Fostering Ltd.’s Privacy Notice.

Star Fostering respects your privacy and is committed to protecting your personal data. We will at all times be transparent about how we collect and use your data. We will comply with any such data protection legislation that is currently in force.  Our privacy notice and our terms of use explain in detail how we use any personal information that you provide or which third parties provide to us.

IMPORTANT NOTICE AND WHO WE ARE

This website is owned and managed by Star Fostering Ltd (Company number 12108951)

Our Registered Office is:

Star Fostering Ltd

Gothic House

Barker Gate

Nottingham

NG! 1JU

Star Fostering’s Data protection Officer is Robert North who can be contacted a the above address or by telephone on 0115 9671 1099 or by email dpo@starfostering.co.uk. Robert is responsible for answering any questions or queries you may have about this notice.

Although we would like you to contact us first to deal with any concerns you have, you have the right to complain to the Information Commissioner’s Office (ICO) who are the UK’s supervisory authority for data protection issues.  https://ico.org.uk

This Privacy Notice was last updated on 24th November 2019 and it is important that the information we hold about you is up to date and accurate.

If we update this Privacy Notice and make significant changes we will contact you to inform you that changes have been made.

PERSONAL DATA – HOW WE COLLECT IT FROM YOU AND HOW WE USE IT

The people who use our children and young person’s services and provide family placement.   

This explains what information Star Fostering collects, keeps and stores about you and/or your family if you receive one of our services or provide care, and your rights in relation to that information.

INFORMATION THAT WE COLLECT AND HOW WE USE IT

Star Fostering holds personal information about you, which may include your name, date of birth, address, gender, ethnicity, sexual identity and whether you have a disability, so that we can make sure our services meet your needs. We will also record information about the service provided to you, including case reporting, plans and reviews.

WHY DO WE COLLECT INFORMATION?

When Star Fostering provides you with a service, we will process your data on the basis of legitimate interest or public task. We do this because we cannot provide a service to you without using your personal information.

Under the General Data Protection Regulation (GDPR) we must have a legal reason to keep your data and process it.

Who do we share your information with?

We share your data within Star Fostering with people who need to see it in order to provide you with a service. We may also share it with the organisation that pays for your service or with external agencies (such as Local Authorities), that inspect our work (OFSTED). We may be required to share your data with other agencies for legal reasons, a court order for example, or with other organisations if we believe that you are at risk of harm or may harm someone else.

Occasionally we may ask you for consent to use your data, for example to help us inform the public about our work. If this is the case, we will explain to you exactly what your data will be used for. You can withdraw your consent at any time, and wherever possible, any of your data that has been used for publicity purposes will be deleted.

Who is responsible for your data?

The Data Controller is responsible for your data. This may be Star Fostering or the local authority that funds the service being delivered by Star Fostering. You can get more information about who the Data Controller is for your data from your service provider.

How long do we keep your data?

Star Fostering will keep your data for a specified period of time once we have finished working with you. Depending on the nature of the service and our legal obligations this will be a minimum of 6 years but can extend to 100 years for certain types of work.

On occasions Star Fostering is required to transfer your data to the local authority that has commissioned us to provide your service, or to another organisation providing you with a service.

How can you access your data? (Subject Access Requests)

You may request a copy of the information that Star Fostering holds about you (see The right to access your personal information), but sometimes the local authority that pays for your service might be responsible for providing you with your data. If that’s the case, then the service information leaflet will explain the person/organisation that you should contact.

Job applicants

As part of any recruitment process, Star Fostering collects and processes personal data relating to job applicants. If you apply for a role with Star Fostering, we will only use the information you supply to us to process your application and to monitor recruitment statistics.

What information do we collect?

We will collect a range of information about you, including:

  • Your name, address and contact details, including email address and telephone number
  • Details of your qualifications, skills, experience and employment history
  • Information about your current salary
  • Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process
  • Information about your entitlement to work in the UK
  • Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief – we will only collect this sensitive information with your explicit consent, which can be withdrawn at any time

How do we collect your personal data?

  • We collect it in a variety of ways. For example, you may have filled in an application form, or submitted a CV or resume, you may have provided your passport details or other identification documents, or we may have collected it through interviews or other forms of assessment, like online tests.
  • We may also collect information about you from third parties, such as references supplied by former employers. Star Fostering will only seek information about you from third parties once we’ve made you an offer. In all cases the application process will make clear at what point we will be contacting third parties.

Where will we keep your data?

  • Your personal information will be stored, securely, in several places: on your application record, in our recruitment and selection system, our HR management systems and on other IT systems.

Why do we need your personal data?

  • We need to process your data in order to enter into a working agreement with you. In some cases we need to process your data to ensure we are complying with our legal obligations, e.g. checking an individual’s right to work in the UK.
  • We have a legitimate interest in processing your personal data during the recruitment process and for keeping records of the process. It allows us to manage that process, assess and confirm your suitability for the role and decide who to offer a role to. We may also need to process data from job applicants to respond to, and defend against, legal claims. Where we are relying on legitimate interest as a reason for processing data, we have considered whether or not those interests override the rights and freedoms of the applicant and have concluded that they do not.
  • We process health information if we need to make a reasonable adjustment to the recruitment process for the candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.
  • For some roles Star Fostering is obliged to seek information about criminal convictions and offences. This is necessary to carry out our obligations and exercise specific rights in relation to employment.
  • Star Fostering will not use your personal information for any purpose other than the recruitment exercise for which you have applied.

How long will we keep your data?

  • Personal information about unsuccessful candidates will be held for one year after the recruitment exercise has been completed; it will then be destroyed. Interview notes for all unsuccessful applicants are destroyed after six months..
  • If your application is successful, personal data gathered during the recruitment process will be transferred to your personnel file and will be retained in accordance with our retention policy.

Who has access to your data?

  • Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR (people) and recruitment team.
  • As part of the recruitment process we may need to share your data with third parties in order to conduct any necessary background checks and vetting processes, such as contacting previous employers/referees to obtain a reference; and/or the Disclosure and Barring Service to conduct criminal record checks. As part of the recruitment process, we will make clear to you which checks will be required and at what stage of the process.

What if you don’t provide personal data?

  • You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide Star Fostering with the information, we may not be able to process your application properly, or at all.
  • You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

Our current and former employees.

Star Fostering collects and processes personal data relating to its staff in order to manage the work relationship with you.

What information do we collect?

Star Fostering collects and processes a range of information about you that is appropriate to the role you perform with us. This will vary depending on whether you are an employed member of staff, contractor, agency worker or student, and may include:

  • Your name, address and contact details, including email address and telephone number, date of birth and gender
  • The terms and conditions relating to the work you are doing for Star Fostering
  • Details of your qualifications, skills, experience and employment history, including start and end dates with previous employers and with us.
  • Information about your salary, including entitlement to benefits such as pensions or death in service insurance cover
  • Details of your bank account and national insurance number
  • Information about your marital status, next of kin, dependents and emergency contacts
  • Information about your nationality and entitlement to work in the UK
  • Information about your criminal record
  • Relevant information if you drive a fleet vehicle, your own vehicle for business purposes or if we hire a car for you
  • Details of your schedule (days of work and working hours) and attendance at work
  • Details of periods of leave taken by you, including holiday, sickness absence, family leave and extended leave, and the reasons for the leave
  • Details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence
  • Assessments of your performance, including appraisals, performance reviews and ratings, training you have participated in, performance improvement plans and related correspondence
  • Information about medical or health conditions, including whether or not you have a disability for which the organisation needs to make reasonable adjustments
  • Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

How do we collect your personal data?

  • We collect your information in a variety of ways. For example, you may have filled in an application form, or submitted a CV or resume; you may have provided your passport details or other identity documents; from forms completed by you at the start or during your work with us; from correspondence with you; or through interviews, meetings or other assessments.
  • We may also collect information about you from third parties, such as recruitment agencies, references supplied by former employers, and information from criminal records checks as permitted by law.

Where will we keep your data?

  • Your personal information will be stored, securely, in several places: in your personnel file (hard copy and electronic staff file), in our HR management systems and in other IT systems and email system.

Why do we need your personal data?

  • Star Fostering needs to process your data to enter into a working relationship with you and to meet our contractual obligations under any agreement with you. For example, if you are an employee we need to process your data to provide you with an employment contract, to pay you in accordance with that contract and to administer any benefits.
  • In some cases, Star Fostering needs to process data to ensure that we are complying with our legal obligations. For example, it is required to check a worker’s right to work in the UK, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled. For certain positions, it’s necessary to carry out criminal records checks to ensure that individuals are permitted to carry out the role in question.
  • In other cases, Star Fostering has a legitimate interest in processing personal data before, during and after the end of the working relationship. Processing staff data allows the organisation to:
  • Maintain accurate and up-to-date staff records and contact details (including details of who to contact in the event of an emergency), and records of contractual and statutory rights
  • Operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace
  • Operate and keep a record of employee performance and related processes and workforce management processes
  • Operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay and other benefits to which they are entitled
  • Obtain occupational health advice, to ensure that it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law, and ensure that workers are receiving the sick pay or other benefits to which they are entitled
  • Operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave) to allow effective workforce management, to ensure that Star Fostering complies with duties in relation to leave entitlement, and to ensure that workers are receiving pay or other benefits to which they are entitled
  • Ensure effective general HR and business administration
  • Provide references on request for current or former employees
  • Respond to and defend against legal claims
  • Comply with our statutory and regulatory obligations
  • Maintain and promote equality, diversity and inclusion in the workplace
  • Where Star Fostering is relying on legitimate interest as a reason for processing employee data, we have considered whether, by collecting the data, the company is overriding the rights and freedoms of our employees and workers and has concluded that we are not.
  • Some special categories of personal data, such as information about health or medical conditions, are processed to carry out employment law obligations (such as those in relation to employees with disabilities and for health and safety purposes).
  • Information about trade union membership is processed to allow Star Fostering to operate check-off for union subscriptions (where this is processed through payroll).
  • Where we process other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring.

Who has access to the data?

  • Your information will be shared internally at Star Fostering, including with members of the team (including payroll, pensions), the finance team (including the pensions team), , your line manager, and any other members of staff for whom access to the data is necessary for the performance of their roles.
  • Star Fostering shares your data with third parties in order to obtain pre-employment references from other employers and, if applicable to your role, to obtain necessary criminal records checks from the Disclosure and Barring Service, Disclosure Scotland and AccessNI. Star Fostering may also share your data with third parties in the context of TUPE transfers. In those circumstances the data will be subject to confidentiality arrangements. The services we provide to children and young people are subject to external regulation, so if you work in this service your personal data will be shared with inspectors, and commissioned service data may be shared with the commissioner.
  • Star Fostering also shares your data with third parties that process data on our behalf, in connection with payroll, the provision of benefits, the provision of occupational health services.
  • Star Fostering may transfer your data to countries outside the European Economic Area – see ‘Where we store and process your information’ 

How long will we keep your data?

  • Star Fostering will hold your personal data for the duration of your working relationship with us. After the end of your working relationship with us, due to the nature of the work that Star Fostering carries out, and in order to meet our safeguarding commitments, we may hold some of your data until your 75th birthday depending on your role.

WORKING WITH THIRD PARTIES

STAR FOSTERING will never sell your personal data. However, we may share your information with third parties in order to provide services to you. Your data may be accessible to some of the IT support companies who manage our business critical systems, however, this is only for the purposes of supporting our IT systems and is strictly governed by our contractual arrangements with them. We require all third parties to respect the security of your personal information and to treat it in accordance with the law.

We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Except for these specific cases listed below, we won’t share financial information with third parties without your specific consent unless required to do so by law.

We can share your personal information with:

  • Selected third parties, including:
    • Business partners, suppliers and subcontractors for the performance of any contract we enter into with them, including:
      • Insurers, solicitors, brokers, loss adjusters, managing agents and landlords
      • Benefits providers and criminal records check processors

Analytics and search engine providers that assist us in the improvement and optimisation of our site

Where we are under a duty to disclose or share your personal information in order to comply with any legal obligations, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property of star Fostering. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction

A prospective seller or buyer of our business or assets in the event we sell or buy any such business or assets, including where Star Fostering or substantially all of its assets are acquired by a third party, in which case personal data will be one of the transferred assets

For employees, payroll agencies, HMRC, pension, insurance companies and statutory bodies, where regulated to do so by law

We will keep your personal information confidential, and where we provide it to other third parties we will only do so under contract, on conditions of confidentiality and security, and only for the purposes for which you have provided your information to us.

Third-party websites

Our websites may contain links to third-party websites. This policy only applies to this site, so if you follow a link to a third-party site, please make sure you read the privacy policy on that site. We do not accept any responsibility for third-party sites.

HOW DO WE KEEP YOUR DATA SAFE?

We have out in place appropriate security measures to protect your personal data from accidental loss, used or accessed in an unauthorised way, altered or disclosed. Additionally we limit access to your personal data to those employees, agents, contractors and other third parties who have a business requirement to know. They will only process your information on our instruction and are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected personal data breach and will notify you and any relevant regulatory body where we are legally required to do so.

HOW WE PROCESS AND STORE YOUR PERSONAL INFORMATION

The information that we collect from you may be transferred to, and stored in, a location outside of the United Kingdom, but only where we are satisfied that it has an adequate level of protection. It may also be processed by staff operating in these locations who work for us or for our service providers. This includes staff engaged in, among other things, the hosting of the site and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. Star Fostering will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this privacy notice.

YOUR LEGAL RIGHTS

Under the General Data Protection Regulation (GDPR), you have the following rights:

a. The right to be informed

b. The right to access your personal information

c. The right to edit and update your personal information

d. The right to request to have your personal information deleted

e. The right to restrict processing of your personal information

f. The right to data portability

g. The he right to object – including automated decision making and profiling

h. The right to lodge a complaint with a supervisory authority

If you wish to exercise your rights, please contact us, providing as much information as possible about the nature of your contact with us to help us locate your records. Any changes you have requested may take 30 days before they take effect.

The right to be informed.

You have the right to be informed about the data we hold and share about you. This will be described to you in the service specific information leaflet if you are a service user or through your line manager if you are a member of staff or a volunteer or through our privacy notice above.

The right to access your personal information

You have a right to access your personal data. By making a subject access request to Star Fostering you can find out what personal data we hold about you, why we hold it and whom we disclose it to. You must make a subject access request in writing, and include proof of your identity – you can download a standard form from this website to help make the process quicker and easier.

Emaildpo@starfostering.co.uk

Or write to:

Robert North

Data Protection Officer

Star Fostering

Gothic house

Barker Gate

Nottingham

NG1 1JU

Once we have received your request, and verified your identity, we will respond within 30 days.

The right to edit and update your personal information

The accuracy of your personal information is important to us. You can edit your personal information including your address and contact details at any time.

The right to request to have your personal information deleted

You have the right to request the deletion of your personal information which we will review on a case-by-case basis.

The right to restrict processing of your personal information

You have the right to ‘block’ or suppress processing of your personal data. However, we will continue to store your data but not further process it. We do this by retaining just enough of your personal information so we can ensure that the restriction is respected in the future. Please note, this is not an absolute right and only applies in certain circumstances.

The right to data portability

You have the right to get your personal data from us in a way that is accessible and machine readable,

The right to object – including automated decision making and profiling

You have the right to object to your personal information being processed for marketing (including profiling) and for research purposes.

If we process your personal information for the exercise or defence of legal claims, or we can demonstrate compelling grounds that override your rights and freedoms we may not be able to fulfil your request. However, we will contact you to discuss further.

Your right to lodge a complaint with a supervisory authority

If you wish to lodge a complaint or seek advice from a supervisory authority please contact:

The Office of the Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Tel: +44 (0) 01625 545 745
Website
www.ico.org.uk

R NORTH
Director

(Amended 24th November 2019)