We are committed to protecting and respecting your privacy.
Everyone has rights with regard to the way in which their personal information is handled. During the course of our activities, we will collect, store and process personal information about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.
This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.
For the purpose of UK data protection laws, the data controller is Infinity Foster Care Limited of 61 Cranbrook Road, Ilford, London, IG1 4PG (collectively referred to as “Infinity Foster Care”, “we”, “us” or “our” in this privacy notice).
Our Data Protection Officer can be contacted by writing to the address above or by emailing email@example.com
Data protection principles:
When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal information must be:
· processed lawfully, fairly and in a transparent manner,
· processed for specified, explicit and legitimate purposes,
· adequate, relevant and limited to what is necessary,
· accurate and kept up-to-date, kept for no longer than is necessary, and
· kept for no longer than is necessary, and
· processed in a manner that ensures appropriate security.
· the information you give to us
We may collect, use, store and transfer different kinds of personal information about you, including:
Identity Data: such as your name, title, marital status, date of birth, gender, a copy of your passport and driving licence;
Lifestyle Data: such as your current living arrangements, number of dependents, details of languages spoken, employment details, significant relationships, and details of any previous fostering arrangements;
Contact Data: such as your address, email address and telephone number;
Financial Data: such as bank account and payment card details, national insurance number, confirmation of personal insurance and details of any benefits you may be in receipt of;
Special Category Data: including your race, ethnicity, sexual orientation, religious or philosophical beliefs and details about your health;
Criminal Records Data: including details of any spent convictions, cautions or warnings;
Medical Data: including a medical assessment report and details of any social care support you may be receiving;
Transaction Data: including details about payments to and from you;
Technical Data: including IP addresses, your log-in data, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website;
Usage Data: including information about how you use our website, products and services;
Marketing Data: such as your preferences in receiving marketing from us and our third parties, and your communication preferences;
Referral Data: placement information shared at the matching stage from local authorities relating to children or young persons;
Care Data: covering the key care documents and information relating to children and young persons including care plan, placement plan, risk assessments, personal education plan, pathway plan and other related reports;
Education Data, such as children or young’s school/other educational information and grades relating to their school performance;
‘Special category’ data: during the course of dealing with you, we may collect information about you relating to your racial or ethnic origin, religious or philosophical beliefs, sexual orientation, details of any criminal convictions and details about your health (such information is known as ‘special category’ data).
This is most likely to occur, for example, if you make an application to become a foster carer with us.
How we collect your personal information:
We may obtain personal information by directly interacting with you, such as when you:
· complete an application form to become a foster carer either in paper form or via our website,
· request further information about becoming a foster carer,
· attend one of our fostering information or training events,
· complete one of our feedback forms
· participate in our assessment process to become a foster carer;
· subscribe to our services or publications, or otherwise requesting marketing material to be sent to you, or
· correspond with us by phone, email, letters or otherwise.
We may obtain personal information via automated technology when you interact with our website by using cookies, server logs and other similar technologies.
We may also collect personal information about you from third parties or publicly-available sources, such as:
· local authorities and other foster care agencies,
· Form F assessors and panel members responsible for evaluating your application,
· Your GP or medical practice,
· Disclosure and Barring Service (DBS),
· your employer or other referees,
· analytics providers (such as Google),
· advertising networks,
· search information providers
· providers of technical, payment and delivery services,
· Companies House and the electoral register.
How we use your personal information:
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
· you have given us consent,
· we need to perform a contract we are about to enter into, or have entered into, with you,
· where it is necessary for our or a third party’s legitimate interests and your interests and rights do not override those interests, or
· where we need to comply with a legal or regulatory obligation.
We will only use ‘special category’ information:
· provided we have your explicit consent to use it,
· where we believe that we need to use that data to protect your vital interests where you are not able to provide us with your explicit consent
· where it is necessary for reasons of substantial public interest,
· where you have previously made that data public knowledge, or
· if we need to use that data to establish, exercise or defence legal claims.
Purpose for which we will use the information given to us:
To maintain records of:
· all children placed with foster carers;
· all persons who apply to become foster carers;
· all approved foster carers;
· all employees;
· all accidents and/or allegations occurring to children while placed with foster parents;
To process your application to become a foster carer;
To carry out criminal records and background checks and obtain references from your employer or other personal referees to assess your suitability as a foster carer;
To register you as an approved foster carer and keep an ongoing case record;
To assess your suitability to accept the placement of a child into your care;
To provide details of the placement to the relevant authority;
To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to allow you to participate in interactive features of our service, when you choose to do so, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you and to make suggestions and recommendations to you and other users of our website about services that may interest you or them;
To provide you with information about special offers and other products we sell that are similar to those that you have already received from us;
It will be necessary to take steps at the request of the data subject prior to entering into a contract. Where this involves special category data, it will be necessary for the provision of social care or treatment, or the management of health or social care systems and services.
It will be necessary for us to comply with a legal obligation to which we are subject under Fostering Services (England) Regulations 2011 legislation.
It will be necessary for the performance of the contract between you and us. Where this involves special category data, it will be necessary for the provision of social care or treatment, or the management of health or social care systems and services.
It will be necessary for our legitimate business interests, namely to ensure you are aware of our current terms and conditions.
Where you have previously received marketing communications from us, then it will be necessary for our legitimate business interests, namely to ensure you continue to receive communications that you have previously agreed to receive In all other cases, we will only do this if you give us your consent.
We will only use your personal information for the purpose(s) for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
What if you cannot or will not provide us with your personal information:
It is a contractual requirement for you to provide us with certain information. If you are applying to become a foster carer, this will include your name, address, email address, telephone number, details of any criminal convictions, date of birth, employment details and bank account information. If you do not provide us with that information, we will be unable to accept and process your application. For a placement to made with a Local Authority, we shall require relevant information on the child or young person, if this is not complete, we may not be able to make a relevant match. Further information will be required if a placement proceeds to support the child or young person’s care effectively.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Disclosure of your information:
We may share your personal information with the parties set out below:
· other companies within our group;
· providers of IT and system administration services to our business, including website, and Intranet;
· providers of email marketing platforms and web-based project management applications to our business;
· our professional advisers (including solicitors, bankers, auditors and insurers);
· HM Revenue & Customs, the Information Commissioner’s Office, regulators and other authorities who require reporting of processing activities in certain circumstances;
· The Disclosure and Barring Service (DBS);
· other foster care agencies, social workers, police, Ofsted and local authorities where necessary;
· Form F assessors and panel members;
· training providers or external events organisers;
· social media outlets, including Facebook, Instagram and Twitter;
· our property landlords, or their agents, for our serviced or leased offices;
· analytics and search engine providers that assist us in the improvement and optimisation of our website, and;
· third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
· Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this policy.
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.
Where we store your personal information:
All information you provide to us is stored on our secure servers in the United Kingdom. We will take all steps reasonably necessary to ensure that your data is treated securely, including taking the following safeguards:
Building entry controls. We require staff to use security fobs to access our premises at selected locations.
Secure lockable desks and cupboards. Desks and cupboards are kept locked when not in use if they hold confidential information of any kind.
Methods of disposal. Paper documents are disposed of by shredding in a manner that ensures confidentiality.
Firewalls and encryption. We apply industry-standard firewall protection and encryption technology.
Training. We ensure our employees are trained in the importance of data security.
Cyber Essentials. Maintenance of cyber essentials accreditation.
Overseas transfers. Whenever we transfer your personal information outside the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring that we apply appropriate safeguards (either by transferring data only to recipients in the European Union, to recipients in countries approved by the European Commission, to recipients that are party to the EU-US Privacy Shield, or by using specific contracts approved by the European Commission).
If you are concerned about the levels of data security in any of those countries, please let us know and we will endeavour to advise what steps will be taken to protect your data when stored overseas.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long we will store your personal information:
The length of time that we will store your data will depend on the ‘legal basis’ for why we are using that data, as follows:
|Legal basis||Length of time|
Case files and other records in relation to foster carers
|10 years from the date on which their approval is terminated|
|Records in relation to any child or young person in Infinity Foster Care’s care||15 years from the date of the last entry|
Case records for every fostering applicant who is not approved, or who withdraws their application
|3 years from the date or refusal or withdrawal|
A record of all accidents occurring to children whilst placed with foster carers
|15 years from the date of the last entry|
|Files relating to cases where Infinity Foster Care was a party to legal proceedings or otherwise involved in proceedings brought by the local authority under s.31 of the Children Act 1989||15 years from the date of closure|
Files relating to cases which are of national interest, either because they are subject of a public inquiry or because they give rise to major public concern
|Relevant time to support the relevant inquiry or concern|
|For all other data:|
Where we use/store your data because it is necessary for the performance of the contract between you and us
|We will use/store your data for as long as it is necessary for the performance of the contract between you and us|
Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject
We will use/store your data for as long as it is necessary for us to comply with our legal obligations
Where we use/store your data because it is necessary for our legitimate business interests
We will use/store your data until you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data overrides your interests, rights and freedoms, then we will continue to use and store your data for as long as it is necessary for the performance of the contract between you and us (or, if earlier, we no longer have a legitimate interest in using/storing your data)
Where we use/store your data because you have given us your specific, informed and unambiguous consent
|We will use/store your data until you ask us to stop|
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitive of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
You have various legal rights in relation to the information you give us, or which we collect about you, as follows:
You have a right to access the information we hold about you free-of-charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information;
You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete;
You have the right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not;
You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person;
You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not;
Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms;
Where we use/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time;
You have the right to object to us using/storing your information for direct marketing purposes.
If you wish to exercise any of your legal rights, please contact our Data Protection Officer by writing to the address at the top of this policy, or by emailing us at firstname.lastname@example.org
You also have the right, at any time, to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.
Opting out of receiving marketing communications:
You can ask us to stop sending you marketing communications at any time by writing to the address at the top of this policy, or by emailing us at email@example.com
This also covers how the DBS will process my personal data. Where a person is undertaking Regulated Activity, it is the agency expectation that an Enhanced Check (including a check of the barred list) will be undertaken.
We do not use automated decision-making processes.
Third party links:
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Changes to our policy:
Any changes we make to our policy in the future will be posted on our website and, where appropriate, notified to you by email or via social media. Please check our website frequently to see any updates or changes to our policy.
Questions, comments and requests regarding this policy are welcomed and should be addressed to our Data Protection Officer by writing to the address at the top of this policy, or by emailing us at firstname.lastname@example.org