CCIWBS Privacy Notice
Who We Are
Camden City Islington & Westminster Bereavement Services (CCIWBS) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.
CCIWBS’ registered office is at 6-8 York Mews, Kentish Town, London NW5 2UJ and we are a company registered in England and Wales under company number 03533488. We are registered on the Information Commissioner's Office Register; registration number Z3634729, and act as the data controller when processing your data. Our designated Data Protection Officer/Appointed Person is Vybra Morris who can be contacted at the above address.
Information That We Collect
CCIWBS processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we collect from you is: -
Date of Birth
Home Telephone Number
Mobile Telephone Number
National Health Service Number
Special Category Data (i.e., health/medical information, gender, ethnicity etc.)
We collect and store information about you in the below ways: -
Using Online forms, and on our Database.
How We Use Your Personal Data
CCIWBS takes your privacy very seriously and we will never disclose, share or sell your data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and/or marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below: -
We collect your personal data in the performance of a contract and to provide a service to you
We have a legal obligation to share your personal data with NHS England (if you are a client with an Islington or Camden GP) who use the data to monitor recovery outcomes. All data shared with NHS England is anonymized using your NHS no’ and never looked at on an individual basis
We have a legal obligation to share your personal data with your GP, for example, if we have serious concerns that you are at risk
We may occasionally send you marketing information where we have assessed that it is beneficial to you as a client and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests
You have the right to access any personal information that CCIWBS processes about you and to request information about: -
What personal data we hold about you
The purposes of the processing
The categories of personal data concerned
The recipients to whom the personal data has/will be disclosed
How long we intend to store your personal data for
If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable)in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Sharing and Disclosing Your Personal Information
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. CCIWBS uses it to provide the below services and business functions. However, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures. All processors have signed our comprehensive General Data Protection Regulation (“GDPR”) agreement.
CCIWBS takes your privacy seriously and have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, contractors and other third parties who have a legitimate business need to know.
They will only process your personal data on our instructions and they are subject to a strict duty of confidentiality.
We have put in place procedures to deal with any suspected or real personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Transfers Outside the EU (if applicable)
Personal data in the European Union is protected by the UK GDPR but some other countries may not necessarily have the same high standard of protection for your personal data. CCIWBS does not transfer or store any personal data outside the EU.
Consequences of Not Providing Your Data
You are not obligated to provide your personal information to CCWIBS. However, as this information is required for us to provide you with our services and/or pursue our legitimate interests, we will not be able to offer our services without it.
As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
We use the legitimate interests’ legal basis for processing marketing purposes where we believe those services will be of use or benefit to you and have identified that our interests are:
How Long We Keep Your Data
CCIWBS only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
Special Categories Data
Owing to the services or treatments that we offer, CCIWBS sometimes needs to process sensitive personal information (known as special category data) about you, to provide our services and ensure appropriate safeguards are in place for your protection. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.
Where we rely on your consent for processing special category data, we will obtain your explicit consent through an electronic signature on an agreement. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.
Lodging A Complaint
CCIWBS only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority, ICO.
6-8 York Mews
020 7284 0090
Information Commissioner's Office (ICO)
Telephone: 0303 123 1113
If you have a Camden or Islington GP, this is what you need to know about how we store your personal information:
Information about your treatment is kept on a secure computer system www.iaptus.co.uk. The information we keep is used as part of your treatment and also to see how we can improve our services. Any information included in reports about improving the service is anonymised so no details that could identify you are included. If you would like to see the information we have about you, please discuss this with the counsellor you are working with and we will arrange to you to speak with the Director of the service.
CCIWBS have a partnership arrangement with the following organisations: Nafsiyat, Camden and Islington Icope, Women and Health, Age UK Camden and IESO Digital Health. We share information between us to ensure the best treatment and care for you when necessary. If you don’t want your information shared with the above organisations please let us know.
In addition, all services like ours send reports each month to NHS Digital. These reports contain some information about the people we are seeing. This is so we can compare how we are doing to other services and help the NHS in planning services across the country. No information that could reveal your identity is used in these national reports. However, if you do not want your information included, please tell your counsellor. This will not affect your treatment in any way.