Scope of the Statement
www.justbecroydon.org is a site operated in partnership by Social Change UK Ltd and the Active Lifestyles team, District Centres & Regeneration within Croydon Council. Information collected about you by the Just Be Croydon website will be accessible, as necessary, by both the Active Lifestyles team and Social Change UK Ltd.
PharmOutcomes, known also as Outcomes4Health, is an external online database owned and managed by Pinnacle Health Solutions LLP. Upon completion of the Health MOT if you are screened as eligible, and with your consent, your personal information will be securely transferred to PharmOutcomes for registration to the Just Live Well service.
We process your personal information lawfully and do so under the legal basis of consent. Social Change UK ltd and the Active Lifestyles Team within Croydon Council will:
Collect your responses to the Health MOT for the purposes of screening your eligibility to Just Live Well and for statistical analysis and anonymised reporting.
Collect your responses to the MIND MOT for the purpose of statistical analysis and anonymised reporting.
The assessment of standard internet log information and visitor behaviour patterns through Google Analytics for the purpose of assessing visitor numbers to different parts of the website.
1. The Health MOT; This questionnaire is designed to provide you with some advice and guidance on living a healthier lifestyle, to screen your results for eligibility to our one-to-one service "Just Live Well" and to be used to understand the health of Croydon residents. We will use this data for statistical analysis and anonymised reporting and may share anonymised reports within the Council and stakeholders for the purpose of improving service delivery.
2. The MIND MOT; this questionnaire is designed to provide you with some advice and guidance on mental wellbeing. The Council use this data for statistical analysis and anonymised reporting and may share anonymised reports within the Council and stakeholders for the purpose of improving service delivery.
Any data collected by the Just Be Croydon website will be held in the websites password protected admin area for a period of 2 years before it is truncated to the point of anonymization. This enables Croydon Council to make use of the data for reporting purposes for up to 2 years after it is collected.
3. Just Live Well; The Health MOT will actively screen the answers you provide against eligibility criteria to ascertain if you are eligible for our one-to-one service Just Live Well. If eligible you will be offered the option to consent to take part in this service. In order for the Just Live Well service to contact you, you will be asked to supply your name and contact information, postcode along with key information supplied about your health. The Just Live Well service is delivered by a team of Live Well Advisors from Croydon Council and advisors from Primary and Secondary care and the Community and Voluntary sector. All providers of Just Live Well have contracts with the Council to ensure data is handled appropriately. If you are supported by one of these providers they will be given access to the information you supply to support your ongoing involvement with Just Live Well.
The Just Live Well service providers with your consent, will collect additional information from you, this is intended to support your behaviour change to; quit smoking, lose weight, eat more healthily, do more exercise, drink less alcohol or feel happier.
The data collected by the Just Live Well service providers will be anonymised and reported upon to share the impact of the service with our funders. However it will not be possible to identify you directly from this reporting.
You may be asked to complete an anonymous equalities monitoring form. This is requested solely for the purpose of assessing whether the service is equitable for all users. All questions within this survey are anonymous and optional.
Across all services provided we will make sure the information we collect is the minimum necessary to effectively offer you the services you request.
Some options (such as the online screening) may request Special Category personal data. In the event that a service is requested that requires this information, the following defines, under the General Data Protection Regulations 2018, what information is Special Category Personal Data:
- racial or ethnic origin
- political opinions or persuasion
- religious beliefs or other beliefs of a similar nature
- trade union membership or affiliation
- physical or mental health or condition
- sexual life
- commissioned or alleged commission of offences
- Any proceedings for any offence, committed or alleged, including any sentencing decisions made by the Court.
Just Live Well service providers may use your contact information to send you; Appointment reminders, feedback survey requests, weekly motivational support messages as well as messaging you following a missed appointment. These messages will be sent as a text message or an email and will only be sent to you whilst you are participating in the Just Live Well service. These messages from the Just Live Well service provider are intended to support your engagement in the service or are optional for you to choose to engage with at your convenience (feedback survey requests). You are able to opt out of receiving any of the messages we have listed above without impacting your continual involvement in the Just Live Well service.
How we collect your information and how this information is used
Information we collect about you
When someone visits www.justbecroydon.org we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make and do not allow Google to make, any attempt to find out the identities of those visiting our website. Google Analytics data will be reported by Croydon Council for website evaluation and development purposes only. If at any time we do want to collect personally identifiable information through our website, we will be open and honest about this. Clarity regarding the collection of personal information can be found in the "Information you give us" of this Privacy Statement.
Information you give us
Information you provide to us will be processed in compliance with the General Date Protection Regulations 2018 and any other subsequent and relevant legislation.
Where we store your personal data
All information you provide to us is stored on secure servers located in England and/or Europe.
If the results of your Health MOT are deemed eligible to access Just Live Well then (pending your approval) your data will be transferred securely to the PharmOutcomes database (owned and managed by Pinnacle Health Solutions LLP) for processing and a secure process will be used to transfer your data. The Council and PharmOutcomes shall take appropriate technical and organisational measures against unauthorised or unlawful processing of personal data and against any accidental loss or destruction of or damage to personal data. Just Live Well will remain the data controller of all information held on the PharmOutcomes database. Any data held on PharmOutcomes is compliant with "The NHS Records Management Code of Practice for Health and Social Care 2016" which requires information to be retained for a period of 8 years before it is anonymised or destroyed. Therefore as a participant of the Just Live Well service, your participant record will be held on PharmOutcomes for a period of 8 years before it is securely anonymised or destroyed to prevent your identification as a participant of this service.
The law gives you a number of rights to control what personal information we use and how it is used. These are some of your rights:
You can ask for access to the information we hold about you
This applies to your personal information that is in both paper and electronic records. You can ask for your records by contacting the Information Management team at the Council at SAR@croydon.gov.uk.
When we receive a request in writing, we will give you access to everything we have recorded about you. However, we cannot let you see any part of your record which contains:
- Confidential information about other people or
- Data which is likely to cause serious harm or distress to you or likely to affect your physical or mental wellbeing or
- If we think that giving you the information may stop us or any law enforcement agency from preventing or detecting a crime.
If you cannot ask for your records in writing we will make sure there are other ways that you can ask for your information. If you have any concerns regarding making a request in writing please telephone 020 8726 6000 and ask to speak to a member of the Information Management Team.
You can ask to change information you think is inaccurate
You should let us know if you disagree with something written on your file, we may not always be able to change or remove that information but we will correct factual inaccuracies and may include your comments in the record to show that you disagree with it.
You can ask us to delete information (the "right to be forgotten")
You have the right to ask us to delete your personal information for example where your personal information is no longer needed for the reason why it was collected in the first place or where you have withdrawn your consent for us to use your personal information and there is no legal obligation for the Council to use it. Where your personal information has been shared with others legally, we will use reasonable endeavours to make sure the 3rd party also deletes your data where you request this.
You can ask us to limit how we use your personal information
You have the right to ask us to restrict what we use your personal information for where for example you have identified inaccurate information and have told us of it or where you want us to restrict what we use it for rather than erase the information altogether.
You can ask to have your information moved to another provider (data portability)
You have the right to ask for your personal information to be given back to you or another service provider of your choice in a commonly used format; this only applies where we are using your personal information with your consent and not if we are using it under any other legal basis.
You have a right to ask for any computer made decisions to be explained to you and to request details of how we may have "risk profiled" you
You have the right to question decisions made about you by a computer unless it is required for any contract you have entered into, required by law or you have consented to it.
You also have the right to object if you are being "profiled". Profiling is where decisions are made about you based on certain things in your personal information e.g. your health condition.
If and when the council uses your personal information to profile you, in order to deliver the most appropriate service to you, you will be informed.
You can exercise any of these rights by contacting us at firstname.lastname@example.org and providing details of the right you wish to exercise and the service involved.
To request to exercise any or all relevant rights, raise queries or make complaints please in the first instance contact to Live Well Croydon team by email on email@example.com
Live Well Croydon team;
Croydon Council's Data Protection Officer;
To contact the Information Commissioner's Office;
For independent advice about data protection you can contact the Information Commissioner's Office at:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5A or email firstname.lastname@example.org or call 0303 123 1113.