Policies and Procedures

Safeguarding

trust⁠wellbeing, as part of Northorpe Hall Child & Family Trust, is fully committed to safeguarding the welfare of everyone we support and our people. We recognise our responsibility to take all reasonable steps to promote safe practice and to protect children and adults from harm, abuse and exploitation. We also acknowledge our duty to act appropriately in response to any allegations, reports or suspicions of abuse.

your privacy

trust⁠wellbeing is committed to protecting your personal information and we are required by the General Data Protection Regulation (GDPR) to make you aware of how we will use the information you give us. We are also required to give you information about your rights.

How and when we collect information about you:

When you make an appointment with trust⁠wellbeing, we will save this on our secure client database. Your information is only available to people at trust⁠wellbeing who will use it to help you get the support you need.

The different ways we may contact you or others about your care:

Telephone Calls
Letters
Emails
Text Messages

The different types of information we might collect:

your personal details (e.g., full name, date of birth, ethnicity, gender
your contact details (e.g., phone number, address, email address)
contact details of people around you such as parents/ carers and any relevant professionals who might be involved in your care as well as
notes of what takes place in therapy session/s
relevant medical information (e.g., neurodevelopmental diagnoses or anything we need to know to keep you safe)

How we use your information:

At trust⁠wellbeing, we will use your personal information to:

help make decisions about the most appropriate support to offer.
keep a record of what we have done in response to your request for support.
keep accurate records so that staff members and counsellors are kept informed about any changes in your circumstances

Although trust⁠wellbeing is part of the Northorpe Hall Child and Family Trust the fee-based services operate differently to our funded support. Under trust⁠wellbeing, we will only share your information with your consent and permission with other organisations where appropriate to do so. If we believe you would benefit from a service from another provider, and this would be more appropriate for you (e.g., Specialist CAMHS) we will discuss this with you and only share information upon your consent to do so.

Lawful basis of us processing your data:

The GDPR sets out six reasons why we may lawfully process your personal information. When we process your personal information, we will ensure that we comply with one or more of these.

We will only share your data for the following purposes:

Third party suppliers. We share information with third parties to enable us to function efficiently as an organisation. Third parties include, for example, our IT contractor. They back our data up so that your data is not lost if we have a system failure.
If you are under the age of 18 and an adult is paying for your support, they will be kept informed about the support you are receiving unless an agreement has been reached between you and the paying adult about not sharing information.
Contracted Counsellors and employed workers/managers have access to your records when you are allocated for support.
You may request that we share information appropriately to support your care or there may be others we may share information with (e.g., school, GP, social workers, family support workers) - but we will always ask you about this first and seek your permission to share.
The Police, Solicitors: Sometimes we get request from the police or legal professionals for information to support criminal investigations or other legal matters. We will only release this information if they provide signed consent from you (or your parent/carer if you are under 13 or do not have the capacity to consent).
Safeguarding - We are committed to keeping your information confidential - however if you tell us something that makes us believe you are going to harm yourself or someone else, we have a legal duty to break confidentiality. We will try to talk to you about this first whenever possible.

Data retention

When determining the storage period for your personal information, we will consider:

any statutory or legal obligations.
the reason for which we originally collected your personal information.
the lawful grounds on which we base our processing.
the types of personal information we have collected.
the amount and categories of your personal information.
whether the purpose of the processing could reasonably be fulfilled by other means.

Your rights

Everybody has rights relating to their own personal information. These are explained below.

right to be informed:
we will always be transparent in the way we use your data. You will be fully informed about the processing through relevant privacy notices.
right to access:
you have a right to request access to the personal data that we hold about you and this should be provided to you.
right to rectification:
we want to make sure that the personal data we hold about you is accurate and up to date.
right to erasure:
you have the right to have your data "erased" in the following situations:
- where the data is no longer necessary in relation to the purpose for which it was originally collected or processed.
- when you withdraw consent (when consent is used to process your data)
- when you object to the processing and there is no overriding legitimate interest for continuing the processing.
- when the personal data was unlawfully processed.
- when the personal data must be erased to comply with a legal obligation.
right to restrict processing:
you have the right to restrict processing in certain situations
right to data portability:
in certain situations, you have the right to obtain and refuse your personal data for your own purposes via a machine-readable format, such as a .CSV file.
right to object:
you have the right to object to the processing of your personal data where processing is based on our legitimate interests

If you would like to enforce any of your rights, please contact us. Please note that each request will be reviewed on a case-by-case basis and, where we have a lawful reason to retain the data, we will advise you accordingly.

For more information, please visit the Information Commissioner's Website.

How to make a complaint or raise a concern

if you would like more information, have any questions about this policy or you wish to make a formal complaint about our approach to data protection please contact us.

If you are not happy with our response to your complaint, you can raise your concern with the relevant statutory body.

Information Commissioner's Office:
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF

Alternatively, you can visit their website.

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Complaints Policy Statement

Complaints are an opportunity for the Trust to learn and improve. They also provide an opportunity to put things right and, offer an explanation for the person who is complaining. Anyone can complain about any aspect of the organisation's work.

To make a formal complaint you must ensure:

It is in writing, being clear that it is a complaint
It provides the contact details of the complainant
It is dated

Complaints Procedure

Northorpe Hall Child and Family Trust has a three stage complaints procedure

Stage 1: Resolution

Wherever possible, complaints will be resolved swiftly and informally by the relevant staff member/manager. If the staff member/manager is involved in the complaint, we will ask another independent manager.
It is our aim that all Stage 1 "resolution" complaints will be resolved in 10 working days after we receive the complaint. If we are unable to resolve the complaint in this timeframe, we will tell you as quickly as possible and let you know when to expect to hear from us.

Stage 2: Appeal

If you are not satisfied with the outcome of the Stage 1 complaint, you can write to us to tell us why you are unhappy within 14 days of receiving written notification of the Stage 1 outcome.
A relevant independent manager will consider reasons for the appeal and to decide if further review is required.
If further review is required, this will be initiated. We will aim to complete this within 15 working days and communicate the outcome with you in writing. If an extension is required, this will be communicated with you.

Stage 3: Final Apeal

If you remain dissatisfied following Stage 2, you need to tell us in writing within 14 days of receiving the written Stage 2 decision notification.
The CEO will review the complaint and appeal aiming to complete this within 20 working days. If an extension is required, you will be advised, and a further timeframe set.
This final appeal stage will involve both a reconsideration of the original complaint and review process. The outcome of the final appeal will be provided in writing to you by the CEO.
Stage 3 final appeal decisions are final.

Options following complaint process

If you remain dissatisfied with the response to your complaint, you have the right to raise your concerns through the following routes:

The Information Commissioners Office via telephone on 0303 123 1113 or on their website: https://ico.org.uk/make-a-complaint
The Charity Commission regulates registered charities in England and Wales. They make sure that charities are accountable, well-run, and meet their legal obligations. Further information is available on the gov.uk site, using this link: https://www.gov.uk/complain-about-charity

You can also raise concerns directly with the professional body if the complaint is in relation to an individual therapist as each will have a different professional membership. In this situation you should contact us and we will advise on which professional body and provide you with details for making complaints.

Habitual and Vexatious Complaints

Where complainants have been identified as habitual or vexatious in accordance with the above criteria, the Chief Executive Officer (CEO) (or appropriate deputy) will determine what action to take in line with the Trust's internal policy.