This privacy notice tells you what to expect us to do with your personal information. 

What information we collect, use, and why   

We collect or use the following information to provide services and for third party referrals: 

names and contact details, gender, pronoun preferences, addresses, date of birth, emergency contact details, next of kin details, service use history, right to work information, health information including medical conditions, test results, allergies, medical requirements and medical history, dietary information including allergies and health conditions, information about care needs including disabilities, home conditions, dietary requirements and general care provisions, information about work, home and living conditions, information about support requirements, information about lifestyle, interests or personal history, criminal offence data, records of meetings and decisions, information about income and financial needs for funding or personal budget support, payment details including card or bank information for transfers and direct debits, and information relating to compliments or complaints. 

We also collect or use the following special category information to provide services and for third party referrals: racial or ethnic origin, religious or philosophical beliefs, health information, and sexual orientation information. 

We collect or use the following information to receive donations or funding and organise fundraising activities:  names and contact details, addresses, donation history, taxpayer information for Gift Aid purposes, gifts in wills, and information about visitors to our website. 

 We also collect or use the following special category information to receive donations or funding. This information is subject to additional protection due to its sensitive nature: Racial or ethnic origin, sexual orientation information. 

We collect or use the following personal information to comply with legal requirements: name, contact information, identification documents, and safeguarding information. 

We collect or use the following personal information for dealing with queries, complaints or claims: names and contact details, addresses, video recordings of public areas, customer or client accounts and records, information relating to health and safety including incident investigation details, reports and accident-book records, and correspondence. 

Lawful bases and data protection rights  

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website. 

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website: 

• Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.  

• Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. 

• Your right to erasure – You have the right to ask us to delete your personal information. 

• Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information.  

• Your right to object to processing – You have the right to object to the processing of your personal data.  

• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.  

• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time.  

If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice. 

Our lawful bases for the collection and use of your data   

Our lawful bases for collecting or using personal information to provide services and goods, including delivery and third party referrals are: 

Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time. 

Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: 

We record personal information and information about peoples’ situations to perform and have records of casework. If a person gives consent, we may: refer people to other services eg advice services, health services or housing providers; make appointments with other advice services, health services or housing providers; share personal information with other advice services, health services or housing providers. This helps us to provide the services we do with an aim to preventing someone from homelessness, housing someone, helping them to secure benefits or documents, assisting them with budgeting and life goals, harm minimisation for substance users. We use client’s data in ways they would reasonably expect with a compelling justification to do so. The benefits of recording personal information are that we can understand a person’s circumstances, pick up casework from another member of staff if they cannot perform the work themself (due to illness or annual leave etc), avoid asking the client the same thing multiple times, coordinate support and make the appropriate referrals to organisations to help meet their needs. The information is highly sensitive, so we recognise that there is risk involved in storing this data. We therefore only access it when we have a good reason, only share it when necessary and relevant and do not sell it to commercial organisations. We shred paper files after uploading them to our case management system or share point, both of which are secured. On balance we think the need for storing personal information to effectively carry out casework outweighs the privacy risk to the client’s data. 

For more information on our use of legitimate interests as a lawful basis, you can contact us using the contact details set out above. 

Recognised legitimate interests – our pre-approved purpose for collecting or using personal information to provide services and goods, including delivery and third party referrals: 

Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability. 

Our lawful bases for collecting or using personal information to receive donations or funding and organise fundraising activities are: 

Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time. 

Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object. 

Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability. 

Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: Our legitimate interest is to raise funds so that we can continue to provide our services. We use limited personal information to maintain records of donors, acknowledge donations, manage fundraising relationships, understand the effectiveness of different campaigns and contact people about relevant opportunities to support us where they would reasonably expect this. The processing is necessary because fundraising could not be managed without basic contact, donation and communication records. It enables the charity to manage funding, run efficient campaigns and thus deliver our services to the people we help. We minimise the information collected and restrict access. We consider the benefits to outweigh the risks to a person’s data privacy as we do not use sensitive information unless specifically justified and we do not make excessive or intrusive contact and people can opt out of fundraising communications at any time.  

For more information on our use of legitimate interests as a lawful basis, you can contact us using the contact details set out above. 

Our lawful bases for collecting or using personal information to comply with legal requirements are: 

Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability. 

Recognised legitimate interests – our pre-approved purpose for collecting or using personal information to comply with legal requirements: 

We need to protect the physical, mental or emotional well-being of people who need extra support, or to protect them from harm or neglect (the ‘safeguarding condition’). 

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are: 

Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability. 

Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: Our legitimate interest is to respond to enquiries, investigate and resolve complaints, and establish, exercise or defend legal claims fairly and effectively. We need to use relevant personal information to understand the issues raised, verify events, communicate with the people involved, reach an informed decision, provide an appropriate response, maintain an audit trail and identify improvements to our services. This processing benefits the person raising the matter by enabling us to consider their concerns properly and provide a clear and accountable response. It also protects the rights and interests of other people involved and enables the charity to manage disputes, demonstrate how decisions were reached and respond to potential legal claims. We only use information that is relevant and necessary for the particular query, complaint or claim. Information is shared externally only where necessary and lawful. People would reasonably expect us to keep sufficient records to respond to a matter they have raised or to investigate an allegation involving them. We recognise that complaint and claim records may contain sensitive or disputed information, so we check accuracy where possible, restrict access and allow people to exercise their data-protection rights. We consider that these safeguards ensure that our interests do not unfairly override the rights and freedoms of the people involved. 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.  

Where we get personal information from 

Directly from you, family members or carers, other health and care providers, social services, charities or voluntary sector organisations, councils and other public sector organisations. 

How long we keep information   

Our policy is to store personal information for 6 years and after that it is anonymised or deleted. 

Who we share information with   

Joint data controllers 

We have a joint controller relationship with Via. We process your personal information with that joint controller for the following reason: Via and KCAH work together and share information which is integral to the care and treatment of the cohort. This will entail simultaneous data entry into Via’s case management system Nebula to effectively share information about individuals engaged in both services. 

 Data Processors 

• Superhighways: used to manage our IT systems 

• People HR: used to store HR records 

Others we share personal information with 

Other health providers such as GPs and consultants, charities and voluntary organisations, care providers, organisations we need to share information with for safeguarding reasons, emergency services, the public through our website, social media or other marketing and information media, and suppliers and service providers. 

How to complain   

If you have any concerns about our use of your personal information, you can make a data protection complaint to us by any contact method listed on the header of this document. If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.  

The ICO’s address: 

Information Commissioner’s Office 
Wycliffe House 
Water Lane 
Wilmslow 
Cheshire 
SK9 5AF 

Helpline number: 0303 123 1113  

Website: https://www.ico.org.uk/make-a-complaint 

Signed:

 

Date: 30/07/26