Privacy notice - Health Needs Assessment: People with multiple compound needs
Overview
This privacy notice covers the collection of personal data for the purpose of conducting a Health Needs Assessment for individuals with Multiple Compound Needs.
Multiple Compound Needs (also described as multiple complex needs or severe and multiple disadvantage) describes the experience of having several support needs linked to social exclusion, and the multiplying effects of these needs in combination.
A Health Needs Assessment is a systematic approach to understanding the health and health care needs of a given population or sub-group in an area. It involves a range of data collection methods to describe the health and wellbeing of a population; including unmet needs and inequalities in health and access to services; and is used to inform effective use of resources to improve outcomes (e.g. as part of commissioning/planning services).
Personal data will be processed from a range of services who support individuals with Multiple Compound Needs. The support needs we are focusing on are a housing need, a substance misuse need, a mental health need, engagement with the criminal justice system (specifically probation) or experience of domestic abuse
East Sussex County Council takes data protection seriously. Please be assured that your information will be used appropriately in line with data protection legislation, will be stored securely and will not be processed unless the requirements for fair and lawful processing can be met.
What information is being used?
This will include the service user's first name, surname, and date of birth. We will also collect the name of the service/organisation the service user accessed.
The following data items will also be collected but will be supplied in a pseudonymised form and so will not be identifiable to any individual: age, gender and lower super output area code.
Special Category Data
The following data items will be collected but will be supplied in a pseudonymised form and so will not be identifiable to any individual: ethnicity, sexual orientation, data concerning health
How will your information be used?
The Public Health Intelligence team will use the personal data (first name, surname and date of birth) to create a pseudonymised key that will be unique to the individual. This key will be returned to the service providers so they can use it to pseudonymise the data they collect on their service users. Once this pseudonymised key has been created and returned to the service providers, ESCC will delete all personal data held relating to service users (first name, surname and date of birth).
We aim to maintain high standards, adopt best practice for our record keeping and regularly check and report on how we are doing. Your information is never sold for direct marketing purposes.
Our staff are trained to handle your information correctly and protect your confidentiality and privacy.
Your information is processed in the UK or in a country with an adequacy agreement with the UK.
What is the legal basis for processing your information?
Public task is the legal basis that applies for the processing of personal data by ESCC.
The Health and Social Care Act (2012), Section 12 sets out the functions of local authorities in the improvement of public health and the steps that may be taken to achieve this. This includes:
- providing services or facilities designed to promote healthy living (whether by helping individuals to address behaviour that is detrimental to health or in any other way);
-providing services or facilities for the prevention, diagnosis or treatment of illness;
The above functions are in line with the overarching aims of the needs assessment and the rationale for processing personal data (i.e. to inform the commissioning of a sustainable, evidence-based, and locally responsive service offer).
How long will your information be kept for?
Personally identifiable data (first name, second name, date of birth) will be kept for no longer than a month after the pseudonymised key for each service user has been returned to each service/organisation and confirmation has been received that they have all successfully used the key to pseudonymise their data.
Completed pseudonymised data extracts that are sent to ESCC for analysis will be deleted 12 months following the publication of the Needs Assessment.
Sharing your information
We will use the personal data shared (first name, surname and date of birth) by service providers participating in the needs assessment to produce a pseudonymised key for each service user which will be returned to the service provider who originally shared the personal information with ESCC. Following submission of a full pseudonymised data set from participating providers, the pseudonymised data will be used to produce statistical reports about the health needs of those people with multiple compound needs and this does not involve any sharing of personal data with other teams or organisations.
Any sharing of personal data is always done:
- on case-by-case basis
- using the minimum personal data necessary
- with the appropriate security controls in place
- in line with legislation.
Information is only shared with those agencies and bodies who have a "need to know" or where you have consented to the sharing of your personal data to such persons.
We may use the information we hold about you to assist in the detection and prevention of crime or fraud. We may also share this information with other bodies that inspect and manage public funds.
Your rights
Under data protection legislation, you have the right:
- to be informed why, where and how we use your information
- to ask for access to your information
- to ask for your information to be corrected if it is inaccurate or incomplete
- to ask for your information to be deleted or removed where there is no need for us to continue processing it
- to ask us to restrict the use of your information
- to ask us to copy or transfer your information from one IT system to another in a safe and secure way, without impacting the quality of the information
- to object to how your information is used
- to challenge any decisions made without human intervention (automated decision making)
Please visit data subject rights for further details.
How to find out more or complain
Should you have any further queries on the uses of your information, please speak directly to our service:
Please contact Joanne Bernhaut, Consultant in Public Health, in writing or by email:
Joanne Bernhaut
Consultant in Public Health
East Sussex County Council
East C
County Hall
St Anne’s Crescent
Lewes
East Sussex BN7 1UE
Email: public.health@eastsussex.gov.uk
To complain about the use of your information, please contact our Customer Services Team or our Data Protection Officer.
Further information on making a complaint.
You can also contact the Information Commissioner's Office (ICO) for further information or to make a complaint:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Phone: 0303 123 1113 (local rate)