Confidentiality Agreement
In order to effectively provide you with appropriate accommodation and support services Queens Quarter Housing Ltd is required to process Personal Data/Sensitive Personal Data in relation to all Service Users accessing accommodation and/or support from the organisation.
Queens Quarter Housing is committed to the individuals right to confidentiality and the protection of their personal data, however, to enable effective working relationships and support individuals to the best of our ability it will be essential to share/disclose information with other organisations/professionals.
Case Managers, Support Staff and Company Administrators need to work pro-actively with other statutory/voluntary professionals that may be engaged with providing Service Users with support.
Queens Quarter Housing staff may have to make disclosures where a threat to life or well-being has been identified either to a Service User, Staff or members of the public and in these circumstances this agreement is superseded.
We take our data protection duties seriously, because we respect the trust that is being placed in us to use personal information appropriately and responsibly.
Personal data means data (whether stored electronically or paper based) relating to a living individual who can be identified directly or indirectly from that data (or from that data and other information in our possession).
Processing is any activity that involves use of personal data. It includes obtaining, recording or holding the data, organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
Sensitive personal data includes personal data about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic, biometric, physical or mental health condition, sexual orientation or sexual life. It can also include data about criminal offences or convictions. Sensitive personal data can only be processed under strict conditions, including with the consent of the individual.
Anyone processing personal data, must ensure that data is:
- Processed fairly, lawfully and in a transparent manner.
- Collected for specified, explicit and legitimate purposes and any further processing is completed for a compatible purpose.
- Adequate, relevant and limited to what is necessary for the intended purposes.
- Accurate, and where necessary, kept up to date.
- Kept in a form which permits identification for no longer than necessary for the intended purposes.
- Processed in line with the individual’s rights and in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
- Not transferred to people or organisations situated in countries without adequate protection and without firstly having advised the individual.
The Data Protection Requirements are not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the individual.
In accordance with the Data Protection Requirements, we will only process personal data where it is required for a lawful purpose. The lawful purposes include (amongst others): whether the individual has given their consent, the processing is necessary for performing a contract with the individual, for compliance with a legal obligation, or for the legitimate interest of the business.
In the course of our business, we may collect and process personal data. This may include data we receive directly from a data subject (for example, by completing forms or by corresponding with us by mail, phone, email or otherwise) and data we receive from other sources (including, for example, NIHE, PBNI, GP and other medical professionals, Social Services, PSNI and others).
We will only process personal data for the specific purposes or for any other purposes specifically permitted by the Data Protection Requirements. We will notify those purposes to the data subject when we first collect the data or as soon as possible thereafter.
If we collect personal data directly from an individual, we will inform them about:
- The purpose or purposes for which we intend to process that personal data, as well as the legal basis for the processing.
- Where we rely upon the legitimate interests of the business to process personal data, the legitimate interests pursued.
- The types of third parties, if any, with which we will share or disclose that personal data.
- Information about the period that their information will be stored.
- Their right to request from us as the controller access to and rectification or erasure of personal data or restriction of processing.
- Their right to object to processing and their right to data portability.
- Their right to withdraw their consent at any time (if consent was given) without affecting the lawfulness of the processing before the consent was withdrawn.
- The right to lodge a complaint with the Information Commissioners Office.
- Other sources where personal data regarding the individual originated from and whether it came from publicly accessible sources.
- Whether the provision of the personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, or for our legitimate interests as well as whether the individual is obliged to provide the personal data and any consequences of failure to provide the data.
We will inform data subjects whose personal data we process that we are the data controller with regard to that data.
We will only collect personal data to the extent that it is required for the specific purpose notified to the data subject.
We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.
We will not keep personal data longer than is necessary for the purpose or purposes for which it was collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required.
- Data Retention
| Information Retention Schedule | |||
| Record | Retention Period | Additional Info | Action |
| General Files | 6 Yrs from placement closure | Or 2 yrs after Date of Death | Destroy |
| Safeguarding/Vulnerable Adult Protocols | 8 Yrs from placement closure | Or 2 yrs after Date of Death | Destroy |
We will process all personal data in line with data subjects’ rights, in particular their right to:
- Confirmation as to whether or not personal data concerning the individual is being processed.
- Request access to any data held about them by a data controller (see also Clause 15 Subject Access Requests).
- Request rectification, erasure or restriction on processing of their personal data.
- Lodge a complaint with a supervisory authority.
- Data portability.
- Object to processing including for direct marketing.
- Not be subject to automated decision making including profiling in certain circumstances.
We will take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental or unlawful destruction, damage, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed.
We will have in place procedures and technologies to maintain the security of all personal data from the point of the determination of the means for processing and point of data collection to the point of destruction. Personal data will only be transferred to a data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.
We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:
- Confidentiality means that only people who are authorised to use the data can access it.
- Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
- Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on the Company’s central computer system instead of individual PCs.
Security procedures include:
- Entry controls. Any stranger seen in entry-controlled areas should be reported.
- Secure lockable desks and cupboards. Desks and cupboards should be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential.)
- Data minimisation.
- Pseudonymisation and encryption of data.
- Methods of disposal. Paper documents should be shredded. Digital storage devices should be physically destroyed when they are no longer required.
- Staff must ensure that individual monitors do not show confidential information to passers-by and that they log off from their PC when it is left unattended.
We may share personal data for our legitimate interests with the following:
- NIHE
- PSNI
- PBNI
- General Practitioner(s)/Statutory Health Services
- External Support Agencies/Professionals
- Government departments and financial institutions (benefits agencies)
- Other companies within our Group (if applicable)
- Background Checks
When you leave our service your Case Manager, or in their absence a senior member of staff, will complete a Closing Report which will summarise your placement at Queens Quarter Housing Ltd. to include basic essential information, summary of placement, outline of presenting need(s), record of external agencies engaged, record of any warnings issued or incidents that have occurred during placement, closing service charge balance, reason for placement closure and move on address (if known).
How will this information be used?
- Closing reports will be provided to relevant NIHE Housing advisor/Team Leaders where requested.
- Should you be referred to an alternative accommodation provider upon exiting our service we will provide information on your placement as outlined above as per verified request(s).
We will retain closing reports in line with the general data retention procedure noted in Clause 9.
Individuals must make a formal request for information we hold about them to Charles Toland, Managing Director. Queens Quarter Housing Ltd. reserve the right to redact sensitive information where the Managing Director in agreement with the Support Manager identifies a risk to the individual.
When receiving telephone enquiries, we will only disclose personal data we hold on our systems if the following conditions are met:
- We will check the caller’s identity to make sure that information is only given to a person who is entitled to it.
- We will suggest that the caller put their request in writing if we are not sure about the caller’s identity and where their identity cannot be checked.
Where a request is made electronically, data will be provided electronically where possible and will be password encrypted as appropriate.
We reserve the right to change this policy at any time. Where appropriate, we will notify changes by mail or email.
I junderstand how my data will be processed and managed by Queens Quarter Housing Ltd. and consent to such use.
| SIGNED | ||
| Staff Member | Service User | Date |
