The data controller processing your personal data is Pharmacist Support. We are registered as a data controller with the Information Commissioner’s Office (ICO). Our notification number is Z9737277 and we are committed to ensuring that the personal data we process is handled in accordance with data protection legislation (the General Data Protection Regulation and UK Data Protection Act 2018).
Our Finance Manager is the Data Protection Lead and can be contacted via firstname.lastname@example.org
What information do we hold and use in relation to you?
Pharmacist Support holds and processes personal data about the people we help – this could be via our website, our information and enquiry line, via email, a grant application, workshop attendance, or through referral to one of our partner organisations. We only collect the personal data we need for these purposes and use our best endeavours to keep that data up to date.
The personal data that we hold about you may consist of:
- Personal information – This can include your name, date of birth, gender, contact details and general geographical location.
- Evidence of eligibility for our services – This might include your GPhC registration number, or confirmation that you are a pharmacy student on an accredited course.
- Information about your income and expenditure – If you are applying for a Pharmacist Support grant we will hold the following data: your income including salary or pay, Social Security Benefits or payments, pension payments, savings or other income. We may also ask for and hold copies of your regular bills, expenditure and bank statements.
- Information about your family, lifestyle and social circumstances – We may keep information about your personal circumstances and those of your family members. This may include information about your health and wellbeing and any issues or challenges you are facing.
Depending on the nature of the service being provided, Pharmacist Support may process some information about you that is classed as “special category” data, and which receives additional protections.
Where it is of relevance to the service and would assist us in advising you, you may submit to us special category data including:
- Health or disability information about you
- Information about your religion or beliefs
- Information about your ethnic origin
- Your sexual orientation
- Gender identification
- Trade union affiliations
- Your fitness to practice as a pharmacist.
How do we collect this information from you?
We receive data from you when you:
- Contact our Information and Enquiry team or ask for support from us
- Apply for financial assistance
- Are referred on to our partner organisations for additional help.
In some circumstances, we may receive personal data from third parties including people who provide you with services such as doctors and social workers or other professionals. This process will be entirely transparent, and we will only be in touch with these third parties with your consent, unless we feel that there is a safeguarding issue relating to your welfare.
Why do we collect this information from you?
We take our obligations around the handling of data very seriously, and it is therefore important for you to know the various lawful bases that we rely on for the processing of your personal data.
We process your data as we have a legitimate interest in doing so. We would not be able to provide you with services if we were not able to process your data.
This is an assessment made by weighing our requirement against the impact of the processing on you. Our legitimate interests will never override your right to privacy and the freedoms that require the protection of your personal data.
We process your personal data for these purposes when we:
- Provide you with advice, support, financial assistance or other services
- Make referrals to third parties (with your consent) that provide a service to you on our behalf
- Advocate on your behalf (with your consent) with other agencies and organisations
- Produce statistics for reporting to ensure the effective delivery of our services. Analysis of statistics is carried out at an aggregate level and does not identify you directly.
We may also process your Special Category data in order to provide you with services or support.
We may process information about ethnic origin, sexual orientation, religion or belief or trade union membership, gender identification and health information where it is relevant.
Related Criminal data
We may collect, process and transfer ‘related criminal data’ but only in cases where you give us explicit consent and only where it is a directly related factor in the support you would like to access. For example, if you require advice about a criminal case.
What do we do with your information?
Your information may be shared internally with the staff of Pharmacist Support if access to the data is necessary for performance of their roles. For example, a member of the Information & Enquiries Team may refer to notes previously taken by a colleague when you contact us.
Access to, and the sharing of, your special category data are controlled very carefully.
How long do we keep your information?
To ensure that we are able to confirm eligibility for our services, we retain your basic personal data as a legitimate interest to ensure that we can provide lifelong support. For this reason we will retain these records indefinitely unless you object or request to engage your right to be forgotten. See What rights do you have in the way that we protect your data? below.
Who do we share your information with?
- As stated above, your data may be shared with other members of the Pharmacist Support staff team. All our staff have received data protection training and have signed up to client confidentiality.
- Student bursary applications are shared with the Bursary Panel. This comprises staff members, trustees and a specialist volunteer
Under rare circumstances, Pharmacist Support staff may share your details externally if you communicate a serious intent to harm yourself or others. In this case, if we need to breach confidentiality, we will discuss it with you beforehand where possible.
We share your personal data, where relevant, with the following external third parties:
Citizens Advice Manchester (CAM)
We may refer you to CAM for specialist advice. Contact details and brief details of the reason for the advice request are shared with the adviser in order that they can contact the client and deal with their query. The initial referral and contact attempts are managed and recorded using a secure database that both Pharmacist Support and CAM can access. Once the case is closed, the adviser notifies us of the outcome and any actual or potential financial gain via encrypted e-mail or encrypted Google document.
Outcome Consulting (OC)
We use the services of OC to support our addiction services. Where this offer is accepted, we will provide client contact details and reasons for the referral to OC in a password encrypted document via a secure SharePoint system. We receive a monthly report in which actively supported clients are referred to by their initials and reference number. The report includes brief details of the presenting issues and the ongoing support. This report is password protected. OC submits monthly invoices on which the client is identified by reference number only.
Where a client applies for help with treatment costs, a more detailed report to support the application is provided – by OC on behalf of Pharmacist Support – and is -retained. Where a service involving financial assistance or payment for service from OC is provided, these financial details will be retained for six full financial years following the year in which the final payment was made.
Once the services provided to us by OC in respect of a particular client have ended, OC will confirm directly whether the client wishes their data to either be securely destroyed by OC, or retained in accordance with OC’s own retention policy.
Our contracts with Citizens Advice Manchester and Outcome Consulting include Data Sharing Agreements that are reviewed regularly.
The Counselling and Family Centre (CFC)
For people who express an interest in the counselling service provided by the Counselling & Family Centre (CFC), we will hold the following data:
- Email address
- Evidence of eligibility
- The area of pharmacy in which you work
- How you heard of the service
We will email you a unique code and the contact number for the CFC for you to make your own arrangements. The CFC’s own privacy and confidentiality processes will then apply. We will not share any personal data with the CFC and their reports to us will give data in the aggregate from which you will not be identified. We will not receive any details of the areas discussed in the sessions provided by the CFC.
We will not share your personal data with any of the above without your prior knowledge or explicit consent. You are covered by the privacy arrangements of our partner organisations, which they will provide to you.
Our Listening Friends service is provided by trained volunteers. If you are allocated a Listening Friend, your first name, contact telephone number and any further details considered appropriate will be provided to the volunteer. Anything you discuss with the volunteer is confidential and will not be shared, unless there are safeguarding concerns, as described above.
The volunteer may keep notes of calls. These notes are anonymised and stored securely. Once the sessions have come to an end, all data collected by the volunteer will be destroyed.
Other external parties
The following external parties will also have access to your data as required:
- Our external IT support providers, who require access to all our systems
- Our external auditors, who have a legal right of access to any information they reasonably require to enable them to perform their services
- Our retail bankers for the purpose of making payments. Bank details of any recipient who has not been paid in over a year are deleted from the banking software.
People who complete one of our feedback surveys
We use a third party tool, Survey Monkey, to seek feedback from people who use or services about their experience with the charity. We use this information to monitor the quality of our activities and to provide people with the opportunity to give us their feedback and suggestions on developments and improvements. We will use the information only in ways that will not identify anyone. Respondents are given the option of providing their contact details via a separate survey if they wish to subscribe to e-news, provide a case study or would like the charity to contact them regarding some feedback they have given. Contact details will only be used for the purpose stated.
People who make a complaint to us
In the event of receiving a complaint, in accordance with our complaints policy we will record the details of the complaint and complainant and any other individuals involved in the complaint. We will only use the personal information we collect to process the complaint.
If the complaint was about an individual we may have to disclose the complainant’s identity to them, where, for example, the accuracy of a person’s record is in dispute. If a complainant does not want information identifying them to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
Personal information contained in complaint files will be kept for two years from the complaint being closed.
How do we protect your data?
We take the security of your data seriously and have cybersecurity guidelines which specify the correct way of handling IT in order to protect data against the consequences of breaches of confidentiality, failures of integrity and interruption of availability.
We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the performance of their duties.
Where we engage third parties to process, or store, personal data on our behalf, they do so on the basis of written instructions contained within a contract, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
What rights do you have in the way that we protect your data?
As a data subject, you have a number of rights. You can:
- Ask us to confirm that your personal data is being processed and to access (i.e. have a copy of) that data as well as to be provided with supplemental information about the processing (by making a subject access request)
- Require us to change incorrect or incomplete data
- Require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
- Object to the processing of your data where we rely on our legitimate interests as the legal ground for processing
- Receive from us the personal data we hold about you which you have provided to us in a reasonable format specified by you, including for the purpose of you transmitting that data to another data controller
- Ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override Pharmacist Support’s legitimate grounds for processing data
- Withdraw your consent for us to process your data where we do so with your consent.
If you would like to exercise any of these rights or make a subject access request, please contact Pharmacist Support’s Data Protection Lead, the Finance Manager. They can be contacted by email: email@example.com , by phone: 0808 168 2233 or post: Pharmacist Support, 5th Floor, 196 Deansgate, Manchester M3 3WF.
If you continue to have concerns about the use of your personal data, the Information
Commissioner’s Office is an independent body set up to uphold information rights in the UK. They can be contacted through their website: www.ico.org.uk, their helpline on 0303 123 1113, or by post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire
Policy updated March 2023; reviewed annually.