POD Full Privacy Notice

Who we are

When we say ‘we’ or ‘us’ in this notice we are referring to the POD team who are based at the Anna Freud National Centre for Children and Families. The Anna Freud National Centre for Children and Families, a registered mental health charity, is the owner and operator of the POD website and this notice informs you how we use any personal data we collect about you when you use POD. The Data Controller of that data is your service provider, our POD Customer.

We are registered with the Information Commissioner’s Office. Our registration number is: Z479393X.

If you have any questions about the content of this notice you can contact us at:

Anna Freud National Centre for Children and Families
12 Maresfield Gardens
London NW3 5SU

pod@annafreud.org

How we manage your information

Data protection legislation has changed, with the General Data Protection Regulation (EU) 2016/679 and the Data Protection Act (2018) coming into force. These changes give you more rights around how your information is used. To make sure you feel confident with how we process your information, we've updated our Privacy Notice to make things clearer.

What kinds of personal information do we hold about you?

All information about you that is stored on POD is pseudonymised, you use a POD ID not your name, and only your clinician/therapist knows which POD ID is yours.. The information POD collects about you is:

Where do we get your information from?

All of the information you enter into POD will be done collaboratively with your clinician/therapist. They will talk to you in more detail about why they would like to use POD with you and how it can be helpful and it will be your decision as to whether or not you decide to use it.

Your POD data is created directly by you when you complete any Outcome Measures as part of your therapy/treatment and your clinician/therapist will add standard information about the service.

How do we use your information?

We process your POD data on behalf of your service provider, who is a POD customer and the Data Controller of your POD data.

We use your information in the ways that you would expect:

What may be less obvious to you is that we use your information for internal analysis. To do this we combine your data with data from other POD users in order to, for example, evaluate the effectiveness of a particular service or the services in a particular geographic area. It is not possible to identify individuals from the POD data we use for this purpose so you cannot be identified in any report we produce.

Furthermore, your service provider may also be able to combine your with data other data from young people within your service, to look at whether or not the support they are providing is helpful and to think about ways that they can improve what they are offering. Again, none of this will identify you as an individual.

Who do we share your information with?

POD Customers can access all of their POD data directly and only your therapist/clinician can identify who is who in POD because only they have the POD ID list that includes your name. Each POD Customer only has access to their own data.

We do not share POD data outside of the AFNCCF. We use the combined data from many POD users to create the service reports, but we make sure the use of your information is subject to appropriate protection at all times. Only authorised AFNCCF staff have access to the POD data. They all have contractual and ethical obligations to keep the information secure. Aggregate reports, which do not identify individuals, may be published or otherwise circulated.

How long do we keep information for?

We’ll keep personal information for as long as it’s considered necessary, for the purpose for which it was collected, and to comply with our legal and regulatory requirements. This’ll involve keeping your information for a reasonable period of time after your therapy/treatment has ended. This information will not be freely accessible to anyone and will only be accessed by your service provider.

Your data rights

The GDPR has been written to ensure that your rights are central to how organisations manage your data. You have certain rights, depending on the basis for processing, that you can exercise at any time.

  1. The right to be informed – this privacy notice informs you about why and how we use your information
  2. The right of access – you may ask us for a copy of the information we hold about you
  3. The right to rectification – if any data about you is inaccurate or out of date you can ask us to correct it
  4. The right to erasure – in certain circumstances you can ask us to delete your data
  5. The right to restrict processing – in certain circumstances you can ask us to stop processing your data
  6. The right to data portability – an easily transferable copy of your data, this usually refers to IT services, but we can provide a copy.
  7. The right to object – this right particularly applies to direct marketing but we don’t use your data for that purpose
  8. Rights in relation to automated decision making and profiling – we don’t use these

You can find more information about your individual rights on the website of the Information Commissioners Office here and can contact the Data Protection Officer (DPO@annafreud.org 020 7794 2313) if you want to discuss these rights or make a request to see your data.

Security

We work with a third-party hosting company called CWCS who provide secure managed hosting of all of the data that is stored on POD. CWCS have highly secure UK data centres and are ISO 27001 and ISO 9001 accredited.  You can read their Privacy Policy here

How can I find out more?

If you require any more information, please contact us at pod@annafreud.

You may also like to contact your service provider if you would like more information on how they use your POD data.

You can contact the Information Commissioner’s Office if you would like to complain about how we use your data, or find out more about data protection legislation.

https://ico.org.uk/global/contact-us/