Privacy policy – Looking After You Too: Individual coaching support for primary care staff

Last updated – 23/12/21

As a team of organisations, we’re committed to protecting and respecting your privacy. This Policy explains when and why we collect personal information about people who use the service, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using the service, you’re agreeing to be bound by this Policy.

Summary

This is just a summary. Please ensure you read the full, legal version below.

This privacy notice relates to the Looking After You coaching service. It does not include use of this website, the terms for which can be found at the bottom of each page.

Introduction

Below is a description of what data we gather from you as a visitor to our publicly accessible website. Also, included below is a description of why we collect and how we use the data we collect.
In this notice, the words “our,” “us,” “we,” and “Looking After You” refer to NHS England and NHS Improvement and our affiliates (which includes any person or entity that controls us, is controlled by us, or is under common control with us, such as our subsidiary, parent organisation, or our employees).

Before you submit any information to Looking After You, please carefully review this notice. By using any part of the Looking After You applications or services, you consent to the collection, use, disclosure and sharing of your information as further outlined below in this notice.

Affiliates

The Affiliates involved in this programme are:

• Coaching on Call Limited – provide the booking systems for the programme.
• Institute for Employment Studies – leading evaluation of the programme.
• A number of organisations that are providing the coaching and the supervision for coaches.

What data we collect, how we collect it and why

Data you give to us directly.

You will supply us with your name, email address and your mobile phone number. This is used to support the scheduling of sessions with your coach, including any calendar invitations or reminders (including those sent by SMS).

Additionally, we will collect information on your NHS region, role and the standard set of NHS diversity data on gender, marital status, ethnicity, religious belief, disability, age and sexual orientation.  This will be used for diversity monitoring and evaluation.  For each session you book and after two weeks following a session we will also capture a number of statements.  These will be used anonymously to evaluate Looking After You only if you have given your consent. The evaluation is being carried out by The Institute for Employment Studies in conjunction with NHS England and NHS Improvement.  You can find more information on their approach to evaluation here. Additionally the Institute for Employment Studies will contact you by email with two short feedback surveys relating to the programme. Aggregate data on all aspects of the evaluation will be available publicly and will ensure no individual can be identified.

At the end of each session we will ask you for feedback. This information will be shared with the coach, coaching providers, NHS England and NHS Improvement. The aggregated scores may be shared publicly. We may contact you if we wish to share any comments publicly. We will use your email address to send you emails to facilitate the service.

We will also send information on the Looking After You programme, other emails you have requested as part of the signup process and other communications. Each email contains an unsubscribe link.

Data your coach collects from you

Your coach will agree the timing of further sessions with you and may capture the general theme of a session. These may be shared with NHS England, NHS Improvement and The Institute for Employment Studies. The coach may take confidential notes to support the process, which are for their own use only. If information is disclosed that the coach reasonably believes there is an imminent or likely risk of danger or harm to yourself or others, they will discuss a potential referral with you and may, in exceptional circumstances escalate this.  Coaches also partake in formal supervisory processes where they may anonymously share their coaching experiences.

Data we collect from you automatically

When you visit the Looking After You systems, we and our service providers acting on our behalf automatically collect certain data using tracking technologies like cookies, web beacons, and similar technologies. We also will log your IP address. These are primarily needed to support the functioning of the systems and to facilitate troubleshooting, and are not passed on to any third party.

How long we retain your data

NHS England and NHS Improvement and our Affiliates review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations. We will hold your personal information on our systems for as long as is necessary for the relevant activity.

Who we may share your data with

Unless you give us your permission, we don’t share data we collect from you with third parties, except as described below:

• Third-party service providers or consultants (‘Affiliates’). We may share data collected from you on the Looking After You systems with third-party service providers or consultants who need access to the data to perform their work on our behalf, including Associate coaches. These affiliates are limited to only accessing or using this data to provide services to us and must provide reasonable assurances that they will appropriately safeguard the data.
• We may share data on number of sessions and aggregated data on coaching themes/actions with NHS bodies. This will be done such that no individual can be identified from the data.
• Compliance with Laws. We may disclose your data to a third party if (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or government request (including to meet national security or law enforcement requirements), (ii) to enforce our agreements and policies, (iii) to protect the security or integrity of the Coaching on Call Limited systems or their services and products, (iv) to protect ourselves, our Affiliates and their customers, or the public from harm or illegal activities, or (v) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury. If NHS England, NHS Improvement or any Affiliate is required by law to disclose any of your data that directly identifies you, then we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, subpoena or court or administrative order. Further, we object to requests that we do not believe were issued properly.
• Business transfers. If any Affiliate goes through a corporate sale, merger, reorganisation, dissolution or similar event, data we gather from you through our systems may be part of the assets transferred or shared in connection with due diligence for any such transaction. Any acquirer or successor of an Affiliate may continue to use the data we collect from you through our systems as described in this notice.
• We do not share your data with third parties for their direct marketing purpose.

International Operations and Transfers Out of the European Union

Data for this project will not be transferred outside of the UK/EU.

Information from Children

We do not knowingly collect any personal information directly from children under the age of 16. If we discover we have received any personal information from a child under the age of 16 in violation of this Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about anyone under the age of 16, please contact us at [email protected]

How we secure your data

We use appropriate security measures to protect the security of your data both online and offline. These measures vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Please note, though, that no website or internet transmission is completely secure, so while we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur.

How we treat Do-Not-Track Signals

Looking After You systems does not currently respond to web browser’s Do-Not-Track signals. You can learn more about Do Not Track here https://www.makeuseof.com/tag/not-track-actually-work

How we tell you about changes to our privacy practices

We may change our Website Privacy Notice from time to time. If we make changes, we’ll revise the “Last Updated” date at the top of this notice, and we may provide additional notice such as on the NHS England or NHS Improvement homepage. If we make any material changes to this notice, NHS England and NHS Improvement will notify you of those changes through a notice on the NHS England and NHS Improvement Site or through other reasonable means of communication, such as email. We will comply with applicable law with respect to any changes we make to this notice.

How to make choices about your data

Deletion, access, and changes to your data.

The accuracy of your information is important to us. We’re working on ways to make it easier for you to review and correct the information that we hold about you. To request deletion of, access to, or to make changes to data we’ve collected from you via the Looking After You systems, email us at [email protected]. Please note that even if you request that we delete data we’ve collected from you, we may still retain data collected from you in an aggregated or anonymized form that does not identify you, where this cannot be disaggregated. We also will not delete your data if we are legally required to maintain it.