All information held within our service is confidential and information is only disclosed as lawfully required.

Information may only be released to outside agencies following agreement with you unless there physical or psychological harm is of concern. Your identity will remain confidential unless we are legally required to share. You will be made aware of this by your Guardian.

All requests need to be made in writing to bswccg.f2su.wiltshire@nhs.net, We will ensure you receive the information within 20 days.

Read ICO Information On The FOIA

Wilcodoc Limited (we or us) is a company registered in England and Wales under company number 06599944 with registered office address Station House, North Street, Havant, Hampshire, PO9 1QU.

Our contact details are:

Email: bswccg.f2su.wiltshire@nhs.net

• What is the purpose of this document?
  • We are committed to protecting and respecting your privacy. This privacy notice sets out the basis on which we process any personal data we collect about users of our Freedom To Speak Up Guardianship Service (our Service) and how that information will be processed by us.
  • This privacy notice applies to individuals who communicate with us to make use of our Service (you).
  • This privacy notice does not apply to individuals whose personal data you might share with us as part of your conversations with us, although we will treat such shared personal information as confidential as part of your record with us.. You (or the organisation you work for) are required to provide them with a privacy setting out how you use and share their personal data, including with us.
  • We are a data controller. This means that we are responsible for deciding how we hold and use personal information about you, and for explaining this clearly to you.
  • If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our Data Security and Protection Lead using the details set out above.
  • Please read this privacy notice carefully to understand what we do with your personal information and what rights you have in relation to our activities.
  • Our service is not intended for children and we do not knowingly collect personal data of children.
• What is personal data and our lawful basis for processing
  • Personal data, or personal information, means any information relating to an individual from which that person can be identified. There are special categories of more sensitive personal information which require a higher level of protection (see further at section 4, below).
  • We will only use your personal information when the law allows us to. Our principle lawful basis for processing is set out in the table below. However, some of our grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
  • We may only rely on our legitimate interests (or those of a third party) to process your personal information, if your interests and fundamental rights do not override those interests. Where we rely on legitimate interests for our processing, we have set out the relevant interest, below.
  • Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
  • We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
  • Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.
  • Where we need to collect personal data by law, or under the terms of a contract to provide services to you, and you fail to provide that data when requested, we may not be able to perform the contract to provide our services to you. We will notify you if this is the case at the time.
• Data we collect about you
  • Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
  • We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, title and date of birth.

Contact Data includes email address, telephone numbers and home address.

Employment Data includes your employer, office address, job role and nature of your job.

Usage Data includes information about how you use our services.

• We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of people using our services from within a particular area feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
• As part of our usual course of business, we do not ask you to provide Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) except that we may ask you to optionally provide details of your ethnicity for our mandatory reporting requirements (which are reported anonymously as statistics). Nor do we collect any information about criminal convictions and offences. However, we may process such information:
  • if it relates to a health condition or disability, in order to meet our legal obligation to make reasonable adjustments in the provision of our services;
  • to ensure meaningful equal opportunity and diversity and inclusion monitoring and reporting;
  • where it is needed to protect your vital interests (or someone else’s interests) and you are not capable of giving your consent;
  • where it is necessary to establish, exercise or defend a legal claim;
  • where you have manifestly made the information public; or
  • otherwise with your explicit consent.
• How is your personal data collected?
  • We use different methods to collect data from and about you including through:
  • Direct interactions. You may give us your Identity, Contact and Employment by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • register to use the Service;
    • request information to be sent to you;
    • give us feedback, make a complaint or contact us.
  • Third parties or publicly available sources. We may also receive personal data about you from various third parties and public sources as set out below:
    • your employer;
    • people you work with; and
    • your social media profiles.
  • Purposes for which we will use your personal data
    • Use of your data. We will use your:
      • Identity Data and Contact Data to register you as a new user of our services;
      • Identity Data, Contact Data and Employment Data to support you with the issues that you raise with us;
      • Identity Data and Contact Data to manage our relationship with you, which will include notifying you about changes to our services or to this privacy notice;
      • Identity Data, Contact Data and Usage Data to evaluate our services and inform changes to our services; and
      • Identity Data, Contact Data and Usage Data to make suggestions and recommendations to you about goods or services that may be of interest to you.
    • Lawful basis. Our lawful basis for processing your personal data in the ways set out above it that it is necessary for our legitimate interests to provide you with support, keep our records up to date, and develop and improve our services. Our lawful basis for processing any Special Category Data will be as necessary for the purposes listed at section 4 above or otherwise only with your consent.
    • Automated decision-making. Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We do not envisage that any serious decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
  • Sharing your information
    • We share your personal information with third party contractors and service providers to the extent necessary to provide services to you.
    • We share your information with other third parties as follows:
      • our regulators, professional advisors, insurance provider and auditors;
      • HMRC or other government or law enforcement agencies;
      • if we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets;
      • if we have a legal obligation to do so; and
      • for the purposes of fraud protection and credit risk reduction.
    • The categories of third parties listed above use your personal data for their own purposes and are responsible for their own compliance with data protection legislation.
    • We may share your data with third-party service providers who provide services to our business, such as our IT support and maintenance service and email exchange server provider and other businesses that provide certain services on our behalf. All of our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes.
  • Data security
    • We have put in place:
      • appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed; and
      • procedures to deal with any suspected data security breach, and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
    • Any personal information that you submit to us will be held on secure servers, based within the UK or European Economic Area (EEA).
    • If we are required to transfer your information to a third country outside the UK or EEA, we have put in place appropriate measures to ensure that your personal information is protected in those third countries in a way that is consistent with and which respects the EU and UK laws on data protection. Details of these measures are available from the Data Security and Protection Lead on request.
    • If you communicate with us from outside the UK or EEA we may transfer personal information to the correspondence address you provide to us to the extent necessary to provide our services to you. We will take all reasonable steps to ensure that such transfers are secure. By requesting services from us from outside the UK or EEA you agree that such transfer is necessary for us to complete your order.
  • How long will we keep your personal information for?
    • We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
    • To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
    • We keep basic information about you (including Identity, Contact and Employment Data) for eighteen months after we have most recently heard from you or after there has been progress/change in the matter you have raised with us.
    • In some circumstances you can ask us to delete your data: see your rights below for further information.
    • In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
  • Your rights
    • You have the following rights:
      • to be told what we are doing with your personal information (we do this by providing you with this privacy notice);
      • to correct or update the personal information we hold about you.
      • to object to the processing of your personal information;
      • to request a copy of the personal information we hold about you;
      • to ask us to delete the information that we hold about you where there is no good reason for us continuing to process it;
      • to ask us to stop processing your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground and where there is no good reason for us continuing to process it;
      • to ask us to restrict how we use your personal information for a period of time if you claim that it is inaccurate and we want to verify the position or in some limited other circumstances;
      • to ask us to send your personal information to another organisation in a computer-readable format;
      • to complain to the Information Commissioner’s office if you are unhappy with our use of your personal data: you can do this at https://ico.org.uk/concerns/.
    • Do contact us straight away if you consider that we are not handling your personal information properly so we can try and sort the problem out.
    • If we delete your personal information or restrict our use of it, we will not be able to provide our services to you.
    • If you want to exercise any of your rights, please contact us at the address above. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).

Last Updated October 2021

Your opinion matters and it’s for this reason we encourage frank and open discussion and feedback regarding just about everything we do.

We’re keen for you to let us know what you think, whether it’s positive or negative and also to make some suggestions.

We take time to listen and understand so the way we see it, it’s by working in partnership that we can achieve the most advantageous outcomes for everyone involved. There are many ways we go about this, but most importantly the choice is yours.

Here’s some of the ways you can contact us and become involved. We’ve also listed the principal means of communication from ourselves, available to you on an ongoing basis. Communication is a two-way process, so please get in touch whatever your reason.

Who to Contact About What?

Please continue to visit our website. You can also contact us via letter, e-mail, phone or fax. Please see the contact page for our contact details.

We accept that sometimes you may feel a need to complain. If this is the case, you might also find it helpful to speak to our Operations Directors, Anna Morton.

Anna will listen and help resolve issues and misunderstandings which may arise. Please email or use our contact page. She will contact you at the earliest possible opportunity to arrange a convenient time to talk. We will acknowledge your concerns within 3 working days and will undertake a thorough investigation in order to response fully to the issues.