PRIVACY POLICY (GDPR)

Homa Privacy PolicyAudio Version
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The Data Protection Act 1998 (DPA) (the General Data Protection Regulation GDPR from May 2018) protects the rights of individuals by setting out rules about what organisations can and cannot do with information about people. We are required to process and retain individuals’ data lawfully and fairly. In order to ensure that we meet the requirement for fairness, you will find information below on how we process all personal data.

At Homa London we take our obligations under the Data Protection Act very seriously and will always ensure personal data is collected, handled, stored and shared in a secure way.

The following privacy policy outlines what personal data we collect, how we use it and who we share it with. It also provides guidance on your individual rights and how to make a complaint to the Information Commissioner’s Office, the regulator for data protection in the UK.

Homa London’s official contact details are:

Homa London

Data Protection Co-ordinator

585a Fulham Road, 

London

SW6 5UA

 

Tel: 07538 138503

Please note this is a temporary address.

Homa London’s Data Protection Co-ordinator is Audrey Boss

Homa London gathers and processes information about trainees for the following purposes:

  • To enable us to administer trainee functions from the original applications through to certification and to provide services to graduates of the Foundation Year and The Training Programme.

  • To plan and account for the use of the services provided.

  • To produce information including statistics for relevant external bodies such as the BACP.

  • To enable Homa London staff to communicate with trainees.

  • To monitor progress over the period of enrolment towards completion of a qualification.

  • To carry out assessment and to authorise award of certificates.

  • To monitor, complaints and disciplinary cases.

  • To provide trainee support, including financial, pastoral and learning resources.

  • To monitor, develop and update Homa London’s systems to ensure they operate efficiently and securely.

  • To monitor our equality and diversity objectives.

 

Homa London may also process personal data in relation to staff for recruitment purposes.

Homa London processes personal data in relation to graduates of the Foundation Year and The Training Programme to build community to support their continued professional development. 

Details of the data collected by Homa London

 

Initial enquiry via the contact form:

  • Telephone number

  • Email address

 

Detail from application forms:

  • Name

  • Contact telephone number

  • Email address

  • Postal address

  • Age / date of birth

  • Gender

  • Personal and professional references

  • Personal biography

 

Data collected on acceptance of a place on the Training Programme or The Foundation Year, updated during the four years of the training:

  • Name

  • Home address 

  • Emergency contact details (name, address, phone number/s)

  • Demographic information

  • Some sensitive personal information

  • Funding, bursary and fee related information

  • Information needed to provide services in relation to disability, learning or any other type of pastoral support

  • Training and stage details

  • Attendance

  • Trainee progress and Personal Tutor notes

  • Placement records

  • A history of communication and interaction we have had with the trainee, for example: events, surveys, emails, mailings.

 

Additional personal data may be collected by Homa London where relevant in relation to placements, professional body requirements, extenuating circumstances applications, appeals or complaints, disciplinary cases and any further optional trainee services.

 

Homa London holds the following information about tutors and administrative staff:

  • Name 

  • Postal address

  • Telephone number

  • Email address

  • Relevant qualifications

  • Training 

  • Membership of professional bodies

  • Criminal record disclosure

  • Data captured for equal opportunities monitoring (gender, date of birth, nationality, marital status, sexual orientation, religious belief, ethnicity)

  • Declaration about any disability as defined under the Equality Act 2010

 

Homa London Graduates of the Foundation Year and The Training Programme

  • Name

  • Postal address

  • Email address

  • Telephone number

  • Biographical information such as name, gender, date of birth

  • Communication preferences

  • Professional information such as place of work and job title

  • Attendance at Homa London courses and events

  • A history of communication and interaction, for example, events, surveys, emails or mailings

  • We might store information available in the public domain, including information you have shared on social media such as job title and organisation worked for depending on your privacy settings

 

Homa London will not hold onto personal data for longer than is necessary. 

 

Homa London has a retention schedule in place for the different categories of data it holds.

 

Trainee and graduate data will be held for 7 years after the end of training or graduate membership of Homa London unless the graduate chooses to remain a member of the Homa London Professional Community, in which case the following data will be held until the graduate is no longer a member of the professional community.

 

In some cases Homa London will retain data about trainees and other individuals for a significant period of time. The most important reasons are as follows:

 

  • In order that trainees awards can be verified

  • To provide references

  • For graduate events and CPD and ongoing contact with Homa London

  • To deal with complaints, appeals and disciplinary cases

As a guide, records of certificates awarded will be held indefinitely. 

Your rights

 

The GDPR provides the following rights for individuals:

 

  • The right to be informed

  • The right of access

  • The right to rectification

  • The right to erasure

  • The right to restrict processing

  • The right to data portability

  • The right to object

  • Rights in relation to automated decision making and profiling

 

For more information about these rights see:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

 

Knowing what we hold about you (the right to be informed and the right to access), an individual has the right to ask Homa London what personal data we hold about them and to ask for a copy of that information. 

 

This is called making a Data Protection Subject Access Request. A Subject Access Request should be submitted in writing via email to Homa's Data Protection Co-ordinator or by letter to the postal address provided above.

 

Homa London reserves the right to ask you to provide proof of identification and for you to clarify your request if it is unclear. You will normally receive a reply no longer than one calendar month from the date you make the request in writing. If you are unhappy with the initial response you can ask Homa London to undertake a further search if there is specific information you have good reason to believe exists but that hasn’t been provided.

 

Right to correct what we hold about you (rectification)

If you believe that Homa London holds information about you that is factually incorrect or out of date, please email the Data Protection Co-ordinator at hello@homa.london, providing the correct information, and we will seek to update it within one month.

 

The right to ask us to stop processing your data or delete it (erasure or restrict processing) – also sometimes called right to be forgotten.

You also have the right to withdraw consent from the processing of your personal data by Homa London at any time, if the basis for processing of your data relies on consent. If you wish to have your personal information deleted or restrict how we are processing it, please let us know and we will take reasonable steps to comply with your request (unless we need to keep it for academic records, legal, auditing, professional regulation, complaint handling or internal risk management reasons which can be valid reasons to retain data).

Right to data portability

The right to data portability gives you the right to receive a copy of personal data that you have provided to us, or have it sent directly to another data controller in a machine readable format. This right only applies when the data processing is based on consent or a contract and the data processing is automated (i.e. excluding paper records).

 

Right to object

If we become aware of any ongoing concerns or problems concerning our privacy practices, we will take these issues seriously and work to address them with you.

 

You also have the right to complain to the UK Regulator the Information Commissioner’s Office (ICO’s) if you believe your request has not been dealt with properly or you have a complaint to raise against Homa.London for any other data protection related issue. A complaint can be raised via the ICO’s website or write to the following address:

The Office of the Information Commissioner

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Rights in relation to automated decision making and profiling

Homa London does not undertake any automated decision making or profiling.

All trainees, staff and any other relevant individuals who handle personal information which Homa London is responsible for following the requirements of our Data Protection and Privacy Policy