Lancashire County Council Technology Enabled Care Services

In order to comply with the UK General Data Protection Regulation (UK GDPR), where personal data relating to a data subject is collected, Lancashire County Council would like to provide you with the following details.

Identity and contact details of the data controller

Lancashire County Council, PO Box 78 County Hall, Fishergate, Preston, Lancashire, PR1 8XJ

Contact details of the data protection officer

Our Data Protection Officer is Paul Bond. You can contact him at dpo@lancashire.gov.uk or Lancashire County Council, PO Box 78 County Hall, Fishergate, Preston, Lancashire, PR1 8XJ

Purposes for processing

Lancashire County Council's Technology Enabled Care (TEC) Service uses technology such as personal alarm button pendants, wristbands and wireless home sensors and detectors, to help you or a loved one feel safe and maintain independence at home.

We work with accredited suppliers and a service provider to deliver TEC services to citizens in Lancashire. The alarms and sensors are continuously monitored by our provider's dedicated 24/7 alarm receiving centre (ARC) based in Lancashire. When an alarm or sensor is activated, an operator will assess the situation and alert a nominated contact, a mobile responder or an emergency service.

Any alarm may prompt a mobile responder to go out to homes to ensure the safety and wellbeing of the individual affected by the alarm, depending on the nature of the alarm being triggered. For this reason home addresses are processed.

TEC helps any Lancashire resident to live safely and independently including those at the risk of:

Falls
Wandering or leaving their home unsecured
Seizures, blackouts or other unusual activity such as getting up frequently through the night
Forgetting to take medication – including sending prompts and reminders to take certain actions
Neglect

TEC can alert the response centre if there is risk in your property of:

Flooding
Excessive smoke, extreme temperature or gas leaks

We collect your personal data and share this data with the service provider in order to deliver these services to you. We also share your personal data with the provider for the purpose of continually reviewing, improving this service and ensuring best practice is maintained and delivered.

Where data is provided to third parties responsible for deploying technical solutions for the purposes of evaluating performance, such data will always be anonymised.

Category of personal data being processed

Personal data (information relating to a living, identifiable individual)
Special category personal data (racial, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation)

Legal basis for processing personal data

The legal basis for processing your personal data, in accordance with the UK GDPR is:

(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

Lancashire County Council will, at all times, seek the consent of its service users for the purposes of deploying these technologies. However there may be circumstances where LCC isn't able to gain consent owing to lack of capacity.

(e) Public Task: the processing is necessary for the Council to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.

Where Lancashire County Council relies on UK GDPR Article 6 (1) (e) Public Task for the purposes of deploying technology enabled care for its service users, it does so by virtue of the following legislation:

Legal basis for processing special categories of personal data

The legal basis for processing your special categories of personal data, in accordance with the UK GDPR Article 9 (2) is:

(a)The data subject has given explicit consent to the processing of this personal data.

(g) Processing is necessary for reasons of substantial public interest.

Where Lancashire County Council relies on UK GDPR Article 9 (2) (g) Substantial Public Interest for the purposes of deploying technology enabled care for its service users, it does so by virtue of the following legislation:

Data Protection Act (2018) Schedule 1 (2) (16) Support for individuals with a particular disability or medical condition

Lancashire County Council would at all times seek the consent of its service users for the purposes of deploying these technologies. However there may be circumstances where LCC isn't able to gain consent owing to lack of capacity.

Recipients of the data

Progress Housing Group (Progress Lifeline)

Information we process and share

Forename
Surname
Resident address
Telephone number
Email address
Details of social care needs, risks and outcomes
Medical history and details of medication taken
Liquid logic Adults System (LAS) number (or other identifier)
Date of birth
Next of kin details

Progress Housing are acting as a data processor on behalf of Lancashire County Council and will also process specific details relating to device monitoring and activation as well as responses to incidents.

Any transfers to another country

Retention periods

Lancashire County Council will only store your information for as long as is legally required or in situations where there is no legal retention period they will follow established best practice.

File type	Description	Security	Retention period
Electronic or paper records	Information gathered for desktop reviews and joint visits	Any documents shared by secure file sharing site	A period of 3 months only from the start of the project
LAS record	Support plans and reviews, medication and health records Health and safety information such as incident forms and risk assessments Financial profiles Correspondence relating to day to day living, such as hospital appointments and tenancy related matters	Held on a secure password protected system	Destroy 3 years after death of service user or after case has been closed
Call out history	Contact and call out information, including date, nature of the home visit and the mobile's response	Held on a secure password protected system	Destroy 3 years after death of service user or after case has been closed

Your rights

You have certain rights under the UK General Data Protection Regulation (UK GDPR), these are the rights:

to be informed via Privacy Notices such as this.
to withdraw your consent. If we are relying on your consent to process your data then you can remove this at any point.
of access to any personal information the council holds about yourself. To request a copy of this information you must make a subject access request in writing. You are entitled to receive a copy of your personal data within 1 calendar month of our receipt of your subject access request. If your request is complex then we can extend this period by a further two months, if we need to do this we will contact you. You can request a subject access request, either via a letter or via an email to Information Governance Team, address below.
of rectification, we must correct inaccurate or incomplete data within one month.
to erasure. You have the right to have your personal data erased and to prevent processing unless we have a legal obligation to process your personal information.
to restrict processing. You have the right to suppress processing. We can retain just enough information about you to ensure that the restriction is respected in future.
to data portability. We can provide you with your personal data in a structured, commonly used, machine readable form when asked.
to object. You can object to your personal data being used for profiling, direct marketing or research purposes.
in relation to automated decision making and profiling, to reduce the risk that a potentially damaging decision is taken without human intervention.

If you want to exercise any of these rights then you can do so by contacting:

Information Governance Team
Lancashire County Council
PO Box 78
County Hall
Preston
PR1 8XJ

Email: dpo@lancashire.gov.uk

To ensure that we can deal with your request as efficiently as possible you will need to include your current name and address, proof of identity (a copy of your driving licence, passport or two different utility bills that display your name and address), as much detail as possible regarding your request so that we can identify any information we may hold about you, this may include your previous name and address, date of birth and what council service you were involved with.

Further information

If you would like more information about this specific service then please contact the Policy Information and Commissioning Team at commissioningagewell@lancashire.gov.uk

For more information about how we use personal information see Lancashire County Council's full privacy notice.

If you wish to raise a complaint on how we have handled your personal data, you can contact the Information Governance team who will investigate the matter.

Lancashire County Council, PO Box 78 County Hall, Fishergate, Preston, Lancashire, PR1 8XJ or email: dataprotection@lancashire.gov.uk

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).