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Privacy Policy

Acorn House respects your privacy and is committed to protecting your personal data. This
privacy notice will inform you as to how we look after your personal data that you supply to us
and tell you about your privacy rights and how the law protects you.
This privacy notice is laid out under manageable sections to make it easier to digest and allow
you to find specific information quickly. We have also included a Glossary to explain the
meaning of some of the terms used in this privacy notice.

  1. Important information and who we are
  2. The data we collect about you
  3. How your personal data is collected
  4. How we use your personal data
  5. Disclosures of your personal data
  6. International Transfers
  7. Data Security
  8. Data Retention
  9. Your legal rights
  10. Glossary
  11. Important information and who we are
    Purpose of this Privacy Notice
    This privacy notice aims to give you information on how Acorn House collects and processes
    your personal data.
    It is important that you read this privacy notice so that you are fully aware of how and why we
    are using your data.
    Controller
    Acorn House (Fostering Services) Limited is the controller and responsible for your personal
    data (collectively referred to as Acorn House, “we”, “us” or “our” in this privacy notice).
    Ian Hopkins is the Data Protection Officer who is responsible for overseeing questions in
    relation to this privacy notice. If you have any questions about this privacy notice, including any
    requests to exercise your legal rights, please contact us using the details set out below.
    Contact Details
    Full name of legal entity: Acorn House (Fostering Services) Limited
    Phone Number: 0161 688 9500
    Email address for our DPO: ian.hopkins@acornhouse.co.uk
    Postal address: Unit 436, Chambers Business Centre, Chapel Road, Oldham, OL8 4QQ

You have the right to make a complaint at any time to the Information Commissioner’s Office
(ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would,
however, appreciate the chance to deal with your concerns before you approach the ICO, so
please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.
Third Party Links
The Acorn House website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties to collect or share
data about you. We do not control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to read the privacy notice
of every website you visit.

  1. The 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 follows:
     Identity Data includes first name, maiden name, last name, username or similar
    identifier, marital status, title, date of birth and gender.
     Contact Data includes address, email address and telephone numbers.
     Sensitive Personal Data includes race or ethnicity, religious or philosophical beliefs,
    sexual orientation, background, financial data, health and medical records, DBS and
    social service checks, family data.
     Circumstantial Data includes details about your relationship with our agency and any
    case records.
     Technical Data includes internet protocol (IP) address, your login data, browser type and
    version, time zone setting and location, browser plug-in types and versions, operating
    system and platform and other technology on the devices you use to access this
    website.
     Profile Data includes your username and password, your interests, preferences,
    feedback and survey responses.
     Usage Data includes information about how you use our website and services.
     Marketing and Communications Data includes your preferences and responses related
    to marketing you may receive from us and your communication preferences.
    We also collect, use and share Aggregated Data such as statistical or demographic data for any
    purpose. Aggregated Data may be derived from your personal data but is not considered

personal data in law as this data does not directly or indirectly reveal your identity. For example,
we may aggregate your Usage Data to calculate the percentage of users accessing a specific
website 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 notice.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with
you, and you fail to provide that data when requested, we may not be able to perform the
contract we have or are trying to enter into with you (for example, to proceed with your
assessment to become a foster carer). In this case, we may have to cancel your enquiry or
assessment with us, but we will notify you if this is the case at the time.
The Acorn House website logs IP addresses and browser types to provide you with the best
possible user experience and allow us insight into consumer behaviour. You can browse our
site without entering any personal information, and therefore remain anonymous during your
visit. However, our enquiry form asks for personal information such as name, postal address,
email address and telephone number to enable us to send out the requested information, and
make any future visits to our site easier.

  1. How your personal data is collected
    We use different methods to collect data from and about you including through direct
    interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by
    corresponding with us by post, phone, email or otherwise. This includes personal data you
    provide when you:
     enquire about fostering
     proceed with an assessment to be a foster carer
     are part of the support network for one of our foster carers
     provide a reference for a person applying to be a foster carer
     create an account on our website
     request marketing to be sent to you, or subscribe to our newsletter
     enter a competition, promotion or survey
     give us some feedback
     are a member of staff employed by our agency
     are a foster child referred to our agency
     are a foster child placed with one of our foster carers
     automated technologies or interactions. As you interact with our website or email
    marketing, we may automatically collect Technical Data about your equipment, browsing
    actions and patterns. We collect this personal data by using cookies, server logs and
    other similar technologies. We may also receive Technical Data about you if you visit
    other websites employing our cookies.
    We may receive personal data about you from various third parties and public sources as set
    out below:- Technical Data from the following parties:
     Analytics providers such as Google and Bing based inside OR outside the EU
     Database software such as web based document management systems

 Search information providers such as Google or Bing based inside OR outside the EU
 Social media channels such as Facebook based inside OR outside the EU
 Email marketing software based inside OR outside the EU
 Identity and Contact Data from publicly availably sources such as Companies House
and the Electoral Register based inside the EU.

  1. How we use your personal data
    We will only use your personal data when the law allows us to. Most commonly, we will use your
    personal data in the following circumstances:
     Where we need to perform the contract we are about to enter into or have entered into
    with you.
     Where it is necessary for our legitimate interests (or those of a third party) and your
    interests and fundamental rights do not override those interests.
     Where we need to comply with a legal or regulatory obligation.
    If you submit your personal data to us via an enquiry form on paper or one of our web pages,
    we will accept this as consent for us to contact you with information regarding fostering.
    For purposes outside of our contract, such as sending you marketing emails and invitation to
    events, we will require you to provide consent as a legal basis for processing your personal data
    in this way. You have the right to withdraw consent to marketing communications at any time by
    contacting us directly to unsubscribe.
    If a child’s personal data is submitted to us to provide the service of foster care, we will process
    this data in accordance with the law.
    Using your sensitive personal data
    In light of the services which we provide in fostering, it is necessary for us to use sensitive
    information about your background, health, finances, race or ethnicity, religious or philosophical
    beliefs, sexual orientation, family data, and outcomes from DBS and social service / local
    authority checks, education checks and other checks and references as appropriate.
    This sensitive information forms a part of our fostering assessments and reviews and allows us
    to proceed with providing a service to you, such as completing an assessment or review on a
    potential or approved foster carer. We will require consent to obtain this information from you
    and process it as part of your assessment or review. We recognise the sensitivity of this
    information and ensure that it is handled both confidentially and within secure computer
    processing software.
    Purposes for which we will use your personal data
    We have set out below, in a table format, a description of all the ways we plan to use your
    personal data, and which of the legal bases we rely on to do so. We have also identified what
    our legitimate interests are, where appropriate.
    Please note that we may process your personal data for more than one lawful ground
    depending on the specific purpose for which we are using your data. Please contact us if you

require details about the specific legal ground we are relying on to process your personal data
where more than one ground has been set out in the table below:
Purpose/Activity
 
 

Type of data
 
 

Lawful basis for processing
including basis of legitimate
interest
 

To process your enquiry
 
 

(a) Identity
(b) Contact
 

Performance of a contract
with you, such as to provide
information on fostering
 

To process and deliver our
services to you:
(a) Commence a fostering
assessment
 
 

(a) Identity
(b) Contact
(c) Sensitive information
(d) Marketing and
Communications
 

(a) Performance of a contract
with you
(b) Necessary for our
legitimate interests
(c) Necessary for us to
proceed with a fostering
assessment
 

To enable you to partake in a
prize draw, consultation,
competition or complete a
survey
 
 
 
 

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
 

(a) Performance of a contract
with you
(b) Necessary for our
legitimate interests (to study
how customers use our
services, to develop them and
grow our business)
 
 

To administer and protect our
business and this website
(including troubleshooting,
data analysis, testing, system
maintenance, support,
reporting and hosting of data)
 
 
 

(a) Identity
(b) Contact
(c) Technical
 
 
 

(a) Necessary for our
legitimate interests (for
running our business,
provision of administration
and IT services, network
security, to prevent fraud and
in the context of a business
reorganisation or group
restructuring exercise)
(b) Necessary to comply with
a legal obligation
 

To deliver relevant website
content and advertisements to
you and measure or
understand the effectiveness
of the advertising we serve to
you
 
 
 
 

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
 

Necessary for our legitimate
interests (to study how
customers use our services,
to develop them, to grow our
business and to inform our
marketing strategy)
 
 
 
 

To use data analytics to
improve our website,
products/services, marketing,
customer relationships and
experiences
 
 

(a) Technical
(b) Usage
 
 

Necessary for our legitimate
interests (to define types of
customers for our services, to
keep our website updated and
relevant, to develop our
business and to inform our
marketing strategy)
 

To make suggestions and
recommendations to you
about services that may be of
interest to you
 
 
 
 

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
 

Necessary for our legitimate
interests (to develop our
products/services and grow
our business)
 
 
 
 

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising.
Promotional news and events
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what
we think may be of interest to you. This is how we decide which services and events may be
relevant for you (we call this marketing).
You will receive marketing communications from us, including information about fostering and
invitations to events, if you have opted in to receive these communications.
Third Party Marketing
We will get your opt-in consent before we share your personal data with any company outside of
Acorn House, for marketing purposes.
Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by
Contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data
provided to us as a result of a service we are providing, such as completing a fostering
assessment or review.
Cookies and Webtracking
WHAT ARE COOKIES?

Our site uses cookies to keep track of progress and to provide our visitors with a tailored user
experience. With the help of cookies, we can present you with customised content and adverts
that will be of more interest to you. We also use cookies to remember your passwords for you
so you don’t have to re-enter them each time you visit the site. You have the option of setting
your browser to reject cookies. However, if certain cookies that track your details are rejected
then we won’t be able to pre-fill any data on the site or direct you to the correct stage on your
next visit.
COOKIE UPDATES
Acorn House use necessary cookies to make the website easier for you to use and to ensure
you get the best experience. If you choose to continue without changing these settings, you
consent to this, but should you want to, you can change your settings at any time.
We will only read or write cookies for the preference level set, cookies set prior to you changing
your settings will still be on your computer and you can remove them using your browser
settings.
We use a cookie to remember your cookie preferences this has a couple of consequences:
If you delete all your cookies you will have to update your preferences with us again.
If you use a different device, computer profile or browser you will have to tell us your
preferences again.
ADVERTISER COOKIES
You may be served cookies from advertisers while visiting our site. We do not control, nor do we
have access to, any of the information they may collect.
HOW WE USE COOKIES AT ACORN HOUSE
Please view our Cookie Policy on the website for information on how we use Cookies.
INFORMATION THIS WEBSITE GATHERS/TRACKS
As web tracking offers more chances to market to website visitors across the Internet, you as a
visitor to our agency website may be targeted with adverts on other websites. Google and third
party vendors might show targeted adverts with the ability to opt out. First and third party
cookies are used to provide information and offer improvements to optimise quality of adverts
served. You can change the cookie management settings in your web browser to stop these
adverts. If you are a registered Facebook user, you may also receive targeted adverts from us.
You can read about how Facebook works by following this link https://en-
gb.facebook.com/policies/cookies/
CHANGE OF PURPOSE
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new
purpose is compatible with the original purpose, please contact us.

If we need to use your personal data 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 data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.

  1. Disclosures of your personal data
    We may have to share your personal data with the parties set out below for the purposes set out
    in the table in paragraph 4 above. Such third parties consist of:
     IT: Service providers acting as processors who provide IT and system administration
    services.
     Advisors: Professional advisers including lawyers, bankers, auditors and insurers who
    provide consultancy, banking, legal, insurance and accounting services.
     Authorities: HM Revenue & Customs, regulators and other authorities who require
    reporting of processing activities in certain circumstances.
    We require all third parties to respect the security of your personal data and to treat it in
    accordance with the law. We do not allow our third-party service providers to use your personal
    data for their own purposes and only permit them to process your personal data for specified
    purposes and in accordance with our instructions.
  2. International Transfers
    The only circumstances where data may be transferred outside the European Economic Area
    (EEA) is regarding surveys completed in Survey Monkey. Survey Monkey transfers some data
    to the United States, however this has a Privacy Shield in place which is compliant with GDPR. 
  3. Data Security
    We have put in place appropriate security measures to prevent your personal data from being
    accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we
    limit access to your personal data to those employees, agents, contractors and other third
    parties who have a business need to know. They will only process your personal data on our
    instructions and they are subject to a duty of confidentiality.
    We have put in place procedures to deal with any suspected personal data breach and will
    notify you and any applicable regulator of a breach where this is likely to result in a risk to the
    rights and freedoms of any person.
  4. Data Retention
    How long will you use my personal data for?
    Acorn House will only retain your personal data for as long as necessary to fulfil the purposes
    we collected it for, including for the purposes of satisfying any legal, accounting, or reporting
    requirements.

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
requirements.
We have outlined the retention periods for different types of personal data in the table below:

Type of Data Period of Retention

Records of people who enquired about

fostering

At least 5 years from the closure of the

enquiry

Case records of prospective foster carers who
are not approved, or who have withdrawn
their application prior to approval

At least 5 years from the refusal or
withdrawal, under the Fostering Services
(England) Regulations 2011. At least 25 years
in line with Agency policy.

Case records of approved foster carers

At least 10 years from the date on which their
approval was terminated, under the Fostering
Services (England) Regulations 2011. At least
25 years in line with Agency policy.

Case records of children placed with foster

carers

Until the 75th anniversary of the child’s date
of birth, in line with the Care Planning,
Placement and Case Review (England)
Regulations 2010, unless requested by the
local authority to return the records to them.

Records of children referred for foster

placements

1 month from the closure of the referral
(unless placed with carers)

  1. Your legal rights
    Under certain circumstances, you have rights under data protection laws in relation to your
    personal data. Your rights include:
     Request access to your personal data (commonly known as a “data subject access
    request”). This enables you to receive a copy of the personal data we hold about you
    and to check that we are lawfully processing it.
     Request correction of the personal data that we hold about you. This enables you to
    have any incomplete or inaccurate data we hold about you corrected, though we may
    need to verify the accuracy of the new data you provide to us.
     Request erasure of your personal data. This enables you to ask us to delete or remove
    personal data where there is no good reason for us continuing to process it, for example
    where you consider that we do not need it any longer for the purposes for which we
    originally collected it as explained to you in this Privacy Policy, where you have
    withdrawn your consent to our using it and we had relied on that consent according to
    this Policy, where you consider that we cannot show a ‘legitimate interest’ in continuing
    to process it and we have relied on that legitimate interest to process it as explained to
    you in this Policy.You also have the right to ask us to delete or remove your personal
    data where you have successfully exercised your right to object to processing (see
    below), where we may have processed your information unlawfully or where we are
    required to erase your personal data to comply with local law. Note, however, that we

may not always be able to comply with your request of erasure for specific legal reasons
which will be notified to you, if applicable, at the time of your request.
 Object to processing of your personal data where we are relying on a legitimate interest
(or those of a third party) and there is something about your particular situation which
makes you want to object to processing on this ground as you feel it impacts on your
fundamental rights and freedoms. You also have the right to object where we are
processing your personal data for direct marketing purposes. In some cases, we may
demonstrate that we have compelling legitimate grounds to process your information
which override your rights and freedoms.
 Request restriction of processing of your personal data. This enables you to ask us to
suspend the processing of your personal data in the following scenarios: (a) if you want
us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do
not want us to erase it; (c) where you need us to hold the data even if we no longer
require it as you need it to establish, exercise or defend legal claims; or (d) you have
objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
 Request the transfer of your personal data to you or to a third party. We will provide to
you, or a third party you have chosen, your personal data in a structured, commonly
used, machine-readable format. Note that this right only applies to automated
information which you initially provided consent for us to use or where we used the
information to perform a contract with you.
 Withdraw consent at any time where we are relying on consent to process your personal
data. However, this will not affect the lawfulness of any processing carried out before
you withdraw your consent.

If you wish to exercise any of these rights, please contact us, marking your query for the
attention of the DPO.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive. Alternatively, we may refuse to comply with your request in these
circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and
ensure your right to access your personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to any person who has no right to
receive it. We may also contact you to ask you for further information in relation to your request
to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer
than a month if your request is particularly complex or you have made a number of requests. In
this case, we will notify you and keep you updated.
10 Glossary

Lawful Basis
Legitimate Interest means the interest of our agency in conducting and managing our business
to enable us to give you the best service and the best and most secure experience. We make
sure we consider and balance any potential impact on you (both positive and negative) and your
rights before we process your personal data for our legitimate interests. We do not use your
personal data for activities where our interests are overridden by the impact on you (unless we
have your consent or are otherwise required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against any potential impact on you in
respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance
of a contract to which you are a party, or to take steps at your request before entering into such
a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are subject to.
Necessary for us to commence a fostering assessment means processing your sensitive
personal data (i.e. health data, finance data) where it is necessary for the purposes of the
assessment to determine the suitability to foster (subject to required conditions and safeguards).