Privacy Policy

The proper handling of personal information by Llesiant Delta Wellbeing is very important to the delivery of our services and maintaining customer confidence.

Personal data is any information that relates to a person who can be directly or indirectly identified from the information. The terms ‘information’ and ‘personal data’ are used throughout this privacy notice and have the same meaning.

To ensure that Delta Wellbeing treats personal information correctly, we seek to adhere in full to the requirements of Data Protection legislation.

This privacy notice has therefore been produced to explain as clearly as possible what we do with your personal data.

1. The purpose for which we use your personal data

The information we collect about you will be used for the purpose(s) of:

  • Planning, preparing and delivering services to support you to stay independent, and to maintain choice and control over your life. These can include, but are not limited to;

    • Alarm monitoring
    • Emergency Community Response
    • Wellbeing Calls
    • Telehealth
    • Digital Services
    • Emergency out-of-hours support
    • Lone working support
    • Emergency housing repairs support

  • Reviewing services given to you to ensure it is of the highest possible standard.

  • Reviewing individual and group data to provide individualised services and population health data.

  • Research to evaluate and improve the quality, effectiveness and impact of our services.

  • Investigating complaints, legal claims or incidents.

  • Helping you access our services:
    • By telephone
    • By email
    • Through our website
    • Via social media channels
            
  •       Automated decision-making including profiling:
    Solely automated individual decision-making - including profiling - with legal or similarly significant effects is restricted, although this restriction can be lifted in certain circumstances. We can only carry out solely automated decision-making with legal or similarly significant effects if the decision is:
  • necessary for entering into or performance of a contract between an organisation and the individual;
  • authorised by law (for example, for the purposes of fraud or tax evasion); or
  • based on the individual’s explicit consent.

If we’re using special category personal data we can only carry out processing described in Article 22(1) if:

  • you have the individual’s explicit consent; or
  • the processing is necessary for reasons of substantial public interest.

Use of Artificial Intelligence (AI):
We may use AI-powered tools to support service delivery – for example to identify patterns in wellbeing data, assist in scheduling, or suggest service improvements. These tools support but do not replace human judgement. Any AI-assisted outputs are reviewed by staff before decisions are made. We carry out Data Protection Impact Assessments (DPIAs) prior to introducing AI systems that use personal or sensitive data. You will be informed where AI is used, and you have the right to request human-only review of decisions.

  • E-mail newsletters when you have agreed for us to do this; you can withdraw your consent at any time.
  • Filming and photography to promote our services to others.

The legal basis for the processing of your information is in order to deliver a statutory function under legislation. Specifically in accordance with:

  • Social Services & Wellbeing Act 2014
  • Mental Health Act 1983 as amended
  • Local Government Act 2000

The basis for processing special category (sensitive) personal data about you is substantial public interest, on the basis of the legislation referred to above.

Where AI tools are used, our legal bases include your consent (where required), or our substantial public interest duty under the legislation above. AI systems are tested for fairness and bias, and we ensure transparency and accountability in their use.

If you do not give us the information we need when we ask for it, this may result in less effective planning and delivery of services to help meet your needs.

2. What type of information do we use?

We may collect the following types of personal data about you, depending on your circumstances:

  • Name
  • Address
  • Date of birth
  • Gender
  • Unique reference number
  • NHS number
  • Telephone number
  • Email address
  • Bank/payment details
  • Your family composition
  • Your social circumstances
  • Your financial circumstances
  • Employment and education details
  • Your housing needs
  • Images/photographs
  • Information about your health
  • Name of housing association/local authority/university
  • Your racial or ethnic origin
  • Religious or philosophical beliefs
  • Information about your sex life or sexual orientation

3. Do we use information received from other sources?

We collect information directly from you but also receive information from the following sources:

  • Your family and care support network
  • National Health Services (NHS)
  • Carmarthenshire County Council departments (e.g. housing services, council tax)
  • Other local authorities
  • Housing associations
  • Regional police forces (e.g. Dyfed Powys Police, South Wales Police)
  • National Probation Service
  • GP practices
  • Department for Work and Pensions
  • Universities

The following types of personal data may be obtained, depending on your circumstances:

  • Name
  • Address
  • Date of birth
  • Gender
  • Unique reference number
  • NHS number
  • GP’s details
  • Telephone number
  • Email address
  • Your family composition
  • Your social circumstances
  • Your financial circumstances
  • Employment and education details
  • Your housing needs
  • Images/photographs
  • Information about your health
  • Your racial or ethnic origin
  • Religious or philosophical beliefs
  • Information about your sex life or sexual orientation

Where data from other sources is used in AI-supported analysis or tools, it is subject to the same protections and oversight described in this notice.

4. Transferring your information abroad

Your information will not be transferred outside the EEA

5. Who has access to your information?

When we share your personal data, we only do so when we need to so and we provide the minimum necessary in each case.  The organisations that we share information with are:

  • National Health Service (NHS)
  • Carmarthenshire County Council departments (e.g. housing services, council tax)
  • Other local authorities
  • Regional police forces (e.g. Dyfed Powys Police, South Wales Police)
  • National Probation Service
  • Other local education authorities and schools
  • GP practices
  • Department for Work and Pensions
  • Contracted service providers

There are also other specific situations where we may be required to disclose information about you, such as:

  • Where the company is required to provide the information by law
  • Where disclosing the information is required to prevent or detect a crime
  • Where disclosure is in vital or legitimate interests

Population-level analytics and sharing with health partners: In future, we may analyse information in aggregate form to identify trends and improve services at population level. Wherever possible this analysis uses anonymised or pseudonymised data, so that individuals cannot be directly identified. When we share such information with health partners or other public bodies, this is done under formal data-sharing agreements, for specific purposes such as planning, prevention, or evaluating services. AI or advanced analytics may be used in this context to identify patterns or emerging risks; these tools inform service planning but do not make individual care decisions.

Individual pathway analytics (future use): In future, systems may be developed that use information to map an individual’s pathway across health and social care services, with the aim of improving coordination and outcomes. Where this occurs, we will ensure:

  • It is supported by a clear legal basis
  • You are informed when your data is used in this way
  • Any predictions or recommendations are reviewed by professionals before decisions are made, and
  • You retain the right to request explanation, challenge, or human-only decision-making.

6. How long we will keep your information?

Your information will be kept in accordance with the company and our Shareholders Retention Guidelines.

  • Financial information; 7 years from last date of contact
  • Personal information on UMO; kept for a minimum of 1 year and a maximum of 2 years after the service has ceased, in line with the TEC Service Association (TSA) standards. 
  • Telephone voice recordings; 1 year
  • Personal data collected on behalf of corporate customers, as agreed contractual arrangements.

7. Your Data Protection rights

You have the right to:

  • Obtain access to the personal data that Delta Wellbeing Ltd is processing about you
  • Have any inaccurate or incomplete information rectified (corrected)
  • Withdraw your consent to processing, where this is the only basis for the processing
  • Make a complaint to the Information Commissioner’s Office (ICO), the independent body in the UK which protects information rights
  • In some circumstances, you may have the right to:
  • Object to the processing of your personal information
  • The erasure of your personal data
  • Restrict the processing of your personal information
  • Data portability

8. Contact details

For more information regarding this privacy notice and your rights, please contact:

Data Protection Officer
Delta Wellbeing
Unit 2, Heol Aur,
Dafen,
Llanelli,
Carmarthenshire
SA14 8QN

Email: Info@deltawellbeing.org.uk

Tel: 0300 333 2222

Contact details for the Information Commissioner’s Office along with further guidance on Data Protection legislation can be found on the ICO website.

You may find this ICO guide helpful Getting copies of your information (SAR) | ICO