Privacy Policy

Privacy Policy for Personal Information Belonging to Adopters and Adoption Applicants

This document is an addendum to the Polaris Community Privacy Notice detailed on our website and provides further details on the processing of data within our adoption services

1. The purpose of this document

For data protection purposes ‘Processing’ means the collection, recording, organising, structuring or storing, adapting or altering, retrieving, consulting or use, disclosing by transmission, disseminating or otherwise making available, aligning or combining or restricting, erasing or destroying personal data.

We are a ‘Data Controller’. This means that we are responsible for deciding the purposes for which we hold and use personal information about you and this privacy policy will describe how we collect and use your personal information during the relationship you have with us.

2. The personal data we may process about you.

Personal information is any information about an individual from which that person can be directly or indirectly identified. It does not include anonymised data, i.e. where all identifying particulars have been removed.

Personal and special category information that we may collect, use, store and share about you is highlighted below but is not exhaustive:

  • Personal and contact details such as title; full name; address; date of birth; age; personality; sex; nationality; national insurance number; pen picture; telephone and mobile numbers; email address; sexual orientation; place of birth; passport (including passport number); birth certificate (including birth certificate number); driving licence (including driving licence number); next of kin and emergency contact details.
    • Health information such as details of health (supported by a medical report); disability information; doctor’s details; medical advisor’s report.
    • Relationship information such as marital status; current relationship; details of current and any previous marriage, civil partnership or similar relationship; type of marriage; former partners and previous relationships.
    • Information about family and household members such as details of any other adult members of the household (including their relationship to you); information about birth children; details of children in the family, whether or not members of the household, and any other children in the household (including their relationship to you); information from school, nursery and health visitor checks.
    • Race, ethnicity and culture details such as ethnicity; primary language; religion; religious persuasion, racial origin, cultural and linguistic background; capacity to care for a child from any particular religious persuasion, racial origin or cultural or linguistic background.
  • Information about accommodation and local area such as details of accommodation (including landlord details); local authority/trust check.
    • Information about lifestyle and social circumstances such as family background and childhood; adult life information; standard of living; leisure activities; personal and social interests.
    • Employment information such as past and present employment or occupation; previous employment history involving children; voluntary work.
    • Information about previous experience and relevant skills such as previous experience (if any) of caring for your own and other children; skills, competence and potential relevant to your capacity to care effectively for a child placed with you.
    • Information about previous applications such as the outcome of any request or application to foster or adopt children, including particulars of any previous approval or refusal of approval; the outcome of any request or application for registration as an early years provider or later years provider, including particulars of any previous approval or refusal of approval.
    • Information within reference such as referee’s details; referee’s relationship to you.
    • Information about criminal offences, convictions, spent convictions, cautions or warnings such as an enhanced criminal record certificate (which includes suitability information relating to children); court proceedings information.
    • Financial information such as income and expenditure information; bank account details; adoption allowances; expenses.
    • Approval information such as terms of approval; date of approval; variation of terms of approval; review of approval; termination of approval (and the circumstances surrounding this); date of termination of approval.
    • Details of training such as training records; training, support and development information; training history.
    • Adoption placement information such as details of adoption introductions or placement; preferences for type of placement; procedure in connection with the placement of children; matters to be included in any placement plan.
    • Information in relation to legal liabilities such as legal liabilities arising by reason of a placement; insurance policy documents/evidence; details in relation to a claim.
    • Details of incidents such as complaints and representations; outbreak at your home of an infectious disease; serious incident relating to a child placed with you; any serious complaint about you (and its outcome); instigation and outcome of any child protection enquiry involving a child placed with you; allegation made against you (and its outcome); concern or suspicion against you (and its outcome).
    • Information within feedback, reports, records and associated documents such as adopter panel feedback; supervising social worker feedback from panel; panel minutes; supervision feedback; reviews; risk assessments; monitoring reports (accident, injuries, illness, complaints, etc.); misconduct reports (allegation, investigation, etc.); case records.
  • Other information such as social media and internet checks; other checks; bank statement; utility bill; your relationship with the other adopter (if you are approved as a adopter); information obtained in connection with the assessment; report presented to adoption panel (and any associated documents); recommendation of adoption panel; outcome of application and the circumstances surrounding this; performance information; enquiry source (how you contacted us and heard about us).

We may collect, hold and use additional personal information in the course of adoption-related activities during your relationship with us.

Applicants – we obtain and hold applicant data where we are required by law as part of the adoption recruitment and assessment process for the provision of adoption services. Personal data relating to unsuccessful applicants will be retained in accordance to law and in line with our Retention of Records Policy.

3. How your personal information is collected

We may collect personal information about you through the application and recruitment process from the following sources:

  • By directly interacting with you, from an application form, attendance at events, from feedback forms etc
    • If relevant, a recruitment agency, from which we would collect personal and contact details together with any relevant information which the recruitment agency may have acquired about you as part of the referral to us.
    • Information from the checks and enquiries which we undertake as part of the recruitment process. There are several background checks. Examples include checks with your family members and individuals associated with your household, current and previous partners, current and former employers, voluntary agency, landlord, local authority/trust and child’s school/nursery where applicable. Depending on the circumstances, there may be other checks and enquiries.
    • Information from your doctor, hospital and/or other relevant health professional. This includes obtaining a medical report about your health.
    • Any fostering provider to whom you have previously applied, or fostered for, and/or any individual or authority in connection with any previous private fostering arrangement which you have been involved with.
    • Any adoption agency to whom you have previously applied or adopted for, and/or any individual or authority in connection with any previous private adoption arrangement which you have been involved with.
    • Any local authority/trust, other public body or voluntary agency who may hold information pertinent to your prior involvement in child minding or day/play care provision for children, work in any children’s residential care setting, or work or other activities in connection with services to vulnerable adults or children.
    • Information from the other applicant at the time (if you were making a joint application).
  • Disclosure and Barring Service (DBS)/Disclosure Scotland/Access NI in respect of criminal convictions with or without the use of an intermediary external government-accredited agency.
    • Your named referees, from whom we collect information about you which may be relevant for us to consider your application.
  • Information from other parties as part of the recruitment process, such as an independent assessor and regulators.
    • We may also obtain information about you from publicly accessible sources such as through internet and social media checks.

Certain enquiries and checks may need to be renewed on a regular basis during the course of your relationship with us as an approved adopter.

Once you have been approved as a adopter by us, we may also collect personal information about you from the following sources:

  • By directly interacting with you
    • Placing local authorities/trusts for tasks such as reviews, case records and obtaining feedback on the adoption placements.
    • Independent adoption panel for purposes such as a review of your continued approval as an adopter.
    • Your family members and individuals associated with your household for tasks such as obtaining their comments for your annual reviews.
    • Information from the other adopter (if you are approved as a joint adopter).
    • Subcontractors, partnering organisations or other entities which assist us to provide or improve our services.

4. Situations in which we will use your personal information

We need all the categories of information listed above for the following reasons:

  • To enable us to comply with our legal obligations.
    • To allow us to perform our contract and relationship with you.
    • Where we, or a third party, may have a legitimate interest in processing your information. A legitimate interest is where the processing of your personal information is necessary to pursue our legal or commercial interests in a way which is reasonably expected as part of running our business, but which is not detrimental to you and would have a minimal impact on your privacy

The situations in which we will process your personal information may include:

  • Making a decision about your suitability to be an adopter.
    • Determining the terms on which you carry out a role with us.
  • Checking you are legally entitled to reside in the United Kingdom.
    • Reviewing your continued suitability as an adopter.
    • Ascertaining your ongoing fitness and capacity to carry out your role.
    • Assessing your profile as a possible or actual adopter for a child awaiting adoption and matching you with a child in order to form a suitable placement for the child.
    • Administering the placement with a child, including maintaining case records about the placement and making arrangements for the termination of the placement.
  • Providing any benefits or payments to you
    • Administering the contract we have entered into with you.
    • Updating, consolidating and improving the accuracy of our records.
    • Business management and planning, including accounting and auditing.
    • Conducting supervisions and annual reviews, managing performance and determining performance requirements.
    • Making decisions about your continued engagement.
    • Making arrangements for the termination of our relationship with you.
    • Complying with safeguarding obligations.
    • Recording and assessing your training, support and development activities and needs.
    • Dealing with legal claims or disputes involving you, or a child in placement, or others such as our staff members.
    • Managing any respite arrangements.
    • Complying with health and safety obligations.
    • Communicating with you.
    • Checking at regular periods that you have relevant insurance policy documents/evidence which acknowledges your status as an adopter and ensures that appropriate cover is in place.
      • To prevent fraudulent and criminal activity (which includes actual and suspected incidents).
    • To monitor your use of our information, software and communication systems to ensure compliance with our IT policies.
    • To analyse and model data to review and better understand adoption approval and placement matching.
    • Complying with legal or regulatory requirements.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

5. If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you and be prevented from complying with our legal obligations (such as safeguarding and ensuring the welfare of potentially vulnerable children).

6. 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 we need to use your personal data for an unrelated purpose, we will notify you and 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

7. How we use particularly sensitive personal information

We will use your particularly sensitive personal information in order to comply with our legal and regulatory obligations. We also require your sensitive personal information to assess your fitness and suitability as an adopter as well as your ability to meet the needs of a child in placement with you or to potentially be placed with you.

In particular, the collection of such sensitive personal information about you is necessary for the following reasons:

  • To adhere to our obligations under social protection law.
    • To establish, exercise or defend any legal claims. §         To          provide social care services.

8. Information about criminal convictions

We will collect information about your criminal convictions history during the recruitment process. Following your approval as an adopter with us, this check will be repeated periodically during your relationship with us.

We are legally required to carry out criminal record checks for those carrying out this role. This entails an enhanced criminal record certificate (which includes suitability information relating to children). This requirement enables us to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.

As part of the criminal record check which we undertake, DBS/Disclosure Scotland/Access NI will issue you with a certificate. We will be informed when a ‘clear’ certificate has been issued or when it contains information of offences/cautions. In the instance when a disclosure contains information, you will be required to produce a copy of your certificate to us for examination. We may take a copy the certificate for the purpose of conducting a risk assessment of the offences/cautions.

We have in place appropriate safeguards to protect your privacy when processing such data.

9. Automated decision-making

Automated decision-making occurs when an electronic system uses your information to make a decision without human Fintervention.

We do not envisage that any decisions will be taken about you using automated means only. However, we will notify you in writing if this position changes.

10. Data sharing

We will share your personal information with third parties where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so. We have outlined below various third parties with whom we may share your personal information:

  • Various third parties which we need to liaise with during the recruitment process:
  • Examples include, but is not exhaustive, include your doctor, medical advisor and/or other health professional, local authority/trust, independent adoption panel, independent assessor, named referees as well as any other individuals or organisations with which we need to carry out checks during the recruitment process (such as your associated family members and employer).
  • To perform these enquiries and checks, the relevant third parties would be informed that you have made an application to adopt with us and they will receive basic details about you in order for us to undertake the requisite checks and obtain the relevant information.
  • It is possible that such third parties may need to be contacted during the course of your relationship with us as an approved adopter, in order to renew those enquiries and checks.
    • DBS/Disclosure Scotland/Access NI for various reasons including:
  • To obtain the outcome of the check in respect of criminal convictions (both during the recruitment process and at regular intervals during your relationship with us as an approved adopter) with or without the use of an intermediary external governmentaccredited agency.
  • To make a referral to DBS/Disclosure Scotland/Access NI due to concerns which we may have about you.
    • The other applicant/adopter (if you made an application, or are approved, as an adopter).
    • Local authorities/trusts which are seeking to make an adoption placement for a child or in circumstances where an adoption placement has been made with you. We have detailed below some of the reasons for sharing information about you with such placing authorities:
  • Assessing your profile as a possible or adopter for a child awaiting an adoption placement and matching you with a child in order to form a suitable placement for the child.
  • Administering the placement with an adopted child, including maintaining case records about the placement, dealing with any complaints or allegations about you for the protection of children in placement, and making arrangements for the termination of the placement.
    • An independent panel for purposes such as a review of your ongoing approval as an adopter.
      • An independent reviewing officer for tasks such as completing your review as an adopter.
    • An independent investigator or a complaint review panel, depending on the relevant stage of the complaints procedure if a complaint is made by you.
    • A medical advisor and/or other health professional, for example, if there is an outbreak at your home of an infectious disease or to provide updated medical checks at regular intervals and as required.
    • A third party provider of support services in order to register you with them as an approved adopter and enable you to gain access to independent support.
    • An Adopters for Adoption Representative to maintain contact with you about various events and features including news, meetings, support and updates regarding adoption with us.
    • Subcontractors, partnering organisations or other entities which assist us to provide or improve our services.
    • Your employer, for example, if a reference has been requested.
    • Training providers, for example, if you are attending, or considering attending, a course.
    • His Majesty’s Revenue and Customs (HMRC) for tax purposes.
    • The Independent Review Mechanism (or equivalent) for tasks such as withdrawing or altering the terms of your approval as an adopter.
    • Other adoption agencies should you transfer, or consider transferring, to another adoption service provider.
    • Third parties for arranging external events such as functions and conferences. This may include booking hotel rooms if overnight stay is involved.
    • Other entities in our group for purposes such as service delivery, as part of our regular reporting activities on company performance, for training purposes, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.
    • Our legal and other professional advisors, including our auditors and insurers.
    • Application developers for improving communications and services.
    • Partnering organisations who can help us develop our services such as improving adopter retention and placement matching through the analysis and modelling of statistics/data.
    • Other organisations who provide services to us such as back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions.
  • Other third parties, for example, in the context of the possible sale or restructuring of the business.
    • Public authorities or other agencies who may be legitimately discharging statutory functions in relation to the care and protection of children.
    • Regulators, government bodies, statutory agencies, police, courts or to otherwise comply with legal or regulatory obligations.
    • From time to time the agency may share your data with third partner agencies such as the Department for Education. This would be to consider the education attainment of the children you are adopt.

11. Arrangements with third party service providers and other entities in the group

All our third party service providers and other entities in the group 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. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may on occasion anonymise your personal data without your knowledge and share this with trusted third parties who help us develop our services such as improving adopter retention and placement matching through the analysis and modelling of statistics/data. Anonymisation of your data prevents you from being personally identified by the third parties.

12. 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. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place 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.

13. Communications preferences

We may use your home address, telephone numbers, email address and social media or digital channels to communicate with you according to your preferences. You can amend your preferences in respect of such communications, at any time, by contacting us using the details below or by following the instructions in each communication from us.

14. Data retention

Whenever we collect or process your personal data, we will only keep it for as long as necessary. Personal information is retained in accordance with applicable law and regulations and retention periods vary depending on the nature and context of the personal information. We hold your personal information based on the following criteria:

  • For as long as we have reasonable business needs, such as managing our relationship with you and only as long as necessary to fulfil the purposes we collected it for
  • For as long as someone could bring a claim against us
  • Retention periods in line with legal and regulatory requirements or guidance

Retention examples include:

  • Case records for approved adopters who have not had any children placed, information is kept on file for at least 15 years from approval being terminated
  • Case records of prospective adopters who are not approved or who have withdrawn their application prior to approval is kept on file for a minimum of 5 years following date of refusal/withdrawal
  • Case Records where a child application to adopt is not approved or is withdrawn by the approved adopter is kept on file for a minimum of 10 years
  • Adoption Case Records where an Adoption Order has been made will be kept for 100 years

At the end of the retention periods data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning

15. Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. As a result, it is vital that we are informed of any significant changes in the membership of your household, in your circumstances and events that may be relevant to your continued capacity or suitability to adopt.

We have listed below some examples of changes which we would require you to provide full details of, to us, by submitting immediate written and prior notice to us:

  • Any intended change of address.
    • Any change or intended change in the membership of your household including any new relationships which result in a ‘regular’ visitor to the household not included in any previous assessment.
    • Any significant change in your personal circumstances, such as separation/divorce, marriage/remarriage, and death of partner/close family member/significant other person.
  • Any event affecting, or potentially affecting, your ability to care for children placed and, if necessary, to us seeking further information from your doctor and/or other health professionals.
    • Any event which might result, or results, in you being interviewed, arrested or charged in connection with a criminal activity.
    • Receipt of any endorsement or penalty points to your driving licence.
    • Any application which you make in connection with fostering or special guardianship for another fostering agency, adopting a child or children, becoming a registered child-minder or day care provider, or acting as a ‘private foster carer’ for any child not placed by us.
    • Any changes to your employment or any decision to seek employment outside the home, either of which might affect your availability to care for fostered children.

Please keep us informed if your personal information changes during your relationship with us. This includes changes or intended changes as mentioned in the above examples as well as any other personal information which we hold about you.

16. Consent

While the majority of personal information we collect from you may be mandatory, there is some information that you can choose whether or not to provide to us. Whenever we seek to collect information from you we will make it clear whether you must provide this information (and if so, what the possible consequences are of not complying) or whether you have a choice. Where you have provided us with consent to use your data, you may withdraw this consent at any time.

17. Your rights in connection with personal information

We have detailed below a list of the rights that all individuals have under data protection laws. They do not apply in all circumstances and we will explain in writing whether or not they do, at the time you wish to exercise any of these rights.

  • The right to be informed about the processing of your personal information.
    • The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed.
  • The right to object to processing of your personal information.
    • The right to restrict processing of your personal information.
    • The right to have your personal information erased (the “right to be forgotten”).
    • The right to request access to your personal information and to obtain information about how we process it.
    • The right to request the transfer of your personal information to another party (“data portability”).

If you wish to exercise any of these rights, please contact our Data Protection Officer (please see below).

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the supervisory authority for data protection issues in the United Kingdom (www.ico.org.uk).

18. Changes to this privacy policy

We may need to update this Privacy Policy periodically and reserve the right to do so without giving notice. We recommend that you revisit this information via our website from time to time

19. Data Protection Officer

We have appointed a Data Protection Officer to oversee compliance with this privacy policy. If you have any questions about the Polaris Privacy Notice on our website, this privacy policy or how we handle your personal information, please contact Adopters for Adoption directly or the Data Protection Officer by email to DPO@polariscommunity.co.uk or write to the following address:

Data Protection Officer Polaris Community

Malvern View Saxon Business Park Hanbury Road

Stoke Prior Bromsgrove B60 4AD