How we use your information
This privacy notice tells you what to expect when Michael Russell and Company collects personal information and should be referred to alongside other important policies including the Data Protection Policy, Personal Information Audit and Complaints Procedure, all of which are available upon request to the address provided.
This privacy notice applies to information we collect about:
- Visitors to our website
- People who make a complaint to us in regard to our service
- People who use our services, ie. Recipients of Direct Payments or representatives of Recipients of Direct Payments
- Personal Assistants whom we pay either directly or through the Recipients of Direct Payments/their representatives
- Current and former employees
Visitors to our website
When someone visits http://michaelrussell.org.uk we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
People who make a complaint to us
Complaints are processed in line with our Complaints Procedure. When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
People who use our services
Michael Russell and Company offers a range of payroll services to recipients of Direct Payments. For this purpose, we have to hold the details of the people who have requested the service in order to provide it. We only use these details to provide the service that has been requested. Full details of the information we hold on Service Users and/or their representatives, including how we collect it, the purpose for collection, consent and retention can all be found in Michael Russell and Company’s Information Audit which is updated every 12 months.
Once a Service User leaves our services, their details will be securely transferred to a new provider if they are moving, or they will be kept on file with us for a period of time compliant with both HMRC and the Pensions Regulator which is currently four and six years respectively. After this time the details will be destroyed and disposed of securely.
As part of core business it is necessary to share information about Service Users with the Local Authority for whom we work. We have an information sharing agreement in place to govern the sharing of information and Service Users are asked to provide their consent to their information being shared in this way through the Information Sharing Consent Form included in the Information Pack.
Personal Assistants employed by Service Users
Michael Russell and Company run the payroll for Personal Assistants employed by Service Users/their representatives. For this purpose we have to hold the details of Personal Assistants and this information is provided by Service Users upon employment. We only use these details to provide the service that has been requested. Full details of the information we hold on Personal Assistants including how we collect it, the purpose for collection, consent and retention can all be found in Michael Russell and Company’s Information Audit which is updated every 12 months.
Once a Personal Assistant has left the employment of a Service User, they will be issued with a P45 and their details removed from the payroll software. New Starter forms used to gather their information will remain on file for a maximum of six years, as outlined above, and will then be destroyed and disposed of securely.
Current and former employees
When individuals apply to work at Michael Russell and Company, we will only use the information they supply to use to process their application. Where we want to disclose information to a third party, for example to obtain a DBS check, we will not do so without informing them beforehand unless the disclosure is required by law.
Personal information about unsuccessful candidates will be held for 12 months after the recruitment exercise has been completed, it will then be destroyed or deleted.
Once a person has taken up employment with Michael Russell and Company, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with Michael Russell and Company has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it.
Complaints or queries
Michael Russell and Company tries to meet the highest standards when collecting and using personal information. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.
Access to personal information
If you wish to find out what personal information we hold about you, you can make a ‘subject access request’ under the Data Protection Act 1998. If we do hold information about you we will:
- give you a description of it;
- tell you why we are holding it;
- tell you who it could be disclosed to; and
- let you have a copy of the information in an intelligible form.
To make a request to Michael Russell and Company for any personal information we may hold you need to put the request in writing to the address provided below. We will respond to your request within 72 hours.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting us on the address below.
Disclosure of personal information
In many circumstances we will not disclose personal data without consent. However, if we are made aware of a child protection issue or have grave concerns over the health and well-being of one of our clients or their families, or concerns of criminal undertakings we are obliged to share this information with the relevant agency.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 14th November 2017.
How to contact us
Michael Russell and Company
PO Box 449