Privacy Policy for the GamCare East Midlands and Lincoln Police Out of Court Resolution Pathway Partnership

This means not sharing information that you tell us about yourself with anyone else. Whatever you tell us will remain confidential within GamCare unless you request otherwise in writing. You can feel safe talking to us, knowing that we will not pass on your personal information to others without letting you know.

However, occasions may arise when we are required to share your information with others. For example, if we are worried about your safety, we may need to get you help in the following situations:

• If you ask us to
• If we believe your life, or someone else’s life, is in danger
• If you are being hurt by someone in a position of trust, like a partner, carer, or friend.
• If you tell us that you are seriously harming another person/people.

This policy applies to all personal data, special category data, and criminal offence data relating to individuals referred to GamCare by the Lincoln Police under its Out of Court Resolution initiative.

We process the following types of data:

Personal Data

• Name and surname
• Date of birth
• Address
• Email address
• Phone Number

Special category data

Data revealing:

• Racial or ethnic origin
• Religion
• Health
• Sexual orientation

Criminal offence data

Data provided by the Lincoln Police Out of Court Resolution initiative revealing:

• Offences committed
• Convictions

We process your data on the following lawful bases:

• Consent: Article 6(1)A UK GDPR
• Public Interest: Article 6(1)E UK GDPR
• Explicit Consent: Article 9(2)A UK GDPR
• Substantial Public Interest: Article 9(2)G UK GDPR
• Under Official Authority: Article 10 UK GDPR
• Schedule 1, DPA 2018 – These may include the:
  • Prevention or detection of unlawful acts (Sch.1, para.10)
  • Safeguarding of children and vulnerable individuals (Sch.1, para.18)

Where processing is based on consent and explicit consent, this will be freely given, specific, informed, and withdrawable at any time.

We process personal data, special category data, and criminal offence data to:

• Provide services addressing the gambling harms of individuals referred to GamCare East Midlands by the Lincoln Police as part of their Out of Court Resolution initiative.
• Undertake initial assessments on referred individuals from the Out of Court Resolution initiative and ask them to provide more comprehensive details so we can tailor treatment plans that make sure they are getting the right level of support.

We may share data only where lawful and necessary, for example with:

• Partner organisations where required by law, contract, or safeguarding purposes.

We will never sell your data to third parties.

To protect sensitive data, we apply additional safeguards, including:

• Limiting access strictly to authorised staff
• Technical measures: encryption, secure storage, access logs
• Organisational measures: confidentiality agreements, role-based access
• Regular audits and monitoring of processing activities
• Maintaining an Appropriate Policy Document (APD) as required by the DPA 2018

Our treatment and online support records are stored for at least seven years from the date of your last treatment or follow-up from GamCare. If there is no further contact after this period, we will securely destroy all paper records, delete or anonymise electronic records to remove personal, identifiable information.

Under the UK GDPR and DPA 2018, you have rights over your data, including:

• Right of access
• Right to rectification
• Right to erasure
• Right to withdraw consent
• Right to restriction
• Right to object
• Rights in relation to automated decision making and profiling
• Right to lodge a complaint

We demonstrate compliance through:

• Maintaining Records of Processing Activities (RoPA)
• Conducting Data Protection Impact Assessments (DPIAs) for high-risk processing
• Reviewing this policy and our Appropriate Policy Document (APD) annually

If you have questions about this policy or how we process your personal data or a complaint, please contact our Data Protection Officer via email at:

[email protected]

Or you may write to us at:

Data Protection,
GamCare,
Unit 751-760,
Salisbury House,
29 Finsbury Circus,
London,
EC2M 5SQ

If you wish to register a complaint with the Information Commissioner’s Office (ICO), please visit https://ico.org.uk/make-a-complaint/

This policy will be reviewed annually or sooner if required by law, guidance, or changes in processing activities.