Privacy Notice



1. Who We Are


We are Warwickshire Independent Advocacy alliance – trading as:

Independent Advocacy

Avenue R

Stoneleigh Park



The name of your representative is Simon Cottingham

The name of your data protection officer is Simon Cottingham


Contact details are shown below in point7.


2. Who is covered by this Privacy Notice?


This privacy notice covers current clients and clients whose cases have been closed.


3. The Lawful Basis for Holding and Processing your Data


We run a number of different services within Independent Advocacy. Some require us to gain specific consent from you but others do not. In order to be open and transparent about why we are holding your data we have set out below the services we provide and the legal basis for keeping your data for each service. We have also set out other reasons we might keep your data and the legal basis for these activities.

Services where the legal basis is Public Interest/Official Authority

·         Independent Mental Health Advocacy (IMHA)

·         Independent Mental Capacity Advocacy (IMCA)

·         Deprivation of Liberty (DOLS)

·         Care Act Advocacy

·         NHS Complaints



All of these services are commissioned by Local Authorities or Health services to fulfil their Public Duties which are set out in law covered by the following acts of Parliament:

·         Care Act 2014

·         Mental Capacity Act 2005

·         Mental Health Act 2007

·         Department of Work and Pensions guidance


Services where the legal basis is Legal Obligation

·         Appointee Service –

·         An appointment to act as an Appointee is made by the Secretary of State for the DWP under regulation 33 of the Claims and Payments Regulations 1987 or for Universal Credit, Personal Independence Payments and new-style Job Seekers Allowance and Employment Support Allowance, regulation 57 of The UC, PIP, JSA and ESA Claims and Payments Regulations 2013”.


Services where the legal basis is Consent

·         Non-Statutory Advocacy work

·         Community Support work

·         Money Management

·         Pre/post appointee


All information on you for all the services above is held by a third party case management service called CharityLog. We ensure that all our suppliers conform to GDPR legislation and we do this by asking them to confirm that they do so in writing to us. CharityLog is a very secure system that only our staff can access.

We will also use Consent as the legal basis in the following circumstances (not an exhaustive list):

·         When we want to get your permission to use your details in Promotion and Publicity for us

·         When we want to know more about you for research purposes

·         When we want to get feedback from you about our services or from your family/carers

We will not use your data without consent and in relation to the above circumstances we will not use data from anyone who cannot give consent (e.g. Mental Capacity)

We will use Vital Interests as the legal basis in the following circumstances:

·         Making a safeguarding referral (Child or Adult) (not an exhaustive list)

·         Calling the relevant authorities in relation to threats against our Staff, carers or other members of the public

·         In the event of your death

We do collect data in relation to you as a person that is not specific to your case e.g. Gender, Ethnicity, Disability etc. This data helps us to understand our client group and also where we may have gaps in our service, where we need to look at communities who are not accessing our services etc. For these reasons we process data for statistical purposes using the Special Category Basis. This data is reported anonymously using CharityLog reports to collate the data into demographic reports.


4. The Retention Periods for Personal Data


Unless we explain otherwise to you, we will hold your personal information based on the following criteria:

·         For as long as we have reasonable need, such as managing our relationship to you and managing our services.

·         For a period to comply with legal and regulatory requirements or guidance.

·         If your case has been closed we will keep your data only for a period to comply with legal and regulatory requirements and guidance.



5. Your Rights


Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not.

  • 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 move, copy or transfer your personal information (“data portability”)
  • Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you

You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: You can contact us using the details in point 7, below.


6. Changes to the information


We regularly review and, where necessary, update our privacy information.


7. How to Contact Us


You can contact us by writing to:


Independent Advocacy

Avenue R

Stoneleigh Park






Email us at




Telephone 02476697443