Adult SEND service: Smartphone application (Brain in Hand) privacy notice

The Council’s Integrated Commissioning team is part of the Families Directorate. The Care Act 2004 and the Children and Families Act 2014 both place a legal duty of care on the Council to provide support for residents with Special educational needs and disability (SEND) needs and for those residents who require mental health support.​

In furtherance of this duty, the Council will run a pilot project for 2 years with a digital self-management support system. The system is an application that users can download onto their smart devices in order to assist with day-to-day living. The application is provided by Brain in Hand Limited (BIH Ltd.).

BIH Ltd. will also help to produce a full evaluation of the project when it nears the end of its duration. This will be used to build a business case for continuing to use Brain in Hand in our services or expanding to support more people.​

Contact information

If you have questions regarding this service or our privacy practices, you can contact us by e-mail or in writing. Email Sabila Hafejee (Commissioning Supplier and Relationship Manager) at Sabila.Hafejee@walthamforest.gov.uk.

You can also contact us by post. Please write to:

Waltham Forest Council
Waltham Forest Town Hall
Forest Road
Walthamstow E17 4JF

Please note that face-to-face meetings are by appointment only and can be arranged with the service by email.

The Families Directorate already holds the personal data listed below as a referrer (a named professional such as a social worker) will have access to this information in order to support the Council in fulfilling its statutory duties.

Personal data for service users is already held by the Council’s Mosaic system such as:

Name, date of birth, address and contact details.

The additional data that will be collected about participants in the pilot is:

• Details of the SEND needs
• Details about the university and/or workplace
• Details concerning a description of their needs, that is, any health conditions, disability information, goals and aims in achieving day-to-day independence.

Please see below how BiH Ltd. uses this additional information when a pilot participant signs up to use the BiH application:

• Identity Information: pilot participants will provide this themselves when enquiring about or signing up for the service. It may also be provided by someone else who submits enquires on their behalf or refers them to BiH.
• Activity Information: this will be created by activity on the account, the website and mobile applications, such as when BiH is used and how often.
• Private Information: pilot participants enter account content into the website or mobile applications or supporting resources
• Sensitive Information: will come from pilot participants through communication with BiH representatives, via Specialist Support sessions and records, or Response Service interactions.

Please view the BiH Ltd. privacy notice or more detailed information about how your data is used.

The pilot will consist of 20 service users. The Adults Care and Quality Standards service has engaged BiH in order to trial a digital self-management system that has the potential to improve the independent living and quality of life for our service users. 

BiH is a cloud-based application or Software as a Service system (SaaS) that allows users to connect and access the app over the internet. LBWF is buying a licence so that the software can be downloaded and accessed by Residents' using their own devices.

For people that struggle with daily tasks, digitally delivered support can help keep them connected and provide access to support from within their own homes. The use of the application would also introduce efficiencies into the service and increase resources within the social care teams.

If the pilot is successful, the application will be rolled out more broadly.

The lawful basis for processing your data is under the following:

GDPR Article 6.1 (e): Public task - the processing is necessary to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.

This is because we process your data in order to fulfil our duties under the Care Act 2014; Part 1, Section 20 and under the Children and Families Act 2014.

GDPR Article 6.1 (a): Consent

Your data is also processed when you consent to this when you use the BiH application.

For more details on the Lawful Basis see the ICO guidance.

Your information will be shared with Brain in Hand Limited, which is a limited company registered in England and Wales with a registered office at Hampton House, 23 Longbrook Street, Exeter, EX4 6AB,

Contact information:

If you have any queries about how BiH Ltd. uses your data, you can email: dpo@braininhand.co.uk.

Please view the BiH Ltd. privacy notice for more detailed information about how your data is used.

Brain in Hand Limited:

Any personal data that we collect from you (whether submitted directly or collected through your use of our system) will be reviewed on a regular basis to ensure that we only continue to store and process it under lawful grounds and for an appropriate time period.

Identity Information will be retained for two years after you cease using our services.  Your name, contact details and dates of joining and ceasing will be kept for 7 years for external audit and quality purposes.

Activity Information provided through your use of our system will be held for two years after you cease to use the services and then may be held indefinitely in an aggregated and anonymised format to assist us in compiling usage information which helps to inform system development.

Private Information will be stored for up to 2 years after you terminate your use of our services to reactivate the licence if needed, or to respond to any complaints/queries that may arise.

Sensitive Information will be stored for up to 2 years after you terminate your use of our services in order to respond to any complaints/queries that may arise; timesheets and safeguarding data will be kept for 7 years for external audit purposes.

Our Data Protection Officer

Our Data Protection Officer is Mark Hynes, you contact him by email at data.protectionofficer@walthamforest.gov.uk

Protecting your information

Please see the relevant section of the Corporate Privacy Notice.

Your information choice and rights

Please see the relevant section of the Corporate Privacy Notice.

Complaints and contact details

These are included in the relevant section of the Corporate Privacy Notice.

Information Commissioner’s Office

If we’re unable to resolve your complaint to your satisfaction, you can complain to the Information Commissioner's Office (ICO)