Best Start Family Hubs - Digital Platform, Booking and Activities Privacy Notice

This privacy notice explains how Cheshire West and Chester Council uses personal information when delivering the Best Start Family Hubs digital platform and associated services, including booking, attendance and access to activities.

The Best Start Family Hubs service supports families with children and young people (aged 0–19, or up to 25 for young people with SEND) across Cheshire West and Chester. The service provides a digital platform which allows parents and carers to find information, access support, and book onto sessions, activities and events.

Through this platform, families can:

search for local and national support services
register for and attend activities and programmes
receive information and updates relevant to their needs
access support through a digital chatbot function

The Council works with partner organisations and commissioned providers to deliver services through Family Hubs. Where appropriate, personal information may be shared with these providers to ensure activities can be delivered safely and effectively.

What information we collect, use, and why

When you use the Best Start Family Hubs digital platform, book onto activities, or attend sessions, we collect and use personal information to provide services, manage bookings, and ensure you receive appropriate support.

The information we collect depends on how you use the service.

Personal data

We may collect and use the following personal information where it is necessary:

Name, address and contact details
To identify you, manage bookings, contact you about activities, and provide service updates.
Date of birth
To ensure services and activities are appropriate for you or your child and to support service planning.
Information about your household or children (limited)
Where relevant, to ensure activities and support are suitable and accessible.
Booking and attendance information
To register you for activities, manage attendance, and support providers delivering sessions.
Messages or queries submitted through the digital platform (including chatbot)
To respond to queries and help you access information and services.
Technical and usage information
Such as how you use the platform, login activity, and device information. This helps us maintain system security and improve the service.

Special category data

In some cases, we may collect and use additional sensitive information where this is necessary to provide safe and appropriate services:

Health information or disability details
To make reasonable adjustments, ensure safe participation in activities, and provide appropriate support.
Ethnicity
To monitor who is accessing services, identify gaps, and ensure fair and equal access to support.

This information is only collected where it is relevant and necessary and is handled with additional safeguards.

Where your information comes from

We collect personal information directly from you when you use the Best Start Family Hubs digital platform or take part in activities.

This includes when you:

register or create a profile on the platform
book onto a session, activity or programme
contact the service with a query or request (including through the chatbot function)
attend activities or provide feedback

We also receive information from other sources where this is required to deliver the service.

These include:

Service providers delivering activities
Organisations delivering courses or sessions on behalf of the Council provide attendance information and updates relating to activities you are booked onto.
Other Council services
Relevant information is shared internally where this is necessary to support service delivery, safeguard individuals, or improve access to services.
Referrals from other services
Where you are referred to activities or support, relevant information is provided to support your participation.

We only collect and receive information that is necessary and relevant to deliver the Best Start Family Hubs service. All information is handled securely and in accordance with data protection law.

What your personal information is used for

We collect personal information directly from you when you use the Best Start Family Hubs digital platform or take part in activities.

This includes when you:

register or create a profile on the platform
book onto a session, activity or programme
contact the service with a query or request (including through the chatbot function)
attend activities or provide feedback

We also receive information from other sources where this is required to deliver the service.

These include:

Service providers delivering activities
Organisations delivering courses or sessions on behalf of the Council provide attendance information and updates relating to activities you are booked onto.
Other Council services
Relevant information is shared internally where necessary to support service delivery, safeguard individuals, and improve access to services.
Referrals from other services
Where you are referred to activities or support, relevant information is provided to support your participation.

We only collect and receive information that is necessary and relevant to deliver the Best Start Family Hubs service. All information is handled securely and in accordance with data protection law.

Who we share your personal information with

We only share your personal information where it is necessary, lawful, and proportionate to deliver the Best Start Family Hubs service.

Your personal information is shared with the following organisations:

Service providers delivering activities

Organisations delivering courses, sessions and activities on behalf of the Council receive relevant personal information for individuals booked onto their services.

These providers use this information to:

manage attendance
contact you about sessions (for example, changes or cancellations)
deliver activities safely and appropriately

Providers only have access to information relating to the activities they deliver and are required to handle it securely and in accordance with data protection law.

Other Council services

Relevant information is shared internally where necessary to:

support service delivery
coordinate support
safeguard individuals
improve access to services

National government departments (aggregate reporting only)

We share anonymised or aggregated information with government departments, including:

Department for Education (DfE)
Department of Health and Social Care (DHSC)

This information does not identify individuals and is used for monitoring, funding, and statutory reporting.

Safeguarding and risk management

Where there is a concern about the safety or wellbeing of a child or individual, relevant information is shared with appropriate services to protect individuals from harm.

This is carried out in line with the Council’s safeguarding responsibilities and legal duties.

We do not share your personal information more widely than necessary. All organisations receiving personal information are required to handle it securely and in accordance with data protection law.

Data processors and systems we use

We use data processors and information systems to support the delivery of the Best Start Family Hubs service and to ensure personal information is handled securely and efficiently.

Data processors act on the Council’s instructions and are not permitted to use personal information for their own purposes. All processors are required to:

process personal information only in line with Council instructions
keep information secure and confidential
restrict access to authorised personnel
comply with data protection legislation and contractual requirements

The main systems and processing arrangements used for this service include:

Digital platform

We use a secure digital platform to provide access to Family Hubs services, including:

registering and logging into the service
searching for information and support
booking onto sessions and activities
communicating with the service, including through a chatbot function

The platform includes AI-assisted functionality, which provides responses to general queries and helps users find relevant information. This function supports access to services and does not make decisions about individuals.

Booking and attendance systems

We use secure systems to:

manage bookings for activities and sessions
record attendance
support providers delivering services

Access to this information is restricted to authorised staff and providers involved in delivering the service.

Communication systems

We use approved systems to:

communicate with service users
share information securely with providers where required
manage service-related queries and updates

Reporting and monitoring systems

We use secure systems to:

monitor how services are used
assess service performance and outcomes
produce reports for service improvement and statutory or funding requirements

Where possible, reporting uses aggregated or anonymised information.

All systems used by the Council are subject to appropriate technical and organisational controls to ensure personal information is protected in line with data protection law.

Data Controller

Cheshire West and Chester Council is the Data Controller for the personal information processed as part of the Best Start Family Hubs digital platform, booking and activities service.

This means the Council is responsible for deciding how and why your personal information is collected, used, stored and shared, and for ensuring it is handled in line with data protection legislation.

Where the Council works with service providers or system suppliers, they act either as data processors on behalf of the Council or as separate data controllers, depending on their role. In all cases, personal information is handled in accordance with data protection law and appropriate agreements are in place.

The lawful basis for processing your personal information

Cheshire West and Chester Council processes personal information to deliver the Best Start Family Hubs digital platform, booking and activities service in line with its statutory duties.

We do not rely on consent as the lawful basis for delivering the core service.

UK GDPR Article 6(1)(e) – Public Task

Most personal information is processed under Article 6(1)(e), as the Council is carrying out tasks in the public interest and in the exercise of its official authority.

This includes processing personal information to:

provide access to Family Hubs services and support
enable families to find and use services through the digital platform
communicate information about services, activities and support
support safe and appropriate delivery of services, including safeguarding
monitor and improve services, including reporting and service planning

UK GDPR Article 6(1)(b) – Contract

Article 6(1)(b) applies where you actively book onto a session or activity.

This includes processing personal information to:

register you for a session, activity or programme
manage attendance
contact you about bookings, including confirmations, changes or cancellations

Special category data

Where necessary, the Council processes special category data to deliver services safely and appropriately.

This includes the processing of:

health or disability information
ethnicity data

This information is processed under:

UK GDPR Article 9(2)(g) – Substantial Public Interest

Special category data is processed where this is necessary to:

support individuals with a disability or medical condition and make reasonable adjustments
ensure safe participation in activities
safeguard children and individuals at risk
promote equality of access to services and monitor who is using the service

This processing is supported by:

Data Protection Act 2018, Schedule 1, Part 2, Paragraph 16 – Support for individuals with a particular disability or medical condition
relevant statutory duties relating to safeguarding and service delivery

Consent (limited use)

Consent is not used as the lawful basis for delivering the core Best Start Family Hubs service.

Consent is only used in limited circumstances where participation is optional, for example:

optional feedback or engagement activities
use of images or recordings where you have chosen to take part

Where consent is used, it can be withdrawn at any time.

Legislation

The Council processes personal information under its statutory duties and powers, including:

Children Act 1989
Children Act 2004
Children and Families Act 2014
Care Act 2014 (where applicable)
relevant safeguarding and public health legislation

Best Start Family Hubs programme requirements

International Data Transfers

Cheshire West and Chester Council processes and stores personal information within the United Kingdom.

The systems used to deliver the Best Start Family Hubs digital platform and services are hosted in the UK and are not intended to transfer personal information outside the UK.

In the limited event that personal information is transferred outside the UK, the Council ensures that appropriate safeguards are in place to protect personal information and individuals’ rights. This includes:

transferring data only to countries recognised as providing an adequate level of data protection, or
using approved legal agreements and security measures to protect the data

All international transfers are kept under review to ensure they remain necessary, proportionate, and compliant with data protection law.

How long we keep your information (Retention period)

We only keep personal information for as long as it is necessary to deliver the Best Start Family Hubs digital platform, booking and activities service and to meet our legal, safeguarding and accountability requirements.

Personal information is retained in line with Cheshire West and Chester Council’s Corporate Retention Schedule.

In general, this means:

Booking and attendance records
Records relating to bookings, attendance and participation in activities are retained for up to 7 years after the end of the activity, in line with retention requirements for service delivery and events.

Service engagement and support information
Information relating to access to services or participation in activities is retained for up to 7 years after engagement ends, in line with retention requirements for family support services.

Customer contact and digital interactions
Information collected through the digital platform, including enquiries and chatbot interactions, is retained for shorter defined periods, typically:

enquiries and general contact: up to 1 year
user accounts or registrations: up to 3 years after last use
system and chatbot logs: up to 2 years

Monitoring and reporting data
Information used for monitoring, evaluation and reporting is retained for up to 7 years, in line with performance and audit requirements.
Where possible, this information is anonymised and does not identify individuals.

Safeguarding-related information
Where information relates to safeguarding concerns, it is retained in line with statutory requirements.
In these circumstances, retention periods are longer and may extend until the individual reaches adulthood or beyond, depending on the nature of the information and legal obligations.

Once the relevant retention period has expired, personal information is securely deleted or anonymised in line with the Council’s Records Management Policy.

Your Rights

The UK GDPR provides you with a several rights to control what personal information is used by us and how it is used by us.

Further guidance about these rights can be accessed from the Information Commissioner’s Office (ICO) website

If you are not happy about the way your personal data is being used, or you require further information about how we process your personal data, you can contact Council’s Data Protection Team:-

Online: Contact the DPO
By post: Data Protection Officer, The Portal, Wellington Road, Ellesmere Port, CH65 0BA

You also have the right to complain to the Information Commissioner’s Office using the following details:

Website: Information Commissioner's Office (ICO)
Instant Message: Live Chat
By post: The Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113