Direct payments and prepaid cards (allpay) privacy notice
This privacy notice is one of a collection that apply to the processing of personal data for the purpose of meeting our statutory responsibilities under the Care Act 2014 and supporting legislation.
This notice focuses on the information used to provide and manage direct payments and prepaid cards (allpay) in line with our statutory responsibilities under the Care and Support (Direct Payments) Regulations 2014.
Allpay’s Prepaid Card is a preloaded Mastercard that can be used to pay for goods and services up to the value loaded on the card. There is no credit or overdraft facility
The notice provides additional information that specifically relates to this particular service and should be read together with our overarching privacy notice for:
Depending on the amount of support that is required, we may use your information to:
- monitor direct payments and prepaid card accounts as set out in the Direct Payment Agreement
- talk to and instruct, the prepaid card provider (allpay) as required for the delivery of direct payment and prepaid card account.
- we will monitor the transactions on your prepaid account/ card
- we will use the information we hold to arrange to recover surplus/unspent money held on the account directly back to the Council, we will make sure that you retain the relevant amounts to cover your care commitments
- we will use the information held on the prepaid card account to help you to keep your card/account safe and secure, for example we will place immediate “stops” on cards reported as lost/stolen.
- set up a prepaid card account with a third-party provider where and when it is appropriate to do so
- we may also use the information about you that we already hold within different Council Services to help us to verify your identity. This might be (but not limited to) information we already hold for Council Tax, Social Care, Financial Assessments.
- provide you with information and advice regarding your direct payment and allpay account
- refer for direct payment support, including advice on employing personal assistants
- liaise with/query issues with support service providers where necessary in relation to prepaid cards/ accounts
- use your information for the prevention and detection of fraud in line with legal requirements for the administration of public funds and as far as the law allows
What personal data is being collected?
The type and amount of information that we hold will depend on the nature of your direct payment and how it is managed, this notice refers specifically to use of a prepaid card and the related online account.
All of our direct payment services including allpay are subject to terms and conditions providing specific details on your agreement with us and will further inform you of the process and information relevant to you.
The information we may hold may include:
- copies of your identity documents used to set up the prepaid card account, this is required for audit purposes for internal council audit as well as part of the Financial Conduct Authority
- where we manage your direct payment, information about your provider, nature and cost of your services that are being paid for
- information about people that you nominate to support you to manage your direct payment, such as their name, address, and relationship to you (this will also be the case if you have a Lasting Power of Attorney or Deputy who represents you)
- we may access information about your support plan and financial assessment as part of the direct payment processes
What is the legal basis for processing your personal data?
We collect and use your personal data to meet a legal obligation and to comply with a statutory function. The legislation we are relying on for this service is the Care Act 2014 Care and Support (Direct Payments) Regulations 2014.
The information will be managed in confidential manner. All information will be held securely and processed on a ‘need to know’ basis by those people with a business need to do so.
Who we share your personal data with?
Whilst we always prioritise and respect the privacy of everyone involved with our services there may be times under the law when we must share information.
As part of the allpay Limited prepaid card agreement there will be a requirement to share your ID (on request) with allpay Limited (Third Party). The purpose of this is for the Third Party to carry out security checks and searches prior to processing the payment and to ensure you will receive the payment as agreed on your card. These checks are part of fraud and money laundering laws we must comply with.
- Allpay Ltd, Whitestone Business Park, Whitestone, Hereford, HR1 2SE (company number 02933191)
- Allpay pre-paid card is issued by Allpay ltd pursuant to license by Mastercard International Incorporated
We may also share information as part of this agreement with (but not limited to:)
- if there is a concern you are putting yourself, or another person (or child) at risk of serious harm
- where we have been instructed to do so by the Court and/or as part of an investigation of a serious crime
- information about you may be used for the prevention and detection of fraud
- information for the purposes of auditing, internally and externally as far as the law allows
How long will my personal data be retained?
The information will be retained by us for seven years. When the information is no longer needed for this purpose, it will be destroyed securely.
Under UK GDPR you have a number of rights that are set out on our Data protection for you pages.
Further guidance about these rights can be found on the Information Commissioner’s Office (ICO) website.
Who can I complain to if I am unhappy about how my data is used?
You can complain directly to our Data Protection team online or by post.
- 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:
- Information Commissioner's Office (ICO) website
- By post: The Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- Telephone: 08456 30 60 60