Live running memo 27: Erasing participants records and return to face to face interventions
Updated 12 November 2021
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Dear provider and local authority,
The Reducing Parental Conflict provider guidance is being updated to provide information on offering face to face interventions and the correct action to take if a Participant requests you erase their records.
Face to Face Interventions
At all initial assessments parents must be offered the option of a face-to-face intervention. Where face-to-face is requested you must be able to accommodate this. Also you must record on the Intervention Plan that this offer has been made.
Action to take on a request to erase personal records
Upon receipt of the request you should acknowledge the request from the Participant and issue a holding response immediately, detailing that the query will be responded to within one month.
You should then forward the details of the request, including their unique reference number to the Data Protection Office, email address: data.protectionofficer@dwp.gov.uk and copy in the RPC enquiry inbox, email address: cepspecialist.provisionenquiries@dwp.gov.uk
You will receive a generic email containing a reference number and the actions that you should take from the Data Protection Office (DPO) team. The reference number must be used with all correspondence with the DPO team.
Before responding to the Participant, you should consider the following:
Details can be deleted for Participants who:
- did not start
- did not attend the IA
- attended the IA but decided it was not for them
- attended the IA but did not start the actual intervention
If the Participant has started the interventions, their information would be kept for audit and payment purposes
Once you have considered the Participants progress within the programme, and you agree to the erasure of the Participants personal information, you must either issue the accepted letter RPC RTE Acc (letter which approves the request to erase the information) or you must respond with your own communication.
You should then forward the response email (including letter or communication from yourself) with the reference number to the Data Protection Office, email address: data.protectionofficer@dwp.gov.uk and copy in the RPC enquiry inbox, email address: cepspecialist.provisionenquiries@dwp.gov.uk
All responses must be issued within one month of receipt of the request from the Participant and must contain the reference number supplied to you.
If when considering the Participants progress within the programme you cannot erase their information you must either issue the rejection letter RPC RTE Rej (letter which rejects the request to erase the information) or you must respond with your own communication.
You must forward the response email (including the letter or communication from yourself) with the reference number to the data protection office. email address: data.protectionofficer@dwp.gov.uk and send a copy to the RPC enquiry inbox, email address: cepspecialist.provisionenquiries@dwp.gov.uk.
All responses must be issued within one month of receipt of the request from the Participant and must contain the reference number supplied.
Summary and Action
Provider Guidance will be updated shortly.