Data Protection and Record Keeping Policy

Created 11/04/2020 by Glesni Evans 

1. The purpose and scope of this policy statement Adoption Finder will: 

Adoption Finder aims to ensure that all personal data collected about staff, customers and any other individuals is collected, stored and processed in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR), the Data Protection Act 2018 (DPA 2018) and The Regulated Adoption Services (Services Providers and Responsible Individuals) (Wales) Regulations 2019.  This policy applies to all personal data, regardless of whether it is in paper or electronic format.

2. Definitions of data:



Personal Data 

Any information relating to an identified, or identifiable, living individual. 

Special categories of personal data

There is stronger legal protection for more sensitive information, such as:

  • Race
  • Ethnic background
  • Political opinions
  • Religious beliefs
  • Trade union membership
  • Genetics
  • Biometrics (where used for identification)
  • Health
  • Sex life or orientation


Anything done to personal data, such as collecting, recording, organising, structuring, storing, adapting, altering, retrieving, using, disseminating, erasing or destroying. Processing can be automated or manual.

3. Adoption Finder fully support and must be able to demonstrate compliance with the six principles of the Act which are summarised below:

4. This policy applies to all staff including any volunteers.

5. Adoption Finder will do the following:

6. How we will store records

Please see Annex A for information about records we are required to store. 

7. How long we will store your records?

8. Who else could view your records?

9. Accessing records that Adoption Finder has about you

You can access records that Adoption Finder has on you by making this request in writing. You should clearly state what information you want and include some kind of identification in your request. The Service Provider will assess your request and make arrangements with you for you to view your records. The Service Provider will ask for two forms of identification before allowing you access to your records. The Service Provider could refuse you access to your records if the records are likely to cause serious harm or distress to you or another person. The service provider could also refuse you access if third parties are included in the records but these could be removed. 

10. Data protection rights of the individual

In addition to the right to make a subject access request (see above), and to receive information when we are collecting their data about how we use and process it, individuals also have the right to: 

Annex A

  1. In respect of each individual

    • Full Name

    • Date of Birth

    • Whether the person is

      • a child who may be adopted, their parent or guardian

      • a person wishing to adopt a child

      • an adopted person, their parent, birth parent, former guardian or related person

    • Description of support requested

    • Description of need for support along with any assessment of that need

    • Description of support provided

    • Whether the support is provided on behalf of a local authority under regulations made under section 3(4)(b) of the 2002 Act;

    • Plans including

      • adoption support plans

      • care and support plans

      • placement plans

      • reviews of plans referred to in sub-paragraph (1.8)

  2. A record of any charges by the service provider to individuals for the provision of support and any additional services.

  3. A record of all complaints made by individuals or their representatives or by persons working at the service about the operation of the service, and the action taken by the service provider in respect of any such complaint.

  4. A record of all persons working at the service, which must include the following matters

    • full name and home address

    • Date of Birth

    • qualifications relevant to, and experience of, working with individuals

    • the dates on which the person commences and ceases to be so employed

    • whether the person is employed by the service provider under a contract of service, a contract for services, or otherwise than under contract, or is employed by someone other than the service provider

    • Description of support provided

    • the position the person holds at the service, the work the person performs and the number of hours for which the person is employed each week

    • a copy of the person’s birth certificate and passport (if any)

    • a copy of each reference obtained in respect of the person

    • training undertaken by the person, their supervision and appraisal

    • records of disciplinary action and any other records in relation to the person’s employment

    • a record of the date of the person’s latest DBS certificate and whether there was any action taken as a result of the content of the certificate