Active Travel Social Prescribing pilot scheme privacy notice

Leeds City Council (“the council”) has received £1.3m funding from the Department of Transport (DfT), to support the research, delivery and evaluation of an Active Travel Social Prescribing Pilot (ATSP). ATSP is a pilot scheme that will operate from October 2022 to October 2025 in the Burmantofts, Richmond Hill and Harehills Primary Care Network.

The purpose of ATSP is the social prescribing of walking, wheeling and cycling by healthcare professionals through referral from Leeds City Council to improve mental and physical health of people, like yourself, through walking and cycling groups in Burmantofts, Richmond Hill and Harehills Primary Care Network.

The data controller for this project

Leeds City Council is the data controller for all personal data you provide as part of this scheme. Urban Foresight Ltd (“Urban Foresight”), the consultant appointed by Leeds City Council as the monitoring and evaluation partner for ATSP, is the data processor.

The reasons we use your data

As part of the funding agreement between the council and the funder, the Department of Transport, monitoring and evaluation of the pilot scheme needs to be undertaken to show its effectiveness for the following aims of ATSP by the Department for Transport:

• To address local community needs relating to underrepresented groups, high levels of deprivation, and health inequalities.
• To actively promote increased levels of physical activity through cycling and walking
• To understand how infrastructure influences the uptake of active travel
• To support modal shift to active travel providing people with travel choices and supporting changes in behaviour. 

How will we collect your data

The collection of data about participants in the ATSP is crucial to achieving the aims of the project. Once you have provided consent for the ATSP to use your data, there will be several stages in the ATSP that your data will be collected. First when you consent to joining the pilot scheme and then every six months. 

Referral Pathways

There are two referral ways that you will be referred to the ATSP: the Clinical Pathway or the BHR Pathway

Clinical Pathway Referral

If you are referred through the Clinical Pathway, this will be the first point of contact in the ATSP when your data is collected. You will be referred to ATSP from Leeds Encouraging Activity in People (LEAP) by the Active Leeds team. LEAP will collect personal data outlined in the "The data we will collect" section of their privacy notice to determine whether it is appropriate to offer social prescribing to you through an ATSP commissioned walking and cycling provider. If you have been triaged to ATSP, you will have a face to face meeting where we'll explain the project aims and its data collection requirements. If you are happy to consent to your data being collected,  you will be provided a consent form to complete acknowledging you are happy to proceed.

Additionally, your information might be shared from the NHS to Leeds City Council due to a contract between the NHS Primary Care Network and LEAP, and by consenting to take part in LEAP you consent to your personal data being appropriately processed and shared with the ATSP. The LEAP privacy notice can be found on Active Leeds.

Bumantofts, Harehills, and Richmond Hill (BHR) and Self-Referral Referral Pathway

If you are referred through the BHR Referral Pathway, you will be referred to ATSP from Leeds Encouraging Activity in People (LEAP). This will involve a member of LEAP reviewing your personal data as outlined in the "The data we will collect" section of the privacy notice below.

Gaining your consent

We will obtain your consent by providing you with an online consent form via a hyperlink as well as a copy of this privacy notice.

The Active Travel Social Prescribing Consent statement to read and sign.

The consent form has been created using Smart Survey. Smart Survey's UK GDPR compliance policy. Smart survey's privacy notice.

If you provide your consent through signing the online consent form, your personal data will be forwarded to Leeds City Council - Walk It Ride It Development Officer who will contact you and provide details of the Walking and Cycling providers.

Signing the consent form indicates your willingness to take part in the ATSP survey and consents to the use of your personal and special category data by Urban Foresight Limited.

Once you have consented to take part in ATSP, Urban Foresight will contact you to participate in a survey about your experience of socially prescribed walking and cycling. This survey, produced by the Department for Transport, will collect personal data and special category data as mentioned in the "The data we will collect" section of the privacy notice and will be processed by Urban Foresight.

Urban Foresight will contact you at the start of the referral process and at six and twelve months after your engagement with the socially prescribed walking and cycling provision.

Additional events where data will be collected

Alongside the referral pathway and survey, there will be several events you can participate in for ATSP. These include: interviews, focus groups, workshops and community events. These events may collect personal data outlined in "The data we will collect" section of the privacy notice, but no special category data. 

The data we will collect

The ATSP is required to process either your personal and or special category data or both to comply with the funding requirements of the Department of Transport.

The personal data requirements of the pilot are:

• Unique identifier
• First Name
• Postcode
• Partial postcode (i.e. LS10 1)
• Year of birth
• Email address
• Telephone / mobile number
• Date of referral
• Activity referred to
• GP Practice
• NHS Number
• Gender
• Income
• Age range
• Employment/working status

The pilot will collect and use special category data from the following information :

• Ethnicity
• Sexual orientation
• Health (Mental and Physical)

The pilot will also collect the following non-personal data from you:

• Awareness, confidence and skill in using active travel
• Participation of active travel
• Participation of other physical activity options
• Use of health services
• Perceptions of the local area
  
• Experience and perceptions of the activity
• To develop the baseline evidence about perceptions of the local area and barriers to active travel
• To evaluate the extent to which perceptions of the local area improve and barriers to active travel reduce
• To evaluate the extent to which messaging within the community has been received.

How we use your data

Leeds City Council and Urban Foresight will be able to identify you from the information held. However, after you have been directed to the ATSP from LEAP a unique reference number will be allocated at the time you prescribe to either walking and/or cycling provision.

Leeds City Council will share the pseudonymised data (aggregated) with the Department for Transport where your identifiable information, such as name, will be replaced with a Unique Reference Number (URN), however, the URN may include information such as age, sex, ethnicity and medical information. The Department for Transport final report will not be able to identify you as all information collected under the scheme will be aggregated.

We wanted to be completely open about how Urban Foresight will use your data and give you the opportunity to opt out at any time after providing consent up to the point the data is anonymised by aggregating it with the data of the other participants. After which it will not be possible to remove your data.

Why we process your data

The pilot collects personal and special category data to enable it to find out whether the activities you have taken part in and have made an impact on the aims of ATSP

The data you provide from surveys, interviews and other events collected by Urban Foresight will be stored on secure cloud servers by Urban Foresight. Urban Foresight will collect and process your data according to the General Data Protection Regulation ("GDPR"), the Data Protection Act 2018, and Leeds City Council's data protection policies.

Your responses will be treated in confidence and processed by Urban Foresight in accordance with relevant UK data laws.

• The collection, storage and dissemination of data will follow the UK General Data Protection Regulation's (GDPR) principles of lawfulness, fairness and transparency.
• The project will adhere to the requirements of the UK Data Protection Act (2018).
• Your personal data will be obtained lawfully, will be obtained only as is appropriate (i.e., not excessive) for the project, will be used for the stated purpose, will be processed in accordance with the above laws, and will be captured, stored and communicated in a way that protects it against unauthorised or unlawful processing, accidental loss or destruction.

At the end of the pilot (October 2025) Urban Foresight will prepare a final report to the Department for Transport. Pseudonymised survey responses will be shared with Active Travel England and the Department for Transport as well as the national monitoring and evaluation partner for the pilot who are soon to be appointed. We will notify you when the appointment is made and how is impacts your data. The final report will only contain URN information for the results of ATSP. Your personal information, including your name, contact details, and date of birth will be removed before data is shared with Active Travel England/Department for Transport and the national monitoring and evaluation partner (to be appointed). There is no risk of Active Travel England, the Department for Transport of the national monitoring and evaluation partner being able to identify you from the data that is sent.

The final report will be shared with Active Travel England and Department for Transport's national monitoring and evaluation partner. The data provided by you will not be used for any purpose other than for this pilot.

The legal basis for processing your data

We will process your personal data based on your consent in accordance with UK GDPR Article 6(1)(a). The processing shall be lawful only if and to the extent that the following applies:

• You have given consent to the processing of your personal data for one or more specific purposes

We will process your special category data based on your explicit consent in accordance with UK GDPR Article 9(2)(a). The processing shall be lawful only if and to be extent that the following applies:

• the data subject has given explicit consent to the processing of those personal data for one or more specified purposes

UK GDPR Article 9 defines special category data as racial or ethnic origin, political opinions or religious or philosophical beliefs, trade union membership and the processing of genetic data and or biometric data for the purpose of uniquely identifying a natural person, data concerning health and or a natural person's sex life or sexual orientation.

You will provide their explicit consent through agreeing to the consent form provided at the beginning of the referral to the pilot scheme in a face to face meeting. The consent form contains a tick box opt in statement for the participant to consent to allowing the pilot scheme to use their special category data.

Who we can share your data with

If you consent to your data being processed, the council through LEAP will share your data with our monitoring and evaluation partner, Urban Foresight Limited, and third party activity providers. 

Urban Foresight will produce a final report with the data anonymised and collated that will be sent to the council and the DfT about the effectiveness of the pilot scheme. Therefore, it should be noted that neither the council (outside of LEAP), or the Department for Transport, will have access or be able to identify you and your personal data from the pilot scheme. 

Through a data sharing agreement, only your first name and contact details collected in the smartsurvey consent form will be passed onto the Walking Providers, Touchstone and Health for All, in order for them to contact you about walking group opportunities as part of the pilot scheme. 

Both walking providers comply with data protection legislation and their privacy policies can be found online: 

• Touchstone Privacy Policy 
• Health For All Data Protection

If English is not your first language and you require a translator in order to complete the DfT Survey administered by Urban Foresight, a Leeds City Council translator is available to you. As the survey will ask you for personal and special category data, the Leeds City Council translator will sign the data protection guidance provided by the Leeds City Council.

Automated Decision Making

Your data will not be used for any automated decision making.

When your data gets sent to other countries

The information you provide will not be transferred to another country outside of the UK

Withdrawing your consent

You have the right to withdraw your consent from participating in the pilot at any time. Withdrawing your consent will not affect any services or benefits you receive from the pilot. If you decide that you no longer wish to participate in the pilot please contact Activetravelsocialprescribing@leeds.gov.uk. If you get in touch to opt-out of the pilot, we will treat this as notification of removing consent and delete all identifiable personal data.

Data retention, storage, and destruction

Personal and special category data that we process for any purpose or purposes shall not be kept for longer than is necessary.

We will retain your personal data as follows:

• the information collected by Urban Foresight Ltd will be retained for a period of 36 months (3 years) after the completion of the pilot. The pilot is due to complete by October 2025 then your information will be securely destroyed.

The information collected by individuals or businesses we have been commissioned to deliver social prescribing activities will be retained for three years.

In addition, we will share your personal data:

• where such disclosure is necessary for compliance with a legal obligation to which we are subject
• in order to protect your vital interests or the vital interests of another natural person
• for the purposes of security and prevention of fraud and other criminal activity
• where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure

Your rights under UK data protection legislation

Your principal rights under data protection law are:

• the right to access - you can ask for copies of your personal data
• the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data
• the right to erasure - you can ask us to erase your personal data
• the right to restrict processing - you can ask us to restrict the processing of your personal data
• the right to object to processing - you can object to the processing of your personal data
• the right to data portability - you can ask that we transfer your personal data to another organisation or to you
• the right to complain to a supervisory authority - you can complain about our processing of your personal data
• the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent

These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects through the Information Commissioner's Office.

You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

Contact us

Any data protection queries in relation to the pilot should be forwarded to:

Any queries relating to the ATSP pilot scheme should be directed to:

Changes to this notice

We keep our privacy notice under regular review. We will notify you of significant changes to this notice by email or other means as appropriate. This privacy notice was last updated 24 January 2024.