WHO ARE WE?
We are Hill Care Holdings Ltd, registered in England 08902865
If you have any questions about this Policy, or about how we look after your data generally, please contact us via email@example.com or by calling 01246 558734.
Hill Care Holdings Ltd (‘we’ or ‘us’ etc), is a ‘data controller’. This means that, under the General Data Protection Regulation (GDPR), we may control and process your personal data and, in certain circumstances, special categories of data (previously known as sensitive data).
Your care plan, and any associated information, is very likely to be a special category of data.
We take privacy very seriously. We are committed to keeping your data secure and processing it fairly and lawfully. We ask that you read this policy very carefully because it contains important information about how we process your personal data.
This policy is aimed at our clients, service users, staff and any other third parties interacting with us.
PERSONAL DATA WE MAY COLLECT ABOUT YOU
In order that we can provide care and support services to the people we support, we collect and use certain personal information about you.
Personal information means any information about you from which you can be identified, but it does not include information where your identity has been removed (anonymous data).
As the ‘controller’ of personal information, we are responsible for how that data is managed. The General Data Protection Regulation (“GDPR”), which applies in the United Kingdom and across the European Union, sets out our obligations to you and your rights in respect of how we manage your personal information.
As the ‘controller’ of your personal information, we will ensure that the personal information we hold about you is:
- used lawfully, fairly and in a transparent way.
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- relevant to the purposes we have told you about and limited only to those purposes.
- accurate and kept up to date.
- kept only as long as necessary for the purposes we have told you about.
- kept securely.
Information collected by us
When you enquire about our care and support services and during the course of providing care and support services to you we collect the following personal information when you provide it to us:
- your name, home address, date of birth and contact details (including your telephone number, email address) and emergency contacts (i.e. name, relationship and home and mobile numbers)
- your health and social care information, including allergies and any medical, physical or mental health conditions, medications and in particular your care needs
- your likes, dislikes and lifestyle preferences (so far as they relate to providing you with suitable care)
- credit or direct debit details (if you pay for some or all of our services using one of these methods)
- photographs and video material of you as part of providing you with suitable care, but always with your specific consent.
Information collected from other sources
We also obtain personal information from other sources such as:
- your allergies and any medical, physical or mental conditions and in particular your care and support needs, from any appropriate external social or health care professionals (including your GP)
- your name, home address, date of birth, contact details, needs assessments and financial assessments from any appropriate external social or health care professionals (including any relevant public body regardless of whether you are publicly funded)
- your likes, dislikes and lifestyle preferences from your family, friends and any other person you have nominated as your representative, your Attorney or Deputy (if applicable)
HOW WE USE YOUR PERSONAL DATA
We use your personal information to:
- prepare, review and update a suitable care plan, describing the nature and level of care and support services which you have requested we supply to you
- to communicate with you, your representatives and any appropriate external social or health care professionals about your individual needs and personalise the service delivered to you
- make reasonable adjustments, when required, to meet your individual needs and to ensure we have suitable facilities to ensure your safety
- invoice you for the care and support services in accordance with our terms and conditions
- carry out quality assurance procedures, review our service and improve our customer experience (please note that feedback can also be provided anonymously).
- as part of our legal and safeguarding obligations we may share information with regulatory bodies.
In addition, we may use your personal data for the following circumstances:
- Where we consider it necessary to be in your vital interests
- Where we are legally required to do so, such as because of a contractual obligation owed to a third party, such as a commissioning body
- For the purposes of assessing your application for services
- Research, statistical analysis and behavioural analysis
- Direct marketing, where you have specifically consented
- Fraud prevention and detection
- Taking and processing payments
- Customising our website and its content to your particular preferences
- To notify you of any changes to our website or to our services which may affect you
- Security vetting
- Improving our services
We may also share your personal information, including medical information, with appropriate external social or health care professionals and any individuals you have nominated as your representative. This data sharing enables us to establish the type of care and support you need. It also allows us to design the right care package to suit your individual circumstances, including if (in future) you decide to receive care from an alternative provider.
MARKETING AND OPTING OUT
We will not contact you for the purposes of direct marketing unless you have asked us to do so. However, if you have asked us to do so and later your change your mind, you can opt-out at any time with no hassle. To do this, just let us know. See further ‘Your rights’ below for details about how to contact us.
WHO HAS ACCESS TO YOUR PERSONAL INFORMATION?
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
Third Party Service Providers working on our behalf: We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
KEEPING YOUR DATA SECURE
We will use technical and organisational measures to safeguard your personal data, for example:
- Access to our systems is controlled by password and username which are unique to the user;
- We store your electronic personal data on secure servers;
- We store your paper records in locked fire-proof storage rooms;
- We train our staff in good records management;
- Payment details are encrypted
Non-sensitive details (your contact details and preferences for example) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
TRANSFERRING YOUR INFORMATION OUTSIDE OF EUROPE
We may store your data temporarily on our cloud service operated by Google. This may include limited special categories of data. We have taken appropriate steps to satisfy ourselves that your data will be secure during this process; we have a contractual relationship with Google that underpins this. As part of that security, Google may store your data in one or more or its international data centres, meaning that your data may be stored temporarily outside of the European Economic Area. If you have any concerns about this, please contact us using the details below.
INFORMATION ABOUT OTHER INDIVIDUALS
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
- Give consent on his/her behalf to the processing of his or her personal data
- Receive on his/her behalf any data protection notices
HOW LONG DO WE KEEP YOUR DATA FOR?
As a general rule, we will not keep your data for any longer than is necessary to complete tasks or provide you with services. We have a separate policy setting out retention periods for specific types of data. You can ask to see this policy by writing to us, using the contact details under the “Your Rights” section below. You also have the right to ask us to delete your data (sometimes known as ‘the right to be forgotten’.)
- Track your use of the site;
- Recognise you whenever you visit this website (this speeds up your access to the site as you do not have to log on each time);
- Obtain information about your preferences, online movements and use of the internet;
- Carry out research and statistical analysis to help improve our content, products and services and to help us better understand our visitor/customer requirements and interests
• Target our marketing and advertising campaigns more effectively
• Make your online experience more efficient and enjoyable
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If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
You have various rights under the GDPR, including the following rights:
- Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
- Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, providing you with services), or consent to market to you, you may withdraw your consent at any time.
- Data Subject Access Requests (DSAR): Just so it’s clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or delete such information. At this point we may comply with your request or, additionally do one of the following:
– we may ask you to verify your identity, or ask for more information about your request; and
– where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.
- Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply.
- Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format.
- Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority, details of which can be found below.
To exercise any of your rights concerning your information, please send an email to the following address:
Or write to us at the following postal address:
Hill Care Group
2 St. Marys Gate
We may ask you to provide us with proof or your identity. Please do not be offended; this may occur even if we know you. It is a requirement of the GDPR in some cases.
This Policy was last reviewed on 25.05.18
THE INFORMATION COMMISSIONER’S OFFICE
More information about privacy laws can be found at www.ico.org.uk
Details of your local supervisory authority: The Information Commissioner’s Office. You can contact them in the following ways:
- Phone: 0303 123 1113
- Email: firstname.lastname@example.org
- Live chat, via the ICO website
- Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF