Privacy Notice
We ask that you read this privacy
notice carefully as it contains important information on who we are, how and
why we collect, store, use and share personal information, your rights in
relation to your personal information and on how to contact us and other
organisations in the event you have a complaint. Please see the section on ‘Your rights’ for more information.
Introduction
We are Continuity Care
Limited. In order that we can provide
care and support/introduction 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).
We process personal data (including
sensitive personal data), so that we can provide care and support/introduction
services to you. In doing so, we act as a Data Controller and Data Processor.
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 Data
Controller and Data Processor 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.
If you have any questions about
this privacy notice or would like further explanation as to how your personal
information is managed, please send an email to samantha@continuitycare.co.uk,
or write to Samantha Mermagen at 10 Hatherley Road, Cheltenham, Gloucestershire
GL51 6DZ or call 01242 227799.
Please note when we refer to:
- A “public body” we mean any
organisation in the United Kingdom which delivers, commissions or reviews
a public service and includes (but is not limited to) the Ombudsman, local
authorities, councils, unitary authorities, clinical commissioning groups,
health and social care trusts, the National Health Service as well as
their arm’s length bodies and regulators.
- A “social or health care professional”
we mean any person who provides direct services, acts as consultant, or is
involved in the commission of your healthcare or social care services,
including (but not limited to) your General Practitioner (GP), dental
staff, pharmacists, nurses and health visitors, clinical psychologists,
dieticians, physiotherapists, occupational therapists, hospital staff,
social workers and other care and support related professionals.
The personal
information we collect and use in relation to people who enquire about and use
our services
Information collected by us
When you enquire about our care and
support/introduction services and during the course of providing care and
support/introduction 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, mobile
number, email address and client Representative or Power of Attorney contact
details (i.e. name, relationship and Address, Email address and your home
landline and mobile numbers)
- your medical history
including your gender, NHS number, NI number, GP and District Nurse information
and any medical, physical or mental conditions and in particular your care
needs. We ask for consent to access your GP medical records in case of
Emergency situations. i.e for Paramedics and Emergency service responders,
however we will respect your decision and privacy should you not give us
consent for this.
- your property and car
details for information purposes for the Carer/PA’s we introduce to you.
- your likes, dislikes and
lifestyle preferences (including your religious beliefs or other beliefs of a
similar nature, racial or ethnic origin, genetics, health, sexuality (so far as
they relate to providing you with suitable care).
- your preferences in regards
to the Carers/PA’s we introduce to you. (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)
- transaction Data includes
details about payments to and from us and other details of services you have
purchased from us.
- technical Data includes
internet protocol (IP) address, your login data, browser type and version, time
zone settings and locations, operating system and platform and other technology
on the devices you use to access our website.
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 (including your religious beliefs or other beliefs of a
similar nature, racial or ethnic origin, politics, genetics, health, and sexuality
so far as they relate to providing you with suitable care) from your family,
friends and any other person you have nominated as your representative
- your Attorney or Deputy (if
applicable)
- your Carers that we have
introduced to you.
How we use your personal information
We use your personal information
to:
- prepare, review and update
a suitable Guide to the Client document, 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 to personalise the service and
Carers we introduce 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 reassessments
and, review our services to improve our customer experience (please note that
feedback can also be provided anonymously)
Who we share your personal information with
We regularly share your medical
information with appropriate external social or health care professionals
(including your GP and pharmacist) 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 and to
introduce the right Carers to suit your individual circumstances, including if
(in future) you decide to receive care from an alternative provider.
We will share personal information
with law enforcement or other authorities if required by law. This includes
information required by public bodies to evidence our compliance with the
applicable regulatory framework. We are also required to share personal
information with external social or health care professionals, including public
bodies and local safeguarding groups (in some circumstances) to ensure your
safety.
We will only share your personal and sensitive
personal data with service providers such as carers chosen to care for you.
Only that information that is strictly necessary for the provision of care will
be given to that service provider or Carer.
We may have to share your personal data with certain
third parties such as:
- Service Providers acting as processors based in the United Kingdom who
provide IT and systems administration services.
- Professional
advisers acting as processors or joint controllers including lawyers, bankers,
auditors and insurers based in the United Kingdom who provide consultancy,
banking, legal, insurance and accounting services.
- HM
Revenue & Customs, regulators and other authorities acting as processors or
joint controllers based in the United Kingdom who require reporting of
processing activities in certain circumstances.
We require all third parties to respect the security
of your personal data and to treat it in accordance with the law. We do not
allow our third-party service providers to use your personal data for their own
purposes and only permit them to process your personal data for specified
purposes and in accordance with our instructions.
We do not transfer your personal data outside the
European Economic Area (EEA).
Whether information has to be provided by you,
and if so why
The provision of your medical,
physical or mental condition is necessary to enable us to create a Guide to the
Client document and to introduce to you suitable Carers to deliver the care and
support services you need at home. Without this information, we will not be
able to assess your care needs or provide any care services to you.
The provision of your name, home
address is required so that we can arrange a Carer to attend your home to
deliver the services and so that we can invoice you for the fees.
We will inform you or your
representative at the point of collecting information from you, whether you are
required to provide the information to us.
How long your personal information will be
kept
- we will hold the personal
information kept within your client file for the period that is stipulated by
our Insurers.
- we will hold the personal
information kept within our feedback procedure for the duration that the client
has care services from ourselves so that we can identify trends and patterns in
our service
- We will hold credit or
debit card information for the duration that the client has care services from
ourselves so that we can process your payments.
The personal information we hold
Reasons we can collect and use your personal
information
We rely on the following grounds
within the GDPR:
- Article 6(1)(b) –
processing is necessary for the performance of our contracts to provide individuals with care and support/introduction
services
- Article 6(1)(c) –
processing is necessary for us to demonstrate compliance with our regulatory framework and the law
- Article 9(2)(h) –
processing is necessary for the provision
of social care or the management of social care systems and services
- Article 6 (1) (f) –
processing your personal information to improve the care and
support/introduction services we supply to you.
as the lawful
basis on which we collect and use your personal data and special category data
(such as your health).
We also rely on the following
grounds within the GDPR to process your personal information in pursuit of our legitimate Interests:
- Article 6 (1) (f) –
processing your personal information to improve the care and
support/introduction services we supply to you.
Your rights
Under the GDPR you have a number of important rights free
of charge. In summary, those include rights to:
- fair processing of
information and transparency over how we use your use personal information;
- access to your personal
information and to certain other supplementary information that this Privacy
Notice is already designed to address;
- require us to correct any
mistakes in your information which we hold;
- require the erasure (i.e.
deletion) of personal information concerning you, in certain situations. Please note that if you ask us to delete
any of your personal information which we believe is necessary for us to comply
with our contractual or legal obligations, we may no longer be able to provide
care and support/introduction services to you;
- receive the personal
information concerning you which you have provided to us, in a structured,
commonly used and machine-readable format and have the right to transmit those data
to a third party in certain situations;
- object at any time to
processing of personal information concerning you for direct marketing;
- object to decisions being
taken by automated means which produce legal effects concerning you or
similarly significantly affect you;
- object in certain other
situations to our continued processing of your personal information;
- otherwise restrict our
processing of your personal information in certain circumstances;
- claim compensation for
damages caused by our breach of any data protection laws;
For further information on each of
those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO)
on individuals’ rights under the General Data Protection Regulation.
Keeping your personal information secure
We have appropriate security
measures in place to prevent personal information from being accidentally lost,
or used or accessed in an unauthorised way. We limit access to your personal
information to those who have a genuine business need to know it. Those
processing your information will do so only in an authorised manner and are
subject to a duty of confidentiality.
We also have procedures in place to
deal with any suspected data security breach. We will notify you and any
applicable regulator of a suspected data security breach where we are legally
required to do so.
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.
How to contact us and complain
We hope that we can resolve any
query or concern you raise about our use of your information.
How to contact us:
If you would like to exercise any
of your rights, please:
- email, call or write to
Samantha Mermagen, our Data Protection Officer.
- let us have enough
information to identify you (eg your name and address),
- let us have proof of your
identity and address (a copy of your driving licence or passport and a recent
utility or credit card bill), and
- let us know the information
to which your request relates, including any account or reference numbers, if
you have them
The GDPR also gives you right to lodge a complaint
with a supervisory authority, in particular in the European Union (or European
Economic Area) state where you work, normally live or where any alleged
infringement of data protection laws occurred. The supervisory authority in the
UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/
or telephone: 0303 123 1113.
The ICO’s
Address:
Informations
Commissioners Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Changes to this privacy notice
This privacy notice was created on
22nd May 2018 and last updated on 14th June 2019.
We may change this privacy notice
from time to time, when we do we will inform you via letter or email.
Do you need extra help?
If you would like this notice in
another format (for example: audio, large print, braille) please contact us
(see ‘How to contact us’ above).