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Customer Data Protection

What personal information do we process and on what basis?

Below we set out the information we collect and what the basis for processing it is. We collect this information directly from you or your family member or representative. We also collect information from third parties such as social workers and from public registers such as the land register. We also carry our credit checks using the credit reference provider Equifax. All personal information is held securely with our third-party software providers; Access Group (Careblox), Bottomline (PT-X) and Microsoft (Dynamics 365). We also hold some paper records securely in our offices in order to allow us to effectively manage our business and our relationship with you.

 

Admission assessments

Why we use your information

To consider your admission and how we can help your care needs.

Our lawful basis for using your information

  • It is necessary in order to enter into a contract with you.
  • It is necessary to meet legal / regulatory obligations.
  • It is necessary to consider your healthcare requirements as a potential resident*.

What information do we hold?

  • Personal details (such as name, date of birth, gender, marital status and dependents, national insurance number and copy driving license and passport).
  • Contact details (such as your previous address, personal telephone number and personal email address).
  • Financial information (such as your bank account details and information about your financial circumstances).

On whom do we hold data?

  • Resident
  • Potential Resident
  • Funder
  • Next of kin / family / friends / emergency contact / PoA

 

Provision of care and accommodation and related services

Why we use your information

To provide you with safe, appropriate and personalised care and accommodation as one of our residents and ensure that we meet your individual requirements. This will include using your information for the following reasons:

  • Meeting your dietary requirements;
  • Making necessary adaptations to your accommodation;
  • Delivering the healthcare and personal care you require; and
  • Determining your capacity for decision making.

Our lawful basis for using your information

  • It is necessary to perform our contract with you.
  • It is necessary to meet legal / regulatory obligations.
  • It is necessary for our legitimate interests (where they are not overridden by your rights).
  • It is necessary for the protection of your vital interests.
  • It is necessary for us to provide you with healthcare as a resident*.

What information do we hold?

  • Personal details (such as name, date of birth, gender, marital status and dependents, national insurance number and copy driving license and passport).
  • Contact details (such as your previous address, personal telephone number and personal email address).
  • Financial information (such as your bank account details and information about your financial circumstances).
  • Your likes and dislikes (relating to hobbies, food, routines and other categories of likes and dislikes which help us improve your care).
  • Information about your care preferences (to ensure that we are providing you with the care that you want).
  • Details of your life history (to ensure that we help you feel at home with us it is important for us to get to know you as best we can).
  • Information about your family and friends (for the purpose of visiting, next of kin and emergency contact details).
  • Information about external healthcare providers (such as your GP and practice details).
  • Information about your long term wishes (such your desired arrangements in the event that you pass away while staying with us).
  • Medical or health information including whether or not you have a disability
  • And because circumstances are variable and change with time, there may some instances where information is required outside the list above.

On whom do we hold data?

  • Resident

 

Finance

Why we use your information

Administering payments for your stay with us and making necessary checks to ensure that the care and accommodation is affordable.

Our lawful basis for using your information

  • legitimate interests (where they are not overridden by your rights).
  • It is necessary to perform our contract with you.

What information do we hold?

  • Personal details (such as name, date of birth, gender, marital status and dependents, national insurance number and copy driving license and passport).
  • Contact details (such as your previous address, personal telephone number and personal email address).
  • Financial information (such as your bank account details and information about your financial circumstances).

On whom do we hold data?

  • Resident
  • Potential Resident
  • Funder

 

Admin

Why we use your information

Administrative matters which are necessary for the day to day functioning of our organisation. This may occasionally include the prevention, detection and investigation of fraud and corruption.

Our lawful basis for using your information

  • It is necessary to perform our contract with you.
  • It is necessary to meet legal / regulatory obligations.
  • It is necessary for our legitimate interests (where they are not overridden by your rights).
  • It is necessary for us to provide you with healthcare as a resident.*

What information do we hold?

  • Personal details (such as name, date of birth, gender, marital status and dependents, national insurance number and copy driving license and passport).
  • Contact details (such as your previous address, personal telephone number and personal email address).
  • Financial information (such as your bank account details and information about your financial circumstances).

On whom do we hold data?

  • Resident
  • Potential Resident
  • Funder

 

Analysis and monitoring

Why we use your information

Analysing the well-being of our residents and monitoring diversity.

Our lawful basis for using your information

  • It is necessary to perform our contract with you.
  • It is necessary for our legitimate interests (where they are not overridden by your rights).
  • It is necessary to meet legal / regulatory obligations.
  • It is necessary for us to provide you with healthcare as a resident.*

What information do we hold?

  • Your likes and dislikes (relating to hobbies, food, routines and other categories of likes and dislikes which help us improve your care).
  • Information used for equal opportunities monitoring about your sexual orientation, religion or belief and ethnic origin
  • Medical or health information including whether or not you have a disability

On whom do we hold data?

  • Resident

 

Complaints

Why we use your information

Handling any complaints made, concerns raised.

Our lawful basis for using your information

  • It is necessary to perform our contract with you.
  • It is necessary for our legitimate interests (where they are not overridden by your rights).
  • It is necessary to meet legal / regulatory obligations.
  • It is necessary for us to provide you with healthcare as a resident.*

What information do we hold?

  • Personal details (such as name, date of birth, gender, marital status and dependents, national insurance number and copy driving license and passport).
  • Information about your care preferences (to ensure that we are providing you with the care that you want).
  • Information about your family and friends (for the purpose of visiting, next of kin and emergency contact details).
  • Medical or health information including whether or not you have a disability

On whom do we hold data?

  • Resident
  • Next of kin / family / friends / emergency contact / PoA

 

Safeguarding and regulation

Why we use your information

We use your personal data for the purpose of safeguarding and regulation of care.

Our lawful basis for using your information

  • It is necessary to perform our contract with you.
  • It is necessary to meet legal / regulatory obligations.
  • It is necessary for our legitimate interests (where they are not overridden by your rights).
  • It is necessary for us to provide you with healthcare as a resident.*

What information do we hold?

  • Personal details (such as name, date of birth, gender, marital status and dependents, national insurance number and copy driving license and passport).
  • Information about your care preferences (to ensure that we are providing you with the care that you want).
  • Information about your family and friends (for the purpose of visiting, next of kin and emergency contact details).
  • Medical or health information including whether or not you have a disability.

On whom do we hold data?

  • Resident
  • Next of kin / family / friends / emergency contact / PoA

 

Communication

Why we use your information

We will need to use your personal information to communicate with you before, during and after your stay with us. For example, when you telephone us, we may record those calls for monitoring purposes.

Our lawful basis for using your information

  • It is necessary to perform our contract with you.
  • It is necessary for our legitimate interests (where they are not overridden by your rights).

What information do we hold?

  • Personal details (such as name, date of birth, gender, marital status and dependents, national insurance number and copy driving license and passport).
  • Contact details (such as your previous address, personal telephone number and personal email address).

On whom do we hold data?

  • Potential Resident
  • Funder
  • Next of kin / family / friends / emergency contact / PoA

 

Improving our services

Why we use your information

We may ask you to voluntarily complete resident surveys to help us improve the services which we provide to you. When you telephone us, we may record those calls for training purposes.

Our lawful basis for using your information

  • We rely on your explicit consent for us to use your personal data.*

What information do we hold?

  • Personal details (such as name, date of birth, gender, marital status and dependents, national insurance number and copy driving license and passport).
  • Contact details (such as your previous address, personal telephone number and personal email address).

On whom do we hold data?

  • Resident
  • Next of kin / family / friends / emergency contact / PoA

 

Security

Why we use your information

We may need to capture images of you as part of our security processes such as use of CCTV footage.

Our lawful basis for using your information

  • It is necessary for our legitimate interests (where they are not overridden by your rights).
  • It is necessary for us to provide you with healthcare as a resident and for the management of health and social care services.*

What information do we hold?

  • Video and photographs of you (such as CCTV footage, photographs for security purposes, etc):

On whom do we hold data?

  • Resident
  • Next of kin / family / friends / emergency contact / PoA / visitors

 

Marketing

Why we use your information

We may issue you with newsletters or updates. We will only send you e-marketing where you have expressly consented to receive it.

Our lawful basis for using your information

  • We use telephone and postal marketing on the basis of our legitimate interests to promote the services we offer.
  • Where we wish to issue e-marketing, we will only issue it based on your consent.

What information do we hold?

  • Your contact details and marketing preferences.

On whom do we hold data?

  • Resident
  • Next of kin / family / friends / emergency contact / PoA / visitors

 

3rd Party Suppliers and Contacts

Why we use your information

We engage with a number of third-party suppliers such as hairdressers, physios and social workers in order to provide residents with the care that they need.

Our lawful basis for using your information

  • It is necessary for our legitimate interests and for the performance of a contract to engage with third party suppliers and collect information about those suppliers and contacts.

What information do we hold?

  • Contact details, visits to the care home, 3rd party supplier insurance details, PVG / security checks and CVs.

On whom do we hold data?

  • Social workers, third party suppliers

 

* This is an additional lawful basis which we need to rely on in order to use special categories of data such as information about your health

 

How long is it kept?

We are obliged by care regulators to maintain accurate records of care delivery and other data about those for whom we care. When a resident or patient leaves our service, we will archive that personal data in a secure storage facility (for paper records) and in a secure server (for electronic records). We will maintain it securely for no more than 8 years, unless a complaint or claim has been notified in which case we shall retain relevant data for the purpose of addressing that matter. From time to time, our insurers may request that data be held longer than 8 years for the purpose of an individual claim which concerns the data subject.

Where you are a potential resident or a visitor and do not enter into an ongoing relationship with us, we will hold your data for a period of 3 months following your last contact with us, unless there is a legitimate reason for us to hold that information for a longer period.