Introduction
As part of the services we offer, we are required to process personal data about our staff, our service users and, in some instances, the friends or relatives of our service users and staff. In the course of our business we are also required to process data about Directors/Trustees, members of the Company and some suppliers. “Processing” can mean collecting, recording, organising, storing, sharing or destroying data.
We are committed to providing transparent information on why we need your personal data and what we do with it. This information is set out in this privacy notice. It will also explain your rights when it comes to your data.
We do not need consent for processing personal data in the ways described in this privacy notice. However, if we were to process personal data for any different reason we may need your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent.
Your rights
The data that we keep about you is your data and we ensure that we keep it confidential and that it is used appropriately. You have the following rights when it comes to your data:
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You have the right to request a copy of all of the data we keep about you. Generally, we will not charge for this service;
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You have the right to ask us to correct any data we have which you believe to be inaccurate. You can also request that we restrict all processing of your data while we consider your rectification request;
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You have the right to request that we erase any of your personal data which is no longer necessary for the purpose we originally collected it for. We retain our data in line with our record keeping policy and only for as long as it is needed. A copy of this is available upon request.
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You may also request that we restrict processing if we no longer require your personal data for the purpose we originally collected it for, but you do not wish for it to be erased.
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You can ask for your data to be erased if we have asked for your consent to process your data. You can withdraw consent at any time – please contact us to do so.
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If we are processing your data as part of our legitimate interests as an organisation or in order to complete a task in the public interest, you have the right to object to that processing. We will restrict all processing of this data while we look into your objection.
You may need to provide adequate information for our staff to be able to identify you, for example, a passport or driver’s licence. This is to make sure that data is not shared with the wrong person inappropriately. We will always respond to your request as soon as possible and at the latest within one month.
If you would like to complain about how we have dealt with your request, please contact:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
https://ico.org.uk/global/contact-us/
Service Users
What data do we have?
So that we can provide a safe and professional service, we need to keep certain records about you. We may record the following types of data about you:
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Your basic details and contact information e.g. your name, address, date of birth, and next of kin;
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Your financial details e.g. details of how you pay us for your care or your funding arrangements. Information on your National Insurance number, state benefits and personal bank details depending on the level with which we support you with managing your finances.
We also record the following data which is classified as “special category”:
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Health and social care data about you, which will include gender, ethnicity and your physical and mental health data. This will include your NHS number and any medical test results that we should be aware of in order to provide you with appropriate care including COVID-19 swab and antibody test results and COVID-19 vaccinations.
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We may also record data about your sexual orientation or religion.
Why do we have this data?
We require this data so that we can provide high quality care and support. By law, we need to have a lawful basis for processing your personal data.
We process your data because:
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We are required to do so in our performance of a public task (to fulfil a contract with a Local Authority or the NHS);
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We are required to do so in order to fulfil a contract that we have with you;
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We have a legal obligation to do so – generally under the Health and Social Care Act 2012 or Mental Capacity Act 2005.
We process your special category data because:
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It is necessary due to social security and social protection law (generally this would be in safeguarding instances);
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It is necessary for us to provide and manage social care services, including following government guidelines regarding COVID-19 testing and COVID-19 vaccinations.
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We are required to provide data to our regulator, the Care Quality Commission (CQC), as part of our public interest obligations.
Where do we process your data?
So that we can provide you with high quality care and support we need specific data. This is collected from or shared with:
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You or your legal representative(s);
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Third parties.
We do this face to face, via phone, via email, via post, via secure websites.
Third parties are organisations we have a legal reason to share your data with. These include:
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Other parts of the health and care system such as local hospitals, the GP, the pharmacy, social workers, clinical commissioning groups, NHS COVID-19 swab and antibody testing and vaccinations systems and other health and care professionals;
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The Local Authority;
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Organisations we have a legal obligation to share information with i.e. for safeguarding, the CQC;
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The police or other law enforcement agencies if we have to by law or court order.
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Third parties who provide or manage IT software systems or hardware on our behalf, solely for the purpose of providing and managing social care services.
Staff
What data do we have?
So that we can provide a safe and professional service, we need to keep certain records about you. We may record the following types of data about you:
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Your basic details and contact information e.g. your name, address, date of birth, home and mobile telephone numbers, email address, National Insurance number and next of kin;
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Your financial details e.g. details so that we can pay you, pension and tax details;
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Your training records.
We also record the following data which is classified as “special category”:
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Gender, race and ethnicity.
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Health and social care data about you including your NHS number and possibly including data on both your physical and mental health data. We will only collect this if:
– it is necessary for us to know as your employer, e.g. fit notes or in order to claim statutory maternity pay.
– if it is necessary for us to know because we are providing health and social care, and/or in the management of social care systems and services, e.g. results of a COVID-19 swab or antibody test, flu and COVID-19 vaccination records.
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Criminal Record Data.
Why do we have this data?
We require this data so that we can contact you, pay you and make sure you receive the training and support you need to perform your job. We also require the data in order for us to provide and manage social care services. By law, we need to have a lawful basis for processing your personal data.
We process your data because:
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We have a legal obligation under UK employment laws;
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We are required to do so in our performance of a public task (to fulfil a contract with a Local Authority);
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We have a legitimate interest in processing your data – for example, we provide data about your training to Skills for Care’s National Minimum Data Set, this allows Skills for Care to produce reports about workforce planning.
We process your special category data because:
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It is necessary due to social security and social protection law – we are required to perform Disclosure and Barring Service (DBS) checks on our staff;
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It is necessary for us to process requests for sick pay or maternity pay;
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It is necessary for us to provide and manage social care services, including participating in the government’s COVID-19 testing strategies for health and social care, and COVID-19 vaccination programmes;
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We are required to provide data to our regulator, the Care Quality Commission (CQC), as part of our public interest obligations.
Where do we process your data?
As your employer we need specific data. This is collected from or shared with:
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You or your legal representative(s);
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Third parties.
We do this face to face, via phone, via email, via post, via secure websites.
Third parties are organisations we have a legal reason to share your data with. These include:
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Her Majesty’s Revenue and Customs (HMRC);
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NHS for the purposes of COVID-19 swab and antibody testing, COVID-19 vaccinations;
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Our pension and healthcare schemes: Standard Life, The People’s Pension, AXA PPP Healthcare;
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Organisations we have a legal obligation to share information with i.e. for safeguarding, the CQC;
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The police or other law enforcement agencies if we have to by law or court order.
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Third parties who provide or manage IT software systems or hardware on our behalf, solely for the purpose of providing and managing social care services.
Friends/Relatives
What data do we have?
As part of our work providing high-quality care and support, it might be necessary that we hold the following information on you:
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Your basic details and contact information e.g. your name and address; telephone numbers, email addresses.
Why do we have this data?
By law, we need to have a lawful basis for processing your personal data.
We process your data because we have a legitimate business interest in holding next of kin and lasting power of attorney information about the individuals who use our service and keeping emergency contact details for our staff.
Where do we process your data?
So that we can provide high quality care and support we need specific data. This is collected from or shared with:
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You or your legal representative(s);
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Third parties.
We do this face to face, via phone, via email, via post.
Third parties are organisations we have a legal reason to share your data with. These may include:
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Other parts of the health and care system such as local hospitals, the GP, the pharmacy, social workers, clinical commissioning groups, and other health and care professionals;
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The Local Authority;
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The police or other law enforcement agencies if we have to by law or court order.
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Third parties who provide or manage IT software systems or hardware on our behalf, solely for the purpose of providing and managing social care services.
Directors/Trustees
What data do we have?
So that we can fulfil our legal duties as a Company, a body regulated by the CQC and as a registered charity, we need to keep certain records about you. We may record the following types of data about you:
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Your basic details and contact information e.g. your name, address, date of birth, telephone number, email address;
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Your training records where relevant to your role as a Director/Trustee.
We also record the following data which is classified as “special category”:
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Health and social care data about you, which might include both your physical and mental health data – we will only collect this if it is necessary for us to know as it may affect your ability to fulfil your role;
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We may also record data about your race and ethnic origin;
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Criminal Record Data.
Why do we have this data?
We require this data so that we can contact you and make sure you receive the information and support you need to perform your role. We also need the information to maintain records regarding Directors/Trustees in accordance with laws and regulations. By law, we need to have a lawful basis for processing your personal data.
We process your data because:
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We have a legal obligation under UK Company laws (Companies Act 2006), Charity law and Health and Social Care regulations under the Health and Social Care Act 2008.
We process your special category data because:
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It is necessary because under regulations we are required to perform Disclosure and Barring Service (DBS) checks on our Directors/Trustees;
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We are required to provide data to our regulator, the Care Quality Commission (CQC), as part of our public interest obligations.
Where do we process your data?
So that we can fulfil our duties your data is collected from or shared with:
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You or your legal representative(s);
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Third parties.
We do this face to face, via phone, via email, via post, via secure websites.
Third parties are organisations we have a legal reason to share your data with. These include:
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Companies House;
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Organisations we have a legal obligation to share information with i.e. for safeguarding, the CQC;
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The police of other law enforcement agencies if we have to by law or court order.
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Third parties who provide or manage IT software systems or hardware on our behalf, solely for the purpose of providing and managing social care services.
Members
What data do we have?
So that we can fulfill our legal duties as a Company, we need to keep certain records about you. We may record the following types of data about you:
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Your basic details and contact information e.g. your name, address, date of birth, telephone number, email address;
Why do we have this data?
By law, we need to have a lawful basis for processing your personal data.
We require this data so that we can contact you and make sure you receive the information and support you need to perform your role. We also need the information to maintain records regarding Members in accordance with laws and regulations.
We process your data because:
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We have a legal obligation under UK Company laws (Companies Act 2006).
Where do we process your data?
So that we can fulfil our duties your data is collected from or shared with:
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You or your legal representative(s);
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Third parties.
We do this face to face, via phone, via email, via post, via secure websites.
Third parties are organisations we have a legal reason to share your data with. These include:
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Companies House;
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Organisations we have a legal obligation to share information with i.e. for safeguarding, the CQC;
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The police or other law enforcement agencies if we have to by law or court order.
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Third parties who provide or manage IT software systems or hardware on our behalf, solely for the purpose of providing and managing social care services.
Our website
In order to provide you with the best experience while using our website, we process some data about you.
When someone visits https://polesworthhomes.co.uk we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. You can find more information on how cookies are used on this website in the Cookies Policy below.
If we do want to collect personally identifiable information through our website, we will be explicit about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
We don’t share, rent or trade email lists with other organisations or businesses. We gather statistics around clicks using industry standard technologies to help us monitor and improve our website.
Links to other websites
This privacy notice does not cover the links within our website linking to other websites. Those sites are not governed by this Privacy Policy, and if you have questions about how a site uses your information, you’ll need to check that site’s privacy statement.
Cookies
We use a system of classifying the different types of cookies which we use on the website, or which may be used by third parties through our websites. The classification was developed by the International Chamber of Commerce UK and explains more about which cookies we use, why we use them, and the functionality you will lose if you decide you don’t want to have them on your device.
What is a cookie?
Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.
How long are cookies stored for?
Persistent cookies – these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
Session cookies – these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience.
Cookies used on the website
A list of all the cookies used on the website by category is set out below:
- Strictly necessary cookies -These cookies enable services you have specifically asked for. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website.
- Performance cookies –These cookies collect anonymous information on the pages visited. By using the website, you agree that we can place these types of cookies on your device. These cookies collect information about how visitors use the website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the website works.
- Functionality cookies– These cookies remember choices you make to improve your experience. By using the website, you agree that we can place these types of cookies on your device. These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
- Third party cookies -These cookies allow third parties to track the success of their application or customise the application for you. Because of how cookies work we cannot access these cookies, nor can the third parties access the data in cookies used on our site. For example, if you choose to ‘share’ content through Twitter or other social networks you might be sent cookies from these websites. We don’t control the setting of these cookies, so please check those websites for more information about their cookies and how to manage them.
Updated March 2021