This privacy notice provides you with details of how we collect and process your personal data.
Margaret House is the data controller and we are responsible for your personal data (referred to as “we”, in this privacy notice).
Our email address is firstname.lastname@example.org
Our postal address is Margaret House Church End, Barley, Royston SG8 8JS
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com
We need to collect the following sensitive data about each person who enquires about or becomes a resident in order to deliver the services
- Medical History
- Religious beliefs
- Sexual orientation
- Life History
We require your explicit consent for processing sensitive data and we will request your signature for this consent, or the consent of someone acting on your behalf this would normally be some holding Lasting Power of Attorny (LPA ) or an Independent advocate
2a. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at firstname.lastname@example.org
2b WHEN WE ARE BOTH CONTROLLER AND PROCESSOR
On occasions we will be holding information about you and we will also be processing this information. As a consequence, we will be performing both roles of both controller and processor. We will ensure that we will fulfil out respective roles and obligations in how we control and process your data.
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the below table.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you or your relative as a potential or new resident (enquiry)||(a) Identity|
(c ) Medical History
|Consent To ensure that we can provide the service|
|To process and deliver you or your relative’s care including:|
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests to invoice for services provided.
|To manage your or your relative’s care which will include:|
(a) Setting up and then maintaining a personalised care plan
|(a) Performance of a contract with you|
(b) Necessary to comply with Care Commissioners, Local Authority & CQC requirements
(c) Vital Interest where the data subject is physically or legally incapable of giving consent
|To manage our relationship with you as the relative of the resident|
|To ensure we know who is on the premises at all times|
|To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise|
(b) Necessary to comply with a legal obligation
|To deliver relevant content to you and advertisement and marketing materials to prospective new clients and measure and understand the effectiveness of our advertising|
|Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow and promote our business and to inform our marketing strategy|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical|
|Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy|
You will receive marketing communications from us if you have:
- requested information from us or purchased services from us; or
- if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
- in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us at firstname.lastname@example.org or by contacting the Home Manager on 01763 848272
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, service experience or other transactions.
- DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 2 above:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- CQC, Care Commissioners & Local Authority
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
- INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
We currently use Dropbox to store our data and Xero for our accounting purposes. For both of these organisation, some of their services or servers are based in the USA. However, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes and CQC require that we keep information on residents for seven years after they cease being customers.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- COOKIE POLCY
Cookies are small text files that are placed on a website visitor’s computer or mobile device by the web server, and which assign an anonymous, unique identifier to the web browser.
Cookies are either “persistent”, in which case they are stored by the browser until a set expiry date e.g. 10 years unless deleted by the user, or “session” which expire when the browser is closed.
For privacy reasons, most browsers only allow a website to access cookies already sent to you, and not cookies sent by other websites.
Most browsers allow you to refuse to accept cookies and to delete cookies. Please check your own browser settings if you wish to do this. If you prefer not to receive cookies while browsing our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence.
Please note that certain website features on this and other websites may not function properly if cookies are not enabled.
More information about cookies is available at https://ico.org.uk/for-the-public/online/cookies/.