Care4All Privacy Notice
1.1 This privacy notice applies to all personal information processing activities carried out by Care4all.
1.2 Care4all is a data controller in respect of personal information that we process in connection with our business (including the services that we provide). In this notice, references to “we”, “us” or “our” are references to Care4all.
1.3 Our principal address is Grant Thorold Library, Durban Road, Grimsby, North East Lincolnshire, DN32 8BX.
1.4 We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with our business. “Personal information” means information about a living individual who can be identified from that information (either by itself or when it is combined with other information). We may update our Privacy Notice from time to time. When we do we will communicate any changes to you and publish the updated Privacy Notice on our website. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.
The information we process
2.1 We collect and process various categories of personal information at the start of, and for the duration of, your relationship with us. We will limit the collection and processing of information to information that is necessary to achieve one or more legitimate purposes as identified in this notice. What information we collect depends upon the type of service we provide to you. Personal information may include:
a) basic personal information, including name and address, date of birth and contact details;
b) financial information, such as payment information (including account payee) and history;
c) contact information for your next of kin, advocate (by advocate we mean someone named by you to help make decisions on your behalf or contact in cases of emergency) or corporate appointees;
d) services provided to you by Care4all;
e) information about other agencies involved with providing your care and support needs;
f) national insurance number, NHS number and internal reference numbers;
2.2 We may also process certain special categories of information for specific and limited purposes, to make our services accessible to all customers. We will only process special categories of information where we’ve obtained your explicit consent or are otherwise lawfully permitted to do so (and then only for the particular purposes and activities set out at Schedule A for which the information is provided). This may include:
a) information about racial or ethnic origin;
b) religious or philosophical beliefs;
c) physical or psychological health details or medical conditions.
How we obtain information
3.1 Your information is made up of all the personal information we collect and hold about you. It includes:
a) information you give to us;
b) information that we receive from third parties – including next of kin, advocates, corporate appointees and other service providers for example adult social care;
c) information that we learn about you through our relationship with you such as your general daily routines.
4.1 We want to make sure you are aware of your rights in relation to the personal information we process about you. We have described those rights and the circumstances in which they apply in the table below.
• we no longer need to process your information for the purposes for which it was provided;
• we have requested your permission to process your personal information and you wish to withdraw your consent; or
• we are not using your information in a lawful manner.
Please note that if you request us to delete your information, we may have to suspend the services we provide to you. We cannot always delete the information we hold about you if it is necessary to keep where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies.
• any of the information that we hold about you is inaccurate;
• we no longer need to process your information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or
• we are not using your information in a lawful manner.
Please note that if you request us to restrict processing your information,
we may have to suspend the services we provide to you.
Informed – You have the right to know what personal information we collect about you. This privacy notice states the types of personal information we process. Without prior permission we will not process any personal information that is not stated within this document.
Object – You have the right to object You may request for us to stop processing your personal information where we have stated the reason for processing is for a legitimate interest. In some cases we may still need to process your information in order to comply with current laws and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies.
If you wish to exercise any of these rights, if you have any queries about how we use your personal information that are not answered here, or if you wish to complain, please contact us at 01472 322944. Please note that in some cases, if you do not agree to the way we process your information, it may not be possible for us to continue to provide certain products and services to you.
Sharing with third parties
5.1 We will not share your information with anyone outside Care4all except:
a) where we have your permission;
b) where required for your service that we provide;
c) where we are required by law and by law enforcement agencies, judicial bodies, government
entities, tax authorities or regulatory bodies;
d) with third parties providing services to us, such as software providers;
e) with third-parties such as those listed as next of kin, advocates, corporate appointees and account payees;
f) in anonymised form as part of statistics or other aggregated data shared with third parties;
g) where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above, or
h) where we believe by not sharing the information, physical, emotional or mental harm may be caused to you or a third party.
5.2 If you ask us to, we will share information with any third party that provides you with services.
5.3 Care4all will not share your information with third parties for their own marketing purposes without your permission.
Communications about your services
6.1 We will contact you with information relevant to the delivery of your service (including updated information about how we process your personal information), by a variety of means including email, text message, post and/or telephone.
If at any point in the future you change your contact details you should tell us promptly about those changes.
6.2 We may monitor or record calls, emails, text messages or other communications in accordance
with applicable laws for the purposes outlined in Schedule A – Purposes of Processing.
How long we keep your information
7.1 By providing you with products or services, we create records that contain your information, such as customer account records and activity records. Records can be held on a variety of media (physical or electronic) and formats.
7.2 We manage our records to help us to serve our customers well (for example for operational reasons, such as dealing with any queries relating to your services) and to comply with legal and regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities.
7.3 Retention periods for records are determined based on the type of record, the nature of the activity, and service received. We normally keep customer records for up to six years after your relationship with the Care4all ends.
Retention periods may be changed from time to time based on business or legal and regulatory requirements.
7.4 We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies. This is intended to make sure that Care4all will be able to produce records as evidence, if they’re needed.
Schedule A – Schedule of Purposes of Processing
We will only use and share your information where it is necessary for us to carry out our lawful business activities. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail in a table below:
A Contractual necessity
We may process your information where it is necessary to enter into a contract with you for the provision of our services or to perform our obligations under that contract. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to provide services to you. This may include processing to:
a) assess and process applications for services;
b) provide those services throughout your relationship with us, including, collecting and issuing of all necessary documentation; executing your instructions; processing transactions, including transferring money between accounts; making payments to third parties; resolving any queries or discrepancies and administering any changes. Calls to our offices and communications with our staff may be documented and/or recorded and monitored for these purposes.
c) manage and maintain our relationships with you and for ongoing customer service.
When you request a service (and throughout your relationship with us), we are required to collect and process certain personal information about you. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to provide your services. This may include processing to:
a) share data with police, law enforcement, tax authorities or other government agencies including the NHS and adult social care
b) investigate and resolve complaints;
c) conduct investigations into breaches of conduct and policies by our employees;
d) manage contentious regulatory matters, investigations and litigation;
e) perform assessments and analyse customer data for the purposes of managing, improving and fixing data quality;
f) investigate and report on incidents or emergencies on Care4all’s properties and premises;
g) coordinate responses to business-disrupting incidents and to ensure facilities, systems and people are available to continue providing services.
C Legitimate interests of Care4all
We may process your information where it is in our legitimate interests to do so as an organisation and without prejudicing your interests or fundamental rights and freedoms:
a) We may process your information in the day-to-day running of our business, to manage our business and financial affairs and to protect our customers, employees and property. It is in our interests to ensure that our processes and systems operate effectively and that we can continue operating as a business. This may include processing your information to:
(i) monitor, maintain and improve internal business processes, information and data, technology and communications solutions and services;
(ii) ensure business continuity and disaster recovery and responding to information technology and business incidents and emergencies;
(iii) perform general, financial and regulatory accounting and reporting;
(iv) protect our legal rights and interests;
(v) manage and monitor our properties and branches (for example through CCTV) for the purpose of crime prevention and prosecution of offenders, for identifying accidents and incidents and emergency situations and for internal training.
b) It is in our interest as a business to ensure that we provide you with the most appropriate services and that we continually develop and improve as an organisation. This may require processing your information to enable us to:
(i) identify new business opportunities;
(ii) send you relevant marketing information (including details of other services provided by us or which we believe may be of interest to you);
(iii) understand our customers’ actions, behaviour, preferences, expectations, feedback and financial history in order to improve our services and to develop new services
(iv) monitor the performance and effectiveness of services;
(v) assess the quality of our customer services and to provide staff training. Calls to our service offices and other communications with our staff may documented and/or recorded
(vi) perform analysis on customer complaints for the purposes of preventing errors and process failures and rectifying negative impacts on customers.