This Privacy Policy sets out how we, at The Wedge Residential Care Home collect, store and use information about you when you use or interact with our website, http://www.haylingwedge.co.uk (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 1st July 2018.
For the purpose of the Data Protection Act 1998 the data controller is The Wedge Residential Care Home. 8 Park Road, Hayling Island, Hants PO11 0HU.
Contents
This section is intened to provide a general overview as to how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and must be read in conjunction with the corresponding full sections of this Privacy Policy.
- Data controller: The Wedge Residential Care Home
- How we collect or obtain information about you:
- Information we collect: IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on the geographical location from which you accessed our website (based on your IP address), additional personal information provided to us by e-mail or telephone following a visit to our website to enable us to understand your needs and ensure that we can provide you with an appropriate service.
- How we use your information: for administrative and business purposes (particularly to contact you, to improve our business and website, to fulfil our contractual obligations, to analyse your use of our website, and in connection with our legal rights and obligations.
- Disclosure of your information to third parties: only where required by law or to enforce our legal rights
- Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
- How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
- How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where legally necessary.
- Use of cookies and similar technologies: We do not currently use cookies and similar information-gathering technologies on our website but reserve the right to do so at a later stage at which stage this policy would be updated.
- Transfers of your information outside the European Economic Area: we will only transfer your information outside the European Economic Area if we are required to do so by law.
- Use of automated decision making and profiling: We do not use automated decision making and/or profiling.
- Your rights in relation to your information:
- Sensitive personal information: we do not knowingly or intentionally collect from our website what is commonly referred to as ‘sensitive personal information’. Sensitive inforrmation concerning your health to asses your needs may be gathered in follow up e-mails or telephone calls however your express permission to gather that information is required. For more information, please see the main section below entitled Sensitive Personal Information
Our details
The data controller in respect of our website is The Wedge Residential Care Home. 8 Park Road, Hayling Island, Hants PO11 0HU. You can contact the data controller by writing to The Wedge Residential Care Home. 8 Park Road, Hayling Island, Hants PO11 0HU or sending an email to maceyjoanna@aol.com
If you have any questions about this Privacy Policy, please contact the data controller.
Information we collect when you visit our website
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web server log information
We use a third party server to host our website called Cut.co.uk Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as, the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.
Our server is located in the UK.
Use of website server log information for IT security purposes
We AND/OR our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.
Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with a care package or taking steps at your request prior to providing you with our Care Package, we will process your information in order to do so).
Transfer and storage of your information
We use a third party email provider to store emails you send us. Our third party email provider is AOL.
Emails you send us will be stored outside the European Economic Area on our third party email provider’s servers in USAwhere your third party email provider stores your emails (usually where its servers are located)] . For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area
.
When You Contact us by Phone
We collect your phone number and any information provided to us during your conversation with us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with Care services or taking steps at your request prior to providing you with our Care services (for example, providing you with information about our services), we will process your information in order to do so).
Post
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Information we collect when you interact with our website
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information
.
Information collected or obtained from third parties
This section sets out how we obtain or collect information about you from third parties.
Information received from third parties
We may collect your personal information from your relative in order to discuss your care provided we have your permission for them to provide information to us.
We may collect this information from a Health Care Professional in the event that you come to us via a health provider (such as the NHS or Social Services).
In circumstances where care costs are being covered in part or full by an individual (or individuals) other than the person receiving the care (our resident), then it will be necessary to process the personal information of all individuals involved in the care provision, both those receiving and those responsible for the financial aspects. We will of course limit the personal data to the minimum information necessary for us to undertake those activities requiring that information.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party shares information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a contract with a third party, where the third party holds a valid power of attorney. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
Where we receive information about you in error
If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
Disclosure and additional uses of your information
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business. These include the following:
• Telephone provider(s),
• Email provider(s), including. AOL
• IT service provider(s]
• Web developer(s),
• Hosting provider(s)
• GP, Medical Assessment, Occupational Health: . In the case of you being a resident, this will be necessary to ensure that we can meet your needs initially and on an ongoing basis. This is on the basis of protecting your vital interests as well as those of our staff and clients.
• Health Care providers in the event of an emergency: To ensure that in the event you become unwell we are able to provide the necessary information to assist with you receiving the necessary medical attention. This is to protect your vital interests
Apart from e-mail processors which are located in the USA, our service providers are located in the UK.
Your information will be shared with these service providers only where necessary to provide you with the service you have requested.
We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Disclosure of your information to other third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, business partners, independent contractors, and insurers. Further information on each of these third parties is set out below.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.
Accountants
We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.
Our accountants are Bramil Associates. Their privacy policy is available upon request.
Insurers
We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business effectively.
Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.
Disclosure and use of your information for legal reasons
Occassionaly it is necessary to disclose your information for legal reasons examples of the se include:
Preventing crime or suspected criminal activity (such as fraud).
Resolving disputes and potential disputes
For ongoing compliance with laws, regulations and other legal requirements. We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.
Legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).
Where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
How long we retain your information
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Retention periods
Server log information: we retain information on our server logs for 1 month
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email, or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 3 further years(s) after which point we will delete your information.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
• the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
• whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
• any relevant agreed industry practices on how long information should be retained;
• any relevant surrounding circumstances (such as the nature and status of our relationship with you).
How we secure your information
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
• using secure servers to store your information
• verifying the identity of any individual who requests access to information prior to granting them access to information;
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Transfers of your information outside the European Economic Area
Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
e-mail Processing:
Information you submit to us via our e-mail is transferred outside the EEA and stored on our third party provider’s servers. Our e-mail provider is AOL Part of the Oath Group a Verizon company You can access their privacy policy here: https://policies.oath.com/ie/en/oath/privacy/index.html
Country of storage: [USA]. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our e-mail provider has self-certified its compliance with the EU-U.S. Privacy Shield which is available here:
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to The Wedge Residential Care Home, 8 Park Road, PO11 9PG Hayling Island or sending an email to maceyjoanna@aol.com
• to request access to your information and information related to our use and processing of your information;
• to request the correction or deletion of your information;
• to request that we restrict our use of your information;
• to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
• to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
• to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/
Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
• https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Your right to object to the processing of your information for certain purposes
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to The Data Controller, The Wedge Residential Care Home, 8 Park Road, Hayling Island or sending an email to maceyjoanna@aol.com
You have the right to to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
• to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
• clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
• sending an email to maceyjoann@aol.com asking that we stop sending you marketing communications or by including the words “OPT OUT”.
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here:
Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
With your explicit consent or the explicit consent of a person holding a valid power of attorney or in somse cases a relative that you have given explicit consent to talk to us we do gather sufficient personal health information in order that we can asses your physical needs to ensure that we can provide the services that you need to provide you with the quality of care that you will need if you become a resident of our care home.
If, however, you inadvertently or intentionally transmit sensitive personal information to us that we do not need you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Children’s Privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers.
If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to maceyjoanna@aol.com
