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Privacy Policy

Version 2

Last Update: 14/10/2024

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 services users and staff. ‘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.

Services 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:

  • Your basic details and contact information e.g your name, address, date of birth and next of kin;
  • Your financial details e.g details of how you pay us for your care or your funding arrangements

We also record the following data which is classified as ‘special category’.

  • Health and social care data about you, which might include both your physical and mental health data
  • We may also record data about your race, ethnic origin, sexual orientation or religion

Our Care Connected Plexus viewer provides health and care professionals with a secure ‘electronic summary view’ of the information that organisers want to share about you. This provides the people looking after you with important information from other services that you use, so that they can quickly assess you and make the best decision or plans about your care.

The information which health and care organisations can share about you might include the following information:

  • Details about you, such as address, contact details and next of kin
  • Any contact the health or care provider has had with you, such as appointments, clinic visits, emergency appointments etc
  • Notes/reports and assessments about your health and care, including from some specialist services such as the Royal Marsden and Moorfield’s Eye Hospital
  • Details about your planned treatment and care
  • Results of investigations, such as blood tests, scans, x-rays etc
  • Relevant information from other health and care professionals, relatives or those who care for you
  • Care and support you may be receiving from Social Care services
  • Urgent care and NHS 111 visits/calls and London Ambulance Service calls

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.

The processing (sharing) of personal data in the delivery of direct care and for our administrative purposes is supported under the following Article 6 and 9 conditions of the: Data Protection Act 2018/General Data Protection Regulation 2016:

  • Article 6(1)(c) – necessary for the purposes of complying with law
  • Article 6(1)(d) – necessary for the purpose of vital interest (necessary to protect someone’s life)
  • Article 6(1)(e) – necessary for the performance of a task carried out in the public interest or in the exercise of official authority
  • Article 9(2)(h) – necessary for the purpose of preventative or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services

Health and social care services have a legal obligation to share information about you from their records if it is seen to be in your best interests for the purposes of your direct care.

Purpose for sharing data: Information will be shared in order to support your ‘direct care’.

‘Direct patient care’ is defined as ‘a clinical, social or public health activity concerned with the prevention, investigation and treatment of illness and the alleviation of suffering of individuals. It includes the supporting individuals’ ability to function and improve their participation in life and society. It includes the assurance of safe and high-quality care and treatment through local audit, the management of untoward or adverse incidents, person satisfaction including measurement of outcomes undertaken by one or more registered and regulated health or social care professionals and their team with whom the individual has a legitimate relationship for their care’.

In Summary

We process your data because:

  • We are required to do so in our performance of a public task;
  • We are required to do so in order to fulfil a contract that we have with you;
  • 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:

  • It is necessary due to social security and social protection law (generally this would be in safeguarding instances):
  • It is necessary for us to provide and manage social care services:
  • We are required to provide data to our regulator, the Care Quality Commission (CQC), as part of our public interest obligations

We may also process your data with 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.

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:

  1. You or your legal representative(s);
  2. Third parties

we do this face to face, via phone, via email, via post, via application forms.

Third parties are organisations we have a legal reason to share your data with. These include:

  • 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;
  • The Local Authority;
  • Organisations we have a legal obligation to share information with i.e for safeguarding the CQC;
  • The police or other law enforcement agencies if we have to by law or court order

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:

  • Your basic details and contact information e.g your name and address, phone numbers and 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 services and keeping emergency contact details for our staff.

We may also process your data with 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.

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:

  1. You or your legal representative(s);
  2. Third parties

We do this face to face, via phone, via email, via post, via application forms.

Third parties are organisations we have a legal reason to share your data with. These may include:

  • 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;
  • The Local Authority;
  • The police or other law enforcement agencies if we have to by law or court order

How we keep personal data safe?

  • Data is stored on various systems which have different ways of being kept safe and secure
  • Data stored on paper are kept in locked filing cabinets and can only be accessed by staff based on clearance level
  • Data stored on company PCs are not stored on local hard drives. All data is stored in OneDrive. Please see Microsoft’s Privacy policy
  • Residents data is held on a third party system known as Cura, this is backed up by them

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.

  1. 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;
  2. 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;
  3. 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. Social care records for adults are kept or disposed of in accordance with the Data Protection Act 1998 and the General Data Protection Regulations 2018 and are retained for at least three years from last date of entry. A copy of our data retention schedule is available on request.
  4. 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
  5. 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
  6. 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
  7. 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 personal 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

    ICO Website