We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share your personal information. It also contains information about your rights in relation to it, and how to contact us or the Information Commissioner’s Office if you have a concern or complaint. It applies to information about applicants, residents, tenants, leaseholders and other service users.
Care Link is part of WDH, a registered charitable Community Benefit Society that provides social housing and support.
We believe whatever your age or state of health, or however vulnerable you might be, you are entitled to live with confidence in your own home. We offer a number of services to help you do this. Our services include community alarms and pendants, telecare sensors, response service, take a break service and home visiting service. We install, monitor and maintain our community alarms, pendants and telecare sensors.
So we can provide those services and help to maintain your wellbeing we need information about you. We are the ‘data controllers’ of that information. We determine, in most cases with your agreement, why and how it will be used, but we do not own it, it remains your information. You have rights and we have responsibilities.
Your basic right is that we must hold and use your information lawfully, fairly and transparently. This privacy notice which follows guidance given by the Information Commissioners Office is part of being transparent (open and clear) so you can check we are being lawful and fair.
We will avoid jargon but please note that ‘personal information' is information about you from which you can be identified whether directly or indirectly. Our use of your personal information includes obtaining, recording, using, sharing, holding and deleting it.
This notice tells you:
- who we are;
- what the information is;
- what we are doing, or might do with it and why;
- who we might share it with and why;
- the lawful basis for processing in each case;
- how long we will retain it;
- how we will keep it safe; and
- what your rights are.
We will process your information to provide you with support and to monitor and assess that support. In exceptional circumstances, we will process it in the public interest to safeguard you or others and/or to combat crime. We will also process it for equality and diversity purposes.
Those purposes are discussed below.
We will not sell your information or make it available to anyone for commercial use.
When we seek your consent, we will tell you what the information is, what we want to do with it and why. We will tell you who we might want to share it with and why. We must ensure your consent is freely given and is not the result of undue pressure from us or anyone else and you understand it can be withdrawn at any time.
Having said that, when a service is dependent on certain information being used or shared and you do not consent to that, the service may not be as good as it could be, or we may not be able to provide it at all.
Who we are
We are the controller of personal information and collect, use and are responsible for certain personal information about you. When we do so, we are regulated under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. Our contact details for data protection purposes are as follows.
Information Governance Team
The individual responsible for data protection compliance is our Data Protection Officer, who is contactable using the above details.
What information we collect
Care Link will collect the following information.
- Contact information including email address and phone number for each person living in the property.
- Doctor’s name and practice address.
- Medical conditions.
- Communication difficulties, such as hearing or speech impairment.
- Any care package you receive.
- Name, address and phone number of any next of kin and contacts you may have
- Diversity monitoring information such as gender, ethnicity, religion – you do not have to give us this information if you do not wish to.
- Date of birth.
- Photographic ID.
- Bank details.
- Benefits / council tax details.
- Disabilities or vulnerabilities.
- Call recordings from our contact centre.
- Your correspondence and communications with us.
- When you provide information about household members, we assume that you do so with their full knowledge and consent.
- We may hold other information about you for specific purposes for the services we provide. If you do not provide the information, we need then we may not be able to provide all our services to you.
How we use your information
In the course of our activities we need to collect, store and use personal information about you to enable us to deliver efficient and effective services to you including in the following areas.
- Carrying out research.
- Providing associated welfare services, advice and support.
- Maintaining our accounts and records.
- Supporting and managing our employees, agents and contractors.
- Promoting equal opportunities.
- Prevention and detection of crime and tacking antisocial behaviour.
- Keeping you informed of new products and services and to complete customer satisfaction surveys to help monitor performance and improve services.
- Where we carry out profiling to identify service or products that may be of interest to you.
- Dealing with complaints and any feedback from you.
- To comply with legal and regulatory obligations.
We collect most of this information directly from you in person by phone or email and / or through our website. However, we may also collect information from third parties such as health and social welfare agencies, the police and enquiries that are received from councillors, MPs or someone acting on your behalf.
We shall at all times implement and maintain appropriate technical and organisational measures to protect your data against accidental, unauthorised or unlawful destruction, loss, alteration, disclosure or access.
Special categories of personal data
We hold, collect and use special categories of personal information which includes:
- physical or mental health details;
- sexual life;
- sexual orientation;
- political opinions;
- trade union membership;
- ethnic origin;
- biometrics (where used for ID purposes); and
- religious or philosophical beliefs.
We use this information, which is more sensitive, to better understand your needs and provide a better service. We also use special category data to monitor equality, diversity and inclusion to ensure services are delivered appropriately, in order to comply with our legal and statutory duties under equality legislation and to meet our regulatory requirements.
We are committed to keeping your personal details up to date, and we encourage you to inform us about any changes needed to make sure your details are accurate.
Legal basis for processing your information
We collect and use your personal information because it is necessary for:
- the performance of our contract with you in order to manage services you have engaged with or to take steps at your request before entering into a contract;
- to comply with our legal and regulatory obligations;
- for our legitimate interests as a registered provider or those of a third party; and
- in order to protect the vital interests of you or another person.
We may also rely on your consent as a legal basis for processing your information. You have the right to withdraw consent. If we rely on consent and this is the only legal basis for processing, we will no longer process the data after consent is withdrawn.
Periods for which we will store your personal information
We will keep your personal data for no longer than necessary for the purposes that we have obtained it. We have a Records Retention Schedule which sets out how long we will keep different types of information. Once it is no longer necessary to continue processing your personal data, we will delete it or anonymise it.
We may use your personal information to send you updates (by email, text message, phone or post) about our products and / or services and of selected third parties.
We have a legitimate interest in processing your personal information for promotional purposes to promote our business to existing and former customers. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this separately and clearly.
We will always treat your personal information with the utmost respect and never sell it to other organisations outside Care Link for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by emailing email@example.com or using the ‘unsubscribe’ link in emails or the ‘STOP’ number in texts.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and / or services in the future, or if there are changes in the law, regulation, or the structure of our business.
Your personal information
We are committed to making sure that your privacy is protected. Any information you provide will be held securely and in line with the GDPR and the Data Protection Act 2018.
We will share personal information where required with:
- third parties we use to help deliver our products and or services to you, for example, payment service providers;
- credit reference agencies;
- our insurers and brokers;
- our bank;
- local authority teams such as social services, benefits agencies and council tax; and
- relevant statutory agencies such as Department for Work and Pensions and HMRC; and to comply with a legal requirement.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, for example in relation to ISO (International Organisation for Standardization) or Investors in People accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
How long we retain your personal data
We will not keep your personal information for any longer than it is needed and will dispose of it in a secure way. We will keep your information for the duration of the service plus one year.
Equality and diversity
We support and encourage equality and diversity, we oppose discrimination, and we protect and promote human rights.
In accordance with equality legislation we may ask you for your ‘protected characteristics’, namely, age, physical or mental disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and belief, sex and sexual orientation.
We ask for this information so we can give every group of people an equal opportunity to access our services and ensure all groups are benefiting from them.
You do not need to answer any questions you would prefer not to answer. We will only use any information you do give us for equality and diversity purposes. If we want information about your protected characteristics to help you as an individual, as opposed to as a member of group, we will ask for your consent separately.
The lawful basis is equality of opportunity and treatment under Schedule 1 of the Data Protection Act 2018.
You will find further information and advice on the website of the Equality and Human Rights Commission.
Under the GDPR you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal information;
- correct any mistakes in your information which we hold;
- the erasure of personal information concerning you in certain situations;
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
- object at any time to processing of personal information concerning you for direct marketing;
- object in certain other situations to our continued processing of your personal information; and
- otherwise restrict our processing of your personal information in certain circumstances.
If you would like to exercise any of those rights, please:
- email, call or write to us;
- let us have enough information to identify you (customer reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know the information to which your request relates.
Transferring your personal information out of the European Economic Area (EEA)
To deliver services to you, it may be necessary for us to share your personal information outside the EEA, for example if we were to use a cloud service provider based outside the EEA. These transfers are subject to special rules under European and UK data protection law. In such a situation, we will make sure that we have adequate safeguards and security measures in place as required by the GDPR.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The GDPR also gives you the right to complain to a supervisory authority, in particular in the European Union (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who can be contacted at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by phone on 0303 123 1113.
Visitors to our website
We take a proactive approach to user privacy and ensure that appropriate steps are taken to protect the privacy of users of our website.
For further details please see our Cookies Policy.
Changes to this privacy notice
WDH may change this policy from time to time by updating this page. You should check this page regularly so that you are aware of any changes. These will be made in line with any changes to the law.
How to contact us
Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us, please email firstname.lastname@example.org or write to our Information Governance Team, WDH, Merefield House, Whistler Drive, Castleford, WF10 5HX or email email@example.com or call us on 0345 8 507 507.
Do you need extra help?
We are committed to giving everyone equal access to information. If you would like this information in another format please phone us on 0345 8 507 507.