Cooper Noble care work under the legal obligations and conditions of both the principles of the new Data protection Act and the Articles of the European General Data Protection Regulations [GDPR]. Whilst the majority of GDPR is similar to the original Data Protection Act it has provided a fundamental change on how organisations providing adult social care and health process your data.For services users, Article 9 of the GDPR now allows us and other authorised agencies to collect and share your information without consent, but ONLY in order to deliver the care and support you require as defined under the Care Act. We will act in the capacity of both a data controller and data processor when dealing with personal information relating to staff, service users and third party information that we are authorised to process
As the ‘controller’ of your personal information, we will ensure that the personal information we hold about you is:
- Used lawfully, fairly and in a transparent way
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
- Relevant to the purposes we have told you about and limited only to those purposes
- Accurate and kept up to date
- Kept only as long as necessary for the purposes we have told you about
- Kept securely
Information collected by us:
When you enquire about our care and support services through our website, phone, email, post, face to face or social media, and during the course of providing care and support services to you we collect the following personal information when you provide it to us:
- Your name, home address, date of birth and contact details (including your telephone number, email address) and emergency contacts (i.e. name, relationship and home and telephone numbers)
- Your allergies and any medical, physical or mental conditions and in particular your care needs
- Your likes, dislikes and lifestyle preferences (including your religious beliefs or other beliefs of a similar nature, racial or ethnic origin, politics, genetics, health, marital status and sexuality, trade union membership or biometrics (so far as they relate to providing you with suitable care)
- Credit, direct debit details or other payment information (if you pay for some or all of our services using one of these methods)
- Your feedback and contributions to questionnaires and surveys about the service we offer
- Your complaints, compliments or concerns about the service we provide
- Any accidents and incidents or near misses you may have been involved in whist on our premises or whilst our employees are delivering a regulated service to you – this may include details of injuries and treatment you may have received.
When using our website, we collect standard internet log information (commonly known as cookiesThis is statistical information only which we collect in order to find out the numbers of visitors to our site and the pages they have visited. This information collected in such a way that it is not used to identify individuals. Where we do collect personal information on the website, this will be made obvious to you through the relevant pages. Please be aware that our website may provide you with links to other websites. If you follow a link to any other website please note they have their own privacy promises. We do not accept any responsibility or liability for the privacy and security practices of such third-party websites and your use as such is at your own risk.
Information collected from other sources:
We work closely with third parties such as social and healthcare professionals and public bodies. We therefore also obtain personal information about you from other sources such as:
- Your allergies and any medical, physical or mental conditions, test results and in particular your care and support needs, from any appropriate external social or health care professionals (including your GP)
- Your name, home address, date of birth, contact details, needs assessments and financial assessments from any appropriate external social or health care professionals (including any relevant public body regardless of whether you are publicly funded)
- Your likes, dislikes and lifestyle preferences (including your religious beliefs or other beliefs of a similar nature, racial or ethnic origin, politics, genetics, health, sex life, marital status and sexuality trade union membership or biometrics (so far as they relate to providing you with suitable care)) from your family, friends and any other person you have nominated as your representative
- Your legal representative (for example Lasting Power of Attorney), if applicable
How we use your personal information:
We use your personal information to:
- Prepare, review and update a suitable care plan, describing the nature and level of care and support services which you have requested we supply to you
- To communicate with you, your representatives and any appropriate external social or health care professionals about your individual needs and personalise the service delivered to you
- Make reasonable adjustments, when required, to meet your individual needs and to ensure we have suitable facilities to ensure your safety
- Invoice you for the care and support services in accordance with our terms and conditions
- Carry out quality assurance procedures, review our service and improve our customer experience (please note that feedback can also be provided anonymously)
- Send information about our services which we believe you may be interested in. You may unsubscribe from this at any time
- Notify you about changes to our services which are relevant to you
- Monitor how effective our services are and to make sure that the services we provide meet your needs
- Improve your experience of our website and to ensure that the content is presented in the most effective way.
Who we share your personal information with:
We share your medical information with appropriate external social or health care professionals (including your GP and pharmacist) and any individuals you have nominated as your representative as and when required. This data sharing enables us to establish the type of care and support you need. It also allows us to design the right care package to suit your individual circumstances, including if (in future) you decide to receive care from an alternative provider. We will share personal information with law enforcement or other authorities if legally required to do so. This includes information required by public bodies to evidence our compliance with the applicable regulatory framework. We are also required to share personal information with external social or health care professionals, including public bodies and local safeguarding groups (in some circumstances) to ensure your safety.
We will not share, sell or trade your personal information with any other third party without your explicit and informed consent.
In order to deliver our service to you we rely on third parties to provide specialist support to us. To provide this support they will have access to, or a duty of care over your personal information. These providers are:
- IT and Telecoms Support companies – to ensure the safe, secure and resilient operation of our IT infrastructure including computers, servers, phones and mobile devices
- Software support companies – to provide specialist support and resolve issues with the software that we run, for example the systems we use to store and manage your customer records
- Marketing systems providers – to organise marketing communications and for the delivery and analysis of email communications
Keeping your personal information secure:
- We will hold the personal information kept within your electronic customer file for the length of your contract
- We will hold the personal information kept within your hard copy customer files for years from the date of the last entry
- We will hold financial records and transactions in line with our legal requirements
Who we share your personal information with:
The confidentiality and security of your information is of paramount importance to us. We have appropriate organisational and technical 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.
As with the Data Protection Act, GDPR provides all data subjects with a number of very specific rights regarding your information
these include rights to:
- Fair processing of information and transparency over how we use your use personal information
- Access to your personal information and to certain other supplementary information that this Privacy Promise is already designed to address
- Require us to correct any mistakes in your information which we hold
- Require the erasure (i.e. deletion) of personal information concerning you, in certain situations. Please note that if you ask us to delete any of your personal information which we believe is necessary for us to comply with our contractual or legal obligations, we may no longer be able to provide care and support services to you
- 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 to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- Object in certain other situations to our continued processing of your personal information
- Otherwise restrict our processing of your personal information in certain circumstances
- Claim compensation for damages caused by our breach of any data protection laws
All the above rights have ‘terms and conditions’ and in some cases may adversely affect our ability to provide the services you require. We would advise you contact us prior to exercising any of the above
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
How to contact us:
You can contact us by:
- Email – firstname.lastname@example.org email@example.com
- Post – Cooper Noble Care Ltd, Head Office, 84 Windsor St, Liverpool L8 8EQ
- Telephone – 07813 652017 07889 866475
If you would like to exercise any of those rights, please:
- Contact us using the details above – making clear that you wish to exercise one of your privacy rights
- Let us have enough information to identify you (e.g. your name and address)
- 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)
- Let us know the information to which your request relates, including any account or reference numbers, if you have them
We are only obliged to provide you with information we are processing as data controllers, the release of third party information can only be carried out once we have received permission 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 right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) 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 may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
Changes to this privacy notice:
We may change this privacy notice from time to time, when changes are significant we will draw your attention to this via email and on our website.