EXTERNAL PRIVACY POLICY




INTRODUCTION

Coate Water Care is committed to being transparent about how it collects and uses the personal data of its residents and to meeting its data protection obligations. This policy sets out Coate Water Care's commitment to data protection, and individual rights and obligations in relation to personal data.

This policy applies to the personal data of residents and former residents, referred to as Resident-related. Where the term Individual is mentioned this applies to a resident and where that resident has appointed a Power of Attorney the same processes apply.

Regarding Powers of Attorney, Coate Water Care will always need to verify the type of permissions allowed under the Power of Attorney (Financial, Health, Enduring) and that it is duly signed and registered where appropriate.

DATA PROTECTION PRINCIPLES


Coate Water Care processes Resident-related personal data in accordance with the following data protection principles:

  • Coate Water Care processes personal data lawfully, fairly and in a transparent manner.
  • Coate Water Care collects personal data only for specified, explicit and legitimate purposes.
  • Coate Water Care processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
  • Coate Water Care keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
  • Coate Water Care keeps personal data only for the period necessary for processing.
  • Coate Water Care adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.
  • Coate Water Care tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons. Where Coate Water Care relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.

Where Coate Water Care processes special categories of personal data to perform obligations or to exercise rights in law, this is done in accordance with a policy on special categories of data and criminal records data

Coate Water Care will update Resident-related personal data promptly if an individual advises that his/her information has changed or is inaccurate.

Personal data gathered during the residents time with Coate Water Care is held securely in hard copy or electronic format, or both, and on paper-based or electronic systems. The periods for which Coate Water Care holds Resident-related personal data are contained in its privacy notices.

Coate Water Care keeps a record of its processing activities in respect of Resident-related personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

INFORMATION YOU GIVE TO US


"Personal data" is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it. This data we will be obtaining is;

Identity data and medical data – name / date of birth / gender / contact details / financial information such as bank account details / next of kin / NI number / title / marital status / employment history / medical and health related data including medical records.

'SPECIAL CATEGORY’ DATA


"Special categories of personal data" means information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data. Specifically this may include – medical information or photos.

HOW WE COLLECT YOUR PERSONAL INFORMATION


Personal data gathered during the Residents stay with us is held in the individual's Care Plan, resident file (in hard copy or electronic format, or both), and on Finance based systems.

We also may collect information from Third Parties such as Doctors, Nurses, health professionals, social workers, hospitals and other medical/health agencies.
 

HOW WE USE YOUR PERSONAL INFORMATION


Where Coate Water Care relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals. Coate Water Care processes care related personal data to accurately ensure we comply with Regulatory practices in the Care Sector and to ensure we provide the appropriate care to the Resident.

Coate Water Care will only use special category data if we have explicit consent or we need to comply with legal or regulatory obligations, for reasons of substantial public interest/ previously made it public knowledge/use to establish, exercise of defend legal claims or protect vital interests.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL INFORMATION


Coate Water Care processes personal data lawfully, fairly and in a transparent manner to undertake its responsibilities and for regulatory purposes. Coate Water Care collects personal data only for specified, explicit and legitimate purposes in regards to running Coate Water Care and to meet its regulatory obligations.

WHAT IF YOU CANNOT OR WILL NOT PROVIDE US WITH YOUR PERSONAL INFORMATION


In these cases please discuss this with the Home Manager.

COOKIE POLICY


A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. Find out more about cookies on www.allaboutcookies.org. We use cookies to identify you when you visit this website and to keep track of your browsing patterns and build up a demographic profile.

Most browsers will allow you to turn off cookies. If you want to know how to do this please look at the menu on your browser, or look at the instruction on www.allaboutcookies.org. Please note however that turning off cookies will restrict your use of our website.

We only use cookies when accessing the Coate Water Care website.

DISCLOSURE OF YOUR INFORMATION


Coate Water Care takes the security of Resident personal data seriously. Coate Water Care has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.

Where Coate Water Care engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical measures to ensure the security of data.

Some of the processing that Coate Water Care carries out may result in risks to privacy. Where processing would result in a high risk to individual's rights and freedoms, Coate Water Care will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include third parties such as; professional advisers / next of kin / the CQC, Social Workers, a County Council, the NHS, medical and health professionals.

This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.


WHERE WE STORE YOUR PERSONAL INFORMATION


Personal data gathered during the Residents stay with us is held in the individual's Care Plan, resident file (in hard copy or electronic format, or both), and on Finance based systems. The data is password protected and securely stored in lockable cabinets accessible by only authorised individuals.


HOW LONG WE WILL STORE YOUR PERSONAL INFORMATION


The periods for which Coate Water Care holds Resident related personal data are contained in its privacy notices. We will not hold data for longer than is necessary by statute or regulatory reasons. Coate Water Care keeps personal data only for the period necessary for processing

YOUR RIGHTS


As a data subject, individuals have a number of rights in relation to their personal data.

  • Individuals have the right to make a subject access request. If an individual makes a subject access request, Coate Water Care will tell him/her:
  • whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
  • to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
  • for how long his/her personal data is stored (or how that period is decided);
  • his/her rights to rectification or erasure of data, or to restrict or object to processing;
  • his/her right to complain to the Information Commissioner if he/she thinks Coate Water Care has failed to comply with his/her data protection rights; and whether or not Coate Water Care carries out automated decision-making and the logic involved in any such decision-making.

Coate Water Care will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.

All data requests will take account of legislation regarding access to the data under the relationship of the residents family, capacity assessments and appropriate Powers of Attorney registered and in force.

To make a subject access request, the individual should send the request to the Home Manager or to the Data Protection Officer at 3 Lancaster Mews, South Marston, Swindon, Wiltshire. SN3 4YF or via email to suehouldey@coatewatercare.co.uk. Coate Water Care may need to ask for proof of identification before the request can be processed. Coate Water Care will inform the individual if it needs to verify his/her identity and the documents it requires.

Coate Water Care will normally respond to a request within a period of one month from the date it is received. In some cases, such as where Coate Water Care processes large amounts of the individual's data, it may respond within three months of the date the request is received. Coate Water Care will write to the individual within one month of receiving the original request to tell him/her if this is the case.

If a subject access request is manifestly unfounded or excessive, Coate Water Care is not obliged to comply with it. Alternatively, Coate Water Care can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which Coate Water Care has already responded.

If an individual submits a request that is unfounded or excessive, Coate Water Care will notify him/her that this is the case and whether or not it will respond to it.


OPTING OUT OF RECEIVING MARKETING COMMUNICATIONS


Please note that your information may be used to send you details of events, activities and updates or news about Coate Water Care that we have identified as likely to be of interest to you.

If at any point you would like to opt-out of receiving communications from us, please contact us at info@coatewatercare.co.uk. .You can also write to us at Coate Water Care, 3 Lancaster Mews, South Marston, Swindon, Wiltshire. SN3 4YF or contact the Home Manager.

This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.


THIRD PARTY LINKS


Where Coate Water Care engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical measures to ensure the security of data. This includes communications with other Health Professionals in the discharge of our responsibilities and during the care of the Resident.

IDENTIFYING YOU AS A RESIDENT


Coate Water Care will always anonomise data when communicating internally and with Third Parties and use every endeavour to ensure that the Resident cannot be identified in communications.


CHANGES TO OUR POLICY


If anything in this policy changes Coate Water Care will ensure the changes are communicated.


CONTACT


Coate Water Care has appointed Sue Houldey, Director of Operations as its Data Protection Officer. Her role is to inform and advise Coate Water Care on its data protection obligations. She can be contacted at suehouldey@coatewatercare.co.uk