Privacy policy

Introduction

Welcome to TLC Group’s privacy policy for Residents and Relatives.

The privacy of our residents is highly important to TLC Group Limited (a company established in England and Wales, with company number 03719278 whose registered office is at 36 Railway Approach, Harrow, Middlesex, HA3 5AA) (“We”, “Us” or “TLC Group”). This privacy policy will inform you as to how we look after your personal data when you visit our website and during its provision of services to you and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below:

1. [IMPORTANT INFORMATION AND WHO WE ARE]

2. [THE DATA WE COLLECT ABOUT YOU]

3. [HOW IS YOUR PERSONAL DATA COLLECTED]

4. [HOW WE USE YOUR PERSONAL DATA]

5. [DISCLOSURES OF YOUR PERSONAL DATA]

6. [INTERNATIONAL TRANSFERS]

7. [DATA SECURITY]

8. [DATA RETENTION]

9. [YOUR LEGAL RIGHTS]

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how TLC Group collects and processes your personal data through your use of this website and during its provision of services to you.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.

Controller

TLC Group is the controller and responsible for your personal data.

Changes to the privacy policy and your duty to inform us of changes

This version was last updated on 24 May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, including any changes to your opt-ins, by contacting us at [email protected].

Exercising Your Rights

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

TLC Group Limited

Lorna Badrick

36 Railway Approach, Harrow, Middlesex, HA3 5AA

Email: [email protected]

Telephone: 020 8863 4637

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

§ Identity Data includes first name, last name, title, NHS number and National Insurance number.

§ Contact Data includes residential address, email address and telephone numbers.

§ Financial Data includes bank account and/or payment card details.

§ Transaction Data includes details about payments to and from you in relation to receiving our services.

§ Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

§ Usage Data includes information about how you use our website and services.

§ Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Transaction Data to compile market research relating to the care industry. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Special Category/Sensitive Personal Data

In relation to Residents only, we may also collect, store and use the following “special categories” of more sensitive personal information:

§ Dietary requirements and health issues (if any)

§ Information about your race or ethnicity, religious beliefs and sexual orientation.

§ Health issues – such as infections status

§ Death records, including preferences after death and if they wish an organ donor

§ Mental health and whether or not a Resident has capacity to make decision about how they live their lives

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

§ Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us in person at one of our care homes, by post, phone, email, social media or otherwise. This includes personal data you provide when you:

§ enquire about our services;

§ contact us via the website to request details about our services or any other enquiry;

§ request marketing to be sent to you;

§ enter a competition, promotion or survey; or

§ give us some feedback.

§ Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://www.tlccare.co.uk/cookie-policy for further details.

§ Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

§ Technical Data from the following parties:

(a) analytics providers such as Google based outside the EU;

(b) advertising networks such as SurveyMonkey, which may be based inside or outside the EU; and

§ Special Category/Sensitive Personal Data from your GP.

§ Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as our banking partners, which may be based inside or outside the EU.

§ Contact Data from providers of care home directories such as Carehome.co.uk, based inside the EU.

§ Contact, and Technical Data from marketing service providers such as Media Hawk, based inside the EU.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

§ Where we need to perform the contract we are about to enter into or have entered into with you.

§ Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

§ Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email, text message, post or phone. You have the right to withdraw consent to marketing at any time at [email protected].

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use Resident and Relative personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at [email protected]if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Residents

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new or prospective resident and uploading your information onto our internal database	(a) Identity(b) Contact	Performance of a contract with you
To manage the services:(a) To carry out the contract for care(b) Manage payments, fees and charges(c) Collect and recover money owed to us(d) Communicate with third-parties as required to provide our Services e.g. agency staff	(a) Identity(b) Contact(c) Financial(d) Transaction(e) Marketing and Communications(f) Special category data	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)In relation to special category personal data:(c) processing is necessary for the provision of health or social care or treatment or management of health or social care systems
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or take a survey	(a) Identity(b) Contact(c) Profile(d) Marketing and Communications	(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how residents use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity(b) Contact(c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical	Necessary for our legitimate interests (to study how Residents use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, Resident relationships and experiences	(a) Technical(b) Usage	Necessary for our legitimate interests (to define types of Residents for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile