0800 327 7678
support@sandehousing.com

66 Leonard Road
South Chingford

33-35 Borwick Avenue
Walthamstow

Privacy Notice

This is S&E Housing Limited Privacy Notice.

Privacy Notice

GENERAL DATA PROTECTION REGULATION (GDPR)

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 service 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.

  1. About this Policy

1.1 This policy explains when and why we collect personal information about our members and instructors, how we use it and how we keep it secure and your rights in relation to it.

1.2 We may collect, use and store your personal data, as described in this Data Privacy Policy and as described when we collect data from you.

1.3 We reserve the right to amend this Data Privacy Policy from time to time without prior notice. You are advised to check our website www.sandehousing.com and Care Management Software (CMS) Policies Section for any amendments.

1.4 We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner (www.ico.gov.uk). For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you.

  1. Service Users

2.1 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. benefits, bank details, client affairs officers, staff cards, PINs, receipts, 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.

2.2 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.

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.

2.3 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 regulators, the Local Authority and if registered 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.

2.4 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 our website, via post, via application forms, via apps.

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.

  1. Staff

4.1 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, National

Insurance number and next of kin;

–  Your financial details e.g. details so that we can pay you, insurance, pension and tax details;

–  Your training records.

–  Photographs

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 will only collect this if it is necessary for us to know as your employer, e.g. fit notes or in order to claim statutory maternity pay;

–  We may also record data about your race, ethnic origin, sexual orientation or religion;

–  Criminal Record Data.

4.2 Why do we have this data?

We require this data so that we can contact you, pay you and make sure you receive the training and support you need to perform your job. By law, we need to have a lawful basis for processing your personal data.

We process your data because:

–  We have a legal obligation under UK employment laws;

–  We are required to do so in our performance of a public task;

–  We have a legitimate interest in processing your data – for example, we provide data about your training to Skills for Care’s National Minimum Data Set, this allows Skills for Care to produce reports about workforce planning.

We process your special category data because

–  It is necessary due to social security and social protection law – we are required to perform

Disclosure and Barring Service (DBS) checks on our staff;

–  It is necessary for us to process requests for sick pay or maternity pay;

–  We are required to provide data to our regulators, the Local Authorities and if registered, 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.

4.3 Where do we process your data?

As your employer 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 our website, via post, via application forms, via apps. Third parties are organisations we have a legal reason to share your data with. These include:

–  Her Majesty’s Revenue and Customs (HMRC);

–  Our pension and healthcare schemes via Creative Pensions.

–  Our external payroll provider, Raffingers.

–  Organisations we have a legal obligation to share information with i.e. for safeguarding, the CQC, Local Authorities.

–  The police or other law enforcement agencies if we have to by law or court order.

  1. Friends/Relatives

5.1 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;

5.2 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 service 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.

5.3 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 our website, via post, via application forms, via apps. 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.

  1. How we protect your personal data

6.1 We will not transfer your personal data outside the EU without your consent.

6.2 We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.

6.3 Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.

6.4 For any payments which we take from you online we will use a recognised online secure payment system.

6.5 We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.

  1. Our Website

In order to provide you with the best experience while using our website, we process some data about you.

7.1 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The

legal basis for this processing is our legitimate interests, namely monitoring and improving our website and

services.

7.2        We may process your account data (“account data“).  The account data may include your name and email address.  The source of the account data is you or your employer. The account data may be

processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely [the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, e.g. annual leave requests.

7.3        We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for [he purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

7.4        We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include details sent in completed application or referral forms.  The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request.

7.5        We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely [the proper administration of our website and business.

7.6        We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

7.7        We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer.  The source of the customer relationship data is you or your employer.  The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

7.8        We may process information relating to transactions, including purchases of goods and services that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be

processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

7.9        We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

7.10     We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication.  Our website will generate the metadata associated with communications made using the website contact forms.  The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

7.11     We may process any of your personal data identified in this policy where necessary for the

purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

7.12     In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7.13     Please do not supply any other person’s personal data to us.

  1. About cookies

8.1        A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2     Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3     Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

8.4     Cookies that we use

We use cookies for the following purposes:

(a)      authentication – we use cookies to identify you when you visit our website and as you navigate our website.

(b)      status – we use cookies to help us to determine if you are logged into our website.

(c)      personalisation – we use cookies to store information about your preferences and to personalise the website for you

(d)      security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally

(e)      advertising – we use cookies to help us to display advertisements that will be relevant to you

(f)      analysis – we use cookies to help us to analyse the use and performance of our website and services

(g)      cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally

8.5.    Cookies used by our service providers

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

8.6     We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

8.7     Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)      https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)      https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

(Firefox);

(c)       http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)      https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-

cookies (Internet Explorer);

(e)      https://support.apple.com/kb/PH21411 (Safari); and

(f)       https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

8.8     Blocking all cookies will have a negative impact upon the usability of many websites.

8.9 If you block cookies, you will not be able to use all the features on our website.

  1. 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. We retain our data in line with the Information Governance Alliance’s guidelines (https://digital.nhs.uk/data-and-information/looking-after- information/data-security-and-information-governance/codes-of-practice-for-handling- information-in-health-and-care/records-management-code-of-practice-for-health-and-social-care-

2016)

  1. 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.
  2. 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.
  3. 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.

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 person inappropriately. We will always respond to your request as soon as possible and at the latest within one month.

  1. Who is the Data Controller?

10.1 The Data Controller, responsible for keeping your information secure and confidential is the Service

Manager at S&E Housing Limited.

  1. Complaints

Should you have any concerns about how your information is managed please contact the Service Manager who is the Data Protection Controller at the following address: management@sandehousing.com

The practice is registered with the Information Commissioners Office (ICO).

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 https://ico.org.uk/global/contact-us/

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