Privacy Policy

Organisation name: Eminence Care Service (Broomfield) Limited
Address: Broomfield Residential Care, Yardley Road, Olney, Buckinghamshire, MK46 5DX
Telephone: 01234 711 619
We are registered with the Information Commissioner’s Office (ICO). You can contact the Home Manager using our Contact Us form.

Under the UK General Data Protection Regulation (GDPR), you have the right to be informed about:

• the collection and use of your personal data
• our purposes for processing that data
• the retention periods for storing your data (or a guarantee that it will be kept only for as long as necessary)
• who it will be shared with (both in this country and, if applicable, in others: in this case, we will inform you of the safeguards which are applied in that country)
• the legal basis under which we process your data
• the right to withdraw your consent (if consent is the legal basis for processing)
• our “legitimate interest” in processing your data (if that interest is the legal basis for processing)
• details of any data we collect about you from a third party (such as publicly-available information)
• the right to lodge a complaint with the ICO
• details of the existence of automated decision-making, including profiling (if applicable)

You also have the right to information that is concise, transparent, intelligible, easily accessible and presented to you in clear and plain language rather than in “legalese”. We would encourage you to get in touch with the contact given above if you have any questions about this policy statement or our procedures with regard to data processing. This will not in any way affect your right (mentioned above) to complain to the ICO. Finally, we commit to informing you if, at any time, we update our privacy information and always to seek permission if we plan to use your personal data for a new purpose.

We process and store details of your:

• name
• chosen mode of address (Mrs, Ms, etc.)
• email address
• telephone number
• any other information you choose to provide
• IP address

These details will typically be provided when you sign up to receive a newsletter, make an enquiry or send a message. We only keep them for as long as necessary and you may, at any time, contact us to ask for them to be removed (see “the right to be forgotten” below).

We use the information that we collect and store about you to:

• provide our services
• manage invoices and accounts
• deliver marketing and events information
• invite participation in polls and surveys
• address any other related contact that you make

• Consent
• Legitimate interests

This organisation has carried out a legitimate interests assessment (LIA) which can be seen on request. In doing so, we have checked that the processing is necessary and that there is no less intrusive way to achieve the same result. We will only use your data in ways that you would reasonably expect, unless we have a very good reason. We will not use your data in ways that you would find intrusive or which could cause you harm, and we have considered and introduced safeguards to reduce the impact where possible.

This organisation is committed to applying the principles set out in the GDPR. To that end, we will always strive to ensure that:

• personal data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
• our procedures are adequate, relevant and limited to what is necessary in relation to the purposes for which they are put in place
• the data we collect are accurate and, where necessary, kept up to date; every reasonable step will be taken to ensure that data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay
• data are kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which they are processed
• data are processed in a manner that ensures their appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures

On receipt of a request for access to the data which we hold about you, we will respond without delay and at the latest within one month of receipt. Information will be provided free of charge, although a reasonable fee may be applied when a request requires excessive work, particularly if it is repetitive. This fee will reflect the amount of administrative work involved.

Also known as data erasure, the “right to be forgotten” set out in the GDPR entitles you to ask any data controllers (including this organisation) to erase your personal data and to cease further dissemination. You can make such a request either verbally or in writing and we will respond as quickly as possible, and at the latest within one month. We understand that there is a particular emphasis on the right to erasure if the request relates to data collected from children, and such requests will always be given the highest priority.

Please note, however, that there are certain circumstances in which the right to erasure may not apply. These include where processing is necessary for one of the following reasons:

• to comply with a legal obligation
• to exercise the right of freedom of expression and information
• for the performance of a task carried out in the public interest or in the exercise of official authority
• for the establishment, exercise or defence of legal claims

In addition, any organisation is allowed to refuse to comply with a request for erasure if it is manifestly unfounded or excessive, taking into account whether the request is repetitive in nature. We will, however, explain and justify any such refusal.

Either verbally or in writing, you may ask for inaccurate personal data to be rectified, or to be completed if it is partial. We will respond as quickly as possible and certainly within the one month time period allowed under the GDPR. In the unlikely event that there is disagreement over the accuracy of the data, we will do our best to resolve this and you will, of course, have the right to take the matter to the ICO if we cannot reach agreement. If that situation arises, we are prepared to consider restricting processing of the contested data during the time it takes to resolve the issue with the ICO.

You have the right to object to:

• processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling)
• direct marketing (including profiling)
• processing for purposes of scientific/historical research and statistics

We will stop processing personal data for direct marketing purposes as soon as an objection is received.

While we will take all appropriate measures to prevent illegal access to your data, we have to prepare for that possibility. Should there be a significant data breach affecting your data and rights, we will notify you (and the ICO) as soon as possible. To minimise any possible danger, we will use encryption and/or pseudonymisation where it is appropriate to do so. We will also have backup systems in place in the event that an outside organisation attempts to disrupt access to our data.

Given that all members of the European Economic Area (EEA) have to comply with the Union’s standards on data protection, and particularly with the GDPR, we can legally transfer data to those countries. However, if we have reason to send data to non-EEA countries, we recognise that they must have equivalent standards in place. This is not a matter for individual organisations to assess but must be based on, for example, standard data protection clauses in the form of template transfer clauses or compliance with an approved Code of Conduct approved by the ICO. Should such transfers take place, we will make it clear which of these provisions we have adopted to ensure safety.

A cookie is a small text file placed on your computer or device by our site when you visit certain parts of it and/or use certain of its features. For example, we may monitor how many times you visit, which pages you go to, traffic data, location data, weblogs and other communication data. We may also look at the originating domain name of a user’s internet service provider, IP address, operating system and browser type. This information helps us to build a profile of our users. Where appropriate, this data will be aggregated or statistical, which means that we will not be able to identify you individually.

Cookies are also used to remember your settings (language preference, for example) and for authentication (so that you do not have to repeatedly sign in). You can set your browser not to accept cookies and there are a number of websites which explain how to remove cookies from your browser. However, it is possible that some of our website features may not function as a result.

Please note that there are some links on our website to other sites where you may find useful information. This does not indicate a general endorsement of those sites and, as we have no control over how data is collected, stored, or used by other websites, we would advise you to check their privacy policies before providing any data to them.

This policy is reviewed periodically by the Data Protection Officer.