When we collect and use your personal information, we look after it properly and use it in accordance with our privacy principles:
Taking Care Services (our Services)
The telecare products and monitoring and support services that we provide.
Taking Care Customer (Customer)
The person who has paid for the service and assumes responsibility under the contract. The Customer is typically a Nominated Contact of the person using our products and services.
Taking Care User (User)
The end user of our social care products and services.
A person who lives locally to the Taking Care User, whom we will contact to provide assistance in case of an emergency or if otherwise required.
3a. Information about Taking Care Customers, Taking Care Users and Nominated Contacts
The personal information we collect in connection with our Services includes:
Taking Care Customers: name, email address, home address, telephone number, date of birth, time away from home (for instance on holiday), and bank/credit card details.
Nominated Contacts: names and contact information, as well as information about time away from home. Nominated Contacts are often also Taking Care Customers.
Taking Care Users: name, home address, email address, telephone number, date of birth, time away from home (for instance on holiday), information about Key Safes (as applicable) and information about houses and gardens so that we can assess the risk of falls (e.g. if there are stairs). We also collect sensitive personal information (known in Data Protection law as ‘Special Category Data’) such as information concerning physical and mental health, including conditions and medication. We collect NHS numbers.
If Users have chosen a ‘location-aware’ product, we collect GPS location and sudden, sharp movements as part of our fall detection service
If Users have chosen a ‘Smart Home Monitoring’ product, we collect information about movements around the home and entries and exits, to build up an understanding of daily routine and variances from it. Our Taking Care Sense proactive monitoring system also collects information about changes in temperature and humidity in homes.
If Users have chosen a Taking Care Prevent activity wearable device, we collect information about activity levels, sleep pattern and heart rate.
How we collect this information
We collect personal information directly from Taking Care Customers and/or Users in different ways, including:
We also collect information about Taking Care Customers and Taking Care Users, including sensitive personal information, in other ways:
We may also collect personal information about Customers and Users from other organisations, for example:
We process personal information for different reasons, which we describe below. Under data protection law we can only process personal information when we have a legal basis to do so; these legal bases are set out in data protection law.
When the personal information is classed as sensitive personal information (for example information relating to health which is also known as ‘Special Category Personal Data’) we must additionally have a legal condition to process it. The legal conditions which we rely on are also set out in data protection law.
4a. To provide PPP Taking Care Services
When providing our Services, we use information about Taking Care Customers and/or Taking Care Users:
When we process your personal information to provide our Services, the principal legal basis that we rely on is that the processing is necessary to provide the products and services under the contract.
The legal condition that we rely on when our processing includes sensitive information, is that it is necessary for health or social care purposes.
We may also rely on other the legal bases to process personal information (including sharing it with emergency services): it is necessary to process it to protect a User’s vital interests; or it is necessary to process it to safeguard their wellbeing (for instance, advising Nominated Contacts or care providers that we are withdrawing our Services).
4b. Optimising online channels
We use the information collected through use of our website to administer, maintain, and improve it. For instance, information about how people interact with our website helps us to make it easier to find information and services. Login information allows us to authenticate the identity of people accessing our apps and portals and keep information secure. Some personal data may also be used to understand and improve the effectiveness and relevance of the advertising we present to individuals online.
Legal basis to process personal information
The legal basis that we rely on to process your personal information for these purposes is that it is in our legitimate business interests to maintain, secure and optimise our online channels.
4c. Using your Information for Business Management Purposes
The legal basis we rely on when processing your personal information for Business Management Purposes is that it is in our legitimate interests to understand, monitor and operate our internal operations. When this requires sensitive information, the legal conditions that we rely on, depending on the processing, is that it is necessary for statistical purposes, necessary for the purposes of health or social care, or because you have provided your consent.
4d. For quality, training and security purposes
We may record phone calls that you have with our customer services representatives and use some of these for quality monitoring and training purposes, and as a record of our conversation.
The legal bases that we rely on is that we have a legitimate business interest to process personal information for service improvements, and that we may need to do so to comply with our legal or regulatory obligations.
The additional legal condition that we rely on when calls include sensitive information, is that it is necessary for health or social care purposes.
4e. Telling you about products and services that may interest you
For information on how to object to our use of your personal information for marketing purposes, please see Section 8.
Our legal basis for processing your personal information for marketing purposes is that it is in our legitimate interests or you have provided your consent.
4f. Anonymising your personal information
When required, we anonymise personal information so that individuals cannot be identified before we use it for management information and analysis of our products and services. Analysis of anonymous information provides us with insights about our business, and with opportunities to improve our products and services and the health and wellbeing of the people who use them. Analysis of anonymous information also allows us to demonstrate the value of the services we provide to our clients. The way that we anonymise personal information aligns with regulatory guidance and is achieved using different techniques, for example removing identifying data or overwriting it with randomised non-identifiable data.
Anonymisation still constitutes use of your personal information; we rely on the legal bases that we relied on when your data was originally collected.
We collect and use personal information when you provide this to us as part of the recruitment process. This includes name, address (and evidence of it), contact details, national insurance number, professional information such as your job title, grade, employment history, education, and financial information relating to your salary and taxation.
The legal basis that we rely on is that the processing is necessary to contract with you, because it is in our legitimate interests or because we need to process the personal data to comply with a legal obligation.
We may disclose your personal information to third parties when we are under a duty to do so to comply with a legal obligation; this may include Coroners Court and Social Services.
Before engaging third party service providers, we conduct risk assessments and put in place contractual arrangements and security mechanisms to protect your data in line with our data protection, confidentiality, and security standards.
Some third-party recipients may be in countries outside the UK and the EEA. When we transfer your personal information outside the UK and the EEA we take steps to ensure that it is protected. Such steps may include placing the party we are transferring personal information to under contractual obligations to protect it to adequate standards.
The rights that you have over your personal information are described below. If you make a request, we’ll either do what you’ve asked, or explain why we can’t - usually for legal or regulatory reasons. When you make a request, we may ask you for information to confirm your identity and/or to enable us to carry out your request.
Please see Section 9 for our contact information.
The right to access your personal information
You are entitled to a copy of the personal information we hold about you and certain details about how we use it. There will not usually be a charge for dealing with these requests.
The right to rectification
We take steps to ensure that the personal information we hold about you is accurate and, to the extent necessary, complete. However, if you do not believe this is the case, you can ask us to update or amend it.
The right to erasure
You can ask us to erase your personal information, for example if we no longer need it for the purposes for which we collected it. However, we won’t always be able to comply with your request, usually for a legal or regulatory reason which we’ll advise you of at the time.
Right to restriction of processing
In certain circumstances, you can ask us to suspend using your personal information for a period. For example, if you think that the personal information we hold about you is inaccurate, you can ask us to stop using it while we verify its accuracy; or if you need us to retain your personal information beyond our retention periods, you can ask us not to delete it.
Right to data portability
In certain circumstances, you have the right to the personal information that you have provided to us in a machine-readable format. You can also ask us to provide this directly to a third party. Once transferred, the other party will be responsible for looking after your personal information.
The right to object
You can ask us to stop sending you marketing messages and to stop using your personal information for marketing purposes (e.g. profiling) at any time (see Section 9 for contact information). You can also follow the unsubscribe instructions in our emails to stop receiving marketing by email. We will continue to send you service related (non-marketing) communications.
You can also ask us to stop processing all or some of your personal information when we’re doing this for other purposes. Depending on the purpose and our legal basis for processing, we may not always be able to fulfil your request.
The right to withdraw consent
In some circumstances, we may ask for your consent to process your personal information, for instance if we want to use it for new purposes which we haven’t already told you about. You have the right to withdraw it at any time.
The right to lodge a complaint
You have the right to complain to the Information Commissioner’s Office (ICO) if you consider that we have not complied with data protection law. The ICO will usually expect you to have given us the opportunity to resolve your complaint before interceding, so please do bring any concerns to us in the first instance (see Section 9). More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/.
If you’d like to make a rights request, or for any other data protection query or complaint, please contact: firstname.lastname@example.org
The Data Protection Officer, PPP Taking Care Limited, Linhay House, Linhay Business Park, Eastern Road, Ashburton TQ13 7UP
Registered Address: 20 Gracechurch Street, London, EC3V 0BG.
ICO Registration Number: Z7105141
Chichester Careline: Chichester Careline is a PPP Taking Care brand which provides telecare by a 24-hour staffed Alarm Receiving Centre (ARC). Chichester Careline is provided by PPP Taking Care.
Last updated 29/08/23
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