Fair Processing Notice
When CCK Support Ltd processes your personal data we are required to comply with the Data Protection Act 1998 ('DPA') up to and including 24 May 2018, and from 25 May 2018, the General Data Protection Regulation 2016 ('GDPR') (the DPA and GDPR are together referred to as the 'Data Protection Legislation').
Your personal data includes all the information we hold that identifies you or is about you, for example:
• Your name, home address, date of birth and contact details (including your telephone number, email address) and emergency contacts (ie name, relationship and home and telephone numbers)
• Your allergies and any medical, physical or mental conditions and in particular your care needs
• Your likes, dislikes and lifestyle preferences (including your religious beliefs, ethnic origin and race, marital status, sexual orientation, political views, trade union membership or biometrics - so far as they relate to providing you with suitable care)
• Credit, debit card details or other payment information (if you pay for some or all of our services using one of these methods)
• Your feedback and contributions to questionnaires and surveys about the service we offer
• Your complaints, compliments or concerns about the service we provide
• Any accidents and incidents or near misses you may have been involved in whilst on our premises or whilst our employees are delivering a regulated service to you – this may include details of injuries and treatment you may have received.
Everything we do with your personal data counts as processing it, including collecting, storing, amending, transferring and deleting it. We are therefore required to comply with the Data Protection Legislation to make sure that your information is properly protected and used appropriately.
This fair processing notice provides information about the personal data we process, why we process it and how we process it.
Our responsibilities
CCK Support Ltd is the data controller of the personal data you provide. We have appointed Deb Rowden as Data Protection Officer who will have day to day responsibility for ensuring that we comply with the Data Protection Legislation and for dealing with any requests we receive from individuals exercising their rights under the Data Protection Legislation.
Why do we process your personal data?
We process your personal data in order to provide you with the services you have requested, to fulfil the contract we have entered into with you and/or to receive services or goods from you. We may also process your personal data to respond to any queries or comments you submit to us and to correspond with you on a day to day basis.
We may need personal data from you to be able to provide services to you, to meet our legal obligations, to enter into a contract with you and/or to provide you with all the information you need. If we do not receive the personal data from you, we may be unable to fulfil our obligations to you.
We use your personal information to:
• Prepare, review and update a suitable care plan, describing the nature and level of care and support services which you have requested we supply to you
• To communicate with you, your representatives and any appropriate external social or health care professionals about your individual needs and personalise the service delivered to you
• Make reasonable adjustments when required to meet your individual needs and to ensure we have suitable facilities to ensure your safety
• Invoice you for the care and support services in accordance with our terms and conditions
• Carry out quality assurance procedures, review our service and improve our customer experience (please note that feedback can also be provided anonymously)
• Notify you about changes to our services which are relevant to you
• Monitor how effective our services are and to make sure that the services we provide meet your needs.
If we obtain consent from you to the processing of your personal data, you can withdraw your consent at any time. This won't affect the lawfulness of any processing we carried out prior to you withdrawing your consent.
Who will receive your personal data?
We only transfer your personal data to the extent we need to. Recipients of your personal data include:
• Staff involved in your care
• Professionals (including your GP and pharmacist)
• If you have a nominated individual as your representative as and when required
• Law enforcement or other authorities if legally required to do so
• Public bodies, CQC, social or health care professionals (including local safeguarding groups to ensure your safety)
• Accountant
We will not share, sell or trade your personal information with any other third party without your consent.
In order to deliver our service to you we rely on third parties to provide specialist support to us. To provide this support they will have access to or a duty of care over your personal information. These providers are:
• IT and Telecoms Support companies – to ensure the safe, secure and resilient operation of our IT infrastructure including computers, servers, phones and mobile devices
• Software support companies – to provide specialist support and resolve issues with the software that we run, for example the systems we use to store and manage your customer records
• Marketing systems providers – to organise marketing communications and for the delivery and analysis of email communications.
These providers are under a written contract to ensure the same level of privacy and security that we promise to you.
We don't transfer your personal data outside of the EEA.
How long will we keep your personal data?
We will retain your personal data for 6 years. We retain your information for this period in case any issues arise or in case you have any queries. Your information will be kept securely at all times. Following the end of the 6 year period, on termination of our service to you, your files and personal data we hold about you will be permanently deleted or destroyed. If we are required to obtain your consent to process your personal data, any information we use for this purpose will be kept until you withdraw your consent, unless we are entitled to retain the personal data on the basis of other grounds set out in the Data Protection Legislation.
What are your rights?
You benefit from a number of rights in respect of the personal data we hold about you. We have summarised the rights which may be available to you below, depending on the grounds on which we process your data. More information is available from the Information Commissioner's Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/).
These rights apply for the period in which we process your data.
1. Access to your data
You have the right to ask us to confirm that we process your personal data, as well as having the right to request access to/copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this fair processing notice.
We will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more than one copy of the same information.
We will provide the information you request as soon as possible and in any event within one month of receiving your request. If we need more information to comply with your request, we will let you know.
2. Rectification of your data
If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it unless we don't feel it is appropriate. In which case we will let you know why. We will also let you know if we need more time to comply with your request.
3. Right to be forgotten
In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:
• Where we no longer need your personal data for the purpose to which we collected it.
• Where we have collected your personal data on the grounds of consent and you withdraw that consent
• Where you object to the processing and we don't have any overriding legitimate interests to continue processing the data
• Where we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR); and
• Where the personal data has to be deleted to comply with a legal obligation
There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we will let you know.
4. Right to restrict processing
In some circumstances, you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don't have to delete it. This right is available to you:
• If you believe the personal data we hold isn't accurate – we will cease processing it until we can verify its accuracy
• If you have objected to us processing the data – we will cease processing it until we have determined whether our legitimate interests override your objection
• If the processing is unlawful; or
• If we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.
5. Data portability
You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies to personal data you provide to us:
• Where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
• Where we carry out the processing by automated means.
We will respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we will let you know.
6. Right to object
You are entitled to object to us processing your personal data:
• If the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority
• For direct marketing purposes (including profiling); and/or
• For the purposes of scientific or historical research and statistics
In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.
Automated decision making
Automated decision making means making a decision solely by automated means without any human involvement. This would include, for example, an online credit reference check that makes a decision based on information you input without any human involvement. It would also include the use of an automated checking-in system that automatically issues a warning if a person is late a certain number of times (without any input from HR, for example).
Your right to complain about our processing
If you think we have processed your personal data unlawfully or that we have not complied with GDPR, you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner's Office ('ICO'). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website – https://ico.org.uk/concerns/.
Any Questions?
If you have any questions or would like more information about the ways in which we process your data, please contact:
Debbie Rowden
Building 1, 10 Wealden Forest Park, Herne Common, Herne Bay, Kent CT6 7LQ
Phone: 01227 668041
Email: debbie@ccksupport.co.uk