QMF 143: Privacy Policy
Creative Independent living Ltd are committed to complying with the General Data Protection Regulation and the Data Protection Act 2018, once enacted. Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer you a better and more personalised experience.
- We have published this notice to help you understand:
- How and why we collect information from you;
- Who we share your information with, why and on what basis; and What your rights are.
If we make changes to this notice we will notify you by updating it on our website. We will be what is known as the ‘Data Controller’ of the personal data you provide to us, and we will sometimes refer to ourselves in this notice as “we” or “us”. By Data Controller, this means we determine the purposes and way in which any personal data are, or will be, processed.
What information we collect:
- Full name
- Contact numbers, and Email address.
How do we use your information?
Data Protection says that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons and these are:
- Contract – your personal information is processed in order to fulfil a contractual arrangement e.g. in order to deliver our services to you or in order to communicate services updates.
- Consent – where you agree to us using your information in this way e.g. for storing your payment details.
- Legitimate Interests – this means the interests of HC4U in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way e.g. to transfer your data to certain Third Party’s such as pharmacies or regulatory bodies
- Legal Obligation – where there is statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes.
Here is a list of the ways that we may use your personal information, and which of the reasons described above we rely on to do so. Where we list legitimate interests as a reason, we also describe below what we believe these legitimate interests are.
| What we use your personal information for | Our reasons (legal basis) |
Our explanation of legitimate interests | |
| Process a job application | Legitimate interest Consent | Necessary to provide employment | |
| Processing of payroll data. | Fulfilling a contract | N/A | |
| Provide private care package | Fulfilling a contract Consent | N/A | |
| Provide a Local Authority care package | Fulfilling a contract | N/A | |
| Process a general enquiry | Consent | N/A | |
| Stakeholder emergency contacts | Legitimate interests | Being able to contact an individual’s designated family member, friend or emergency contact in an emergency is a legitimate interest as a responsible employer | |
| Contact you to undertake customer satisfaction surveys or for market research. | Legitimate interest | Developing services and applications that attract and retain clients. Improving user interaction with our sites. | |
| Notifying you about enhancements to our services, such as changes to the website and new services that may be of interest to you. | Legitimate interest | Developing services and applications that attract and retain clients. Improving user interaction with our sites. | |
| Service an SAR request | Legal Obligation | N/A | |
| To detect, investigate and report financial crime (e.g. | Legal Obligation Legitimate
interests |
Developing and improving how we deal with financial | |
| Fraud) | crime. Complying with any legal obligation placed on us by regulators | ||
| such as HMRC. Complying with any regulations that apply to us. Process efficiency in dealing with such activity, and to make service and process improvements. | ||
| Criminal Behaviour | Legal Obligation Legitimate interests | Disclosing information about possible criminal acts or security threats to the relevant authorities. |
| Intra-group transfers | Legitimate interests | Necessary to provide continuous employment or services from within the group. |
Who are we sharing your information with and why
CQC and local councils and partners, ensure we are meeting legitimate requirements and contractual requirements
NMDS, to record training and qualification levels DBS, to enable to under criminal conviction checks Insurers and legal representatives
We will not share information about you with third parties without your consent unless the law allows or requires us to. We are required to share some of your personal data for lawful, vital and existing protection reasons with:
Your Rights
Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data be erased or corrected; request access to your personal data.
For more information or to exercise your data protection rights, please contact us using the contact details: info@ciliving.co.uk.
You also have a right to complain to the Information Commissioner’s Office, which regulates
the processing of personal data
How long we keep your information
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 4 years after the date it is no longer needed by us for any of the purposes listed under how we use your information above. The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
- we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
- In limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
What are your rights
You are entitled to request the following from HC4U, these are called your Data Subject Rights and there is more information on these on the Information Commissioners website www.ico.org.uk
- Right of access – to request access to your personal information and information about how we process it
- Right to rectification – to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
- Right to erasure (also known as the Right to be Forgotten) – to have your personal information erased.
- Right to restriction of processing – to restrict processing of your personal information Right to data portability – to electronically move, copy or transfer your personal information in a standard form
- Right to object – to object to processing of your personal information
- Rights with regards to automated individual decision making, including profiling –
rights relating to automated decision making, including profiling
If you have any general questions about your rights or want to exercise your rights please contact:info@ciliving.co.uk
Subject Access Request
Should you wish to obtain a copy of the information held by us please
Email: info@ciliving.co.uk
All requests will be dealt with in 40 days of receipt of the form providing sufficient identification has been provided.
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info@ciliving.co.uk
0117 336 1833