Privacy Policy

Introduction

Welcome to the privacy policy for Charing Lodge Limited T/A St. Michael's Care. Charing Lodge Limited shall be referred to as “St. Michael's”, “we”, “us” or “our” throughout this privacy notice. St. Michael's respects your privacy and is committed to protecting your Personal Data. This privacy notice will inform you as to how we look after your Personal Data when you visit our website and tell you about your privacy rights and how the law protects you.

This privacy notice contains the following information:

Purpose of this privacy notice

This privacy notice aims to give you information on how St. Michael's collects and processes your Personal Data through your use of this website, including any data you may provide through this website when you make an enquiry.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

St Michael's is the controller and responsible for your Personal Data.

Contact details

Our full details are:

Full name of legal entity:

Charing Lodge Limited (Company number: 04575597)

Data Protection Officer:

Jacquelyne Osborn

Email address:

info@stmichaelscare.org

Postal address:

St Michael's Nursing Home, Elm Grove, Westgate-on-Sea CT8 8LH

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 25 May 2018.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Third-party links

Our website includes links to third-party websites, plug-ins and applications such as a link to the website of the Care Quality Commission and the review site carehome.co.uk. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you and we have grouped together the Personal Data that we may collect, use, store and transfer as follows:

  • Identity Data includes your first name and last name.
  • Contact Data includes your email address and telephone number.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website and services.
  • Marketing and Communications Data includes where you can sign up to our mailing list or to receive a brochure through our website.

We use different methods to collect data from and about you, including through:

  • Direct interactions: You may give us your Identity and Contact Data by filling in forms on this website, requesting for us to contact you or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
    • request for us to contact you;
    • request marketing to be sent to you or request to be added to our mailing list;
    • make an enquiry; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies.
  • Third parties or publicly available sources. We may receive Personal Data about you from various third parties as set out as follows:

    Technical Data from the following parties:

    (a) analytics providers;

    (b) advertising networks; and

    (c) search information providers.

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

See below to find out more about the types of lawful basis that we will rely on to process your Personal Data.

Generally we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To respond to enquiries that you may make with us through the website (a) Identity
(b) Contact
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
To manage our relationship with you, which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or responding to an enquiry
(a) Identity
(b) Contact
(c) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to analyse how clients use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Transaction
(d) Technical
(e) Usage
(f) Marketing and Communications
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Usage
(d) Marketing and Communications
(e) Technical
Necessary for our legitimate interests (to analyse how clients use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, client relationships and experiences (a) Identity
(b) Contact
(c) Transaction
(d) Technical
(e) Usage
(f) Marketing and Communications
Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You may receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of the services you have purchased, or any other transaction with us.

Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your Personal Data with the parties set out below for the purposes set out in the table in Section 4 above. We will not disclose your Personal Data to a third-party without consent or unless we are satisfied that we are legally entitled to share such data under data protection laws. Where we do disclose your Personal Data to a third-party, we will have regard to the data protection principles under data protection laws.

Shuttlefish Creative Limited: We use Shuttlefish to develop and host our website and to help administer our marketing activities and our newsletter that we send to our residents. The legal basis for sharing this data is our legitimate business interests, namely the proper performance of our website and to administer our marketing activities.

Professional advisers: We may share Personal Data with professional advisers acting as processors or joint controllers including lawyers, experts, other accountants, insurers and other third parties who provide legal, banking, consultancy, accounting, insurance and other related services.

We may also share Personal Data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

We do not transfer your Personal Data outside the European Economic Area (EEA).

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my Personal Data for?

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your Personal Data are available on request by contacting us.

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. For more information on these rights please see 10. Glossary below:

  • Request access to your Personal Data.
  • Request correction of your Personal Data.
  • Request erasure of your Personal Data.
  • Object to processing of your Personal Data.
  • Request restriction of processing your Personal Data.
  • Request transfer of your Personal Data.
  • Right to withdraw consent.
  • If you wish to exercise any of the rights set out above, please contact us.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Data to you or to a third-party. We will provide to you, or a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.