| 1. Business details |
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This is the privacy notice of Interhaze Ltd. Our registered head office is at Hollybush Lane, Codsall WV8 2AT. Interhaze Ltd operates a number of Care Homes in West Midlands.. Note: This last item will indicate the complexity of the organisation and of the personal information it might be collecting and processing. |
| 2. Aims of this notice |
| Interhaze Ltd is required by law to tell you about your rights and our obligations regarding our collecting and processing any of your personal information, which you might provide to us. We have a range of policies and procedures to ensure that any personal information you supply is only stored and used with your active consent (or with one of the other legal grounds for processing set out in the GDPR and which include legal obligations and the necessity of fulfilling an employment contract). It will always be held securely and treated confidentially in line with the requirements of the GDPR. We have listed the relevant documents in a later section (6) and can make any available. |
| 3. What personal information we collect about: a) service users b) employees and c) third parties |
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a) Patients. As a primary care provider, we must collect some personal information on our patients, including personal health information, which is essential to our being able to provide effective care and support. The information is contained in individual files (manual and electronic) and other record systems, all of which are subject to strict security and authorised access policies. Personal information that becomes inactive for any reason is kept securely only for as long as it is needed, before being safely disposed of. Photographs are also taken. b) Employees and volunteers. The service operates a safe recruitment policy to comply with the regulations in which all personal information obtained, including CVs and references, is, as with patients’ information, securely kept, retained and disposed of in line with the GDPR. All employees are aware of their right to access any information about them. c) Third parties. All personal information obtained about others associated with the delivery of the primary care service, including contractors and suppliers will be protected in the same way as information on patients and employees. |
| 4. How we collect information |
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The bulk of patients’, employees’ and third parties’ personal information is collected directly from them or through form filling, mainly manually, but also electronically for some purposes, eg when contacting the service through its website. With patients, we might continue to build on the information provided through consultations and in the process of agreeing treatment. With employees, personal information is obtained directly and with consent through such means as references, testimonials and criminal records (DBS) checks. When recruiting staff, we seek applicants’ explicit consent to obtain all the information needed for us to decide to employ them. All personal information obtained to meet our regulatory requirements will always be treated in line with our explicit consent, data protection and confidentiality policies. Our website and databases are regularly checked by experts to ensure they meet all privacy standards, are protected through strong passwords and encryption and comply with our general data protection security and protection policies. |
| 5. What we do with personal information |
| All personal information obtained on service users, employees and third parties is consistent with our purpose of providing a primary care service which meets all regulatory standards and requirements. It will not be disclosed or shared for any other purpose. |
| 6. How we keep your information safe |
| As already stated, the primary care service has a range of policies that enable us to comply with all data protection requirements, including the Data Protection Policy for Primary Care Services — GDPR. |
| 7. With whom we might share information |
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We only share the personal information of patients, employees and others with their consent on a “need to know” basis, observing strict protocols in doing so. Most information sharing of service users’ information is with other professionals and agencies involved with their care and treatment. Likewise, we would not disclose information about our employees without their clear agreement, eg when providing a reference. The only exceptions to this general rule would be where we are required by law to provide information, eg to help with a criminal investigation. Under the terms of the GDPR, this is “complying with legal obligations”, an alternative to consent. Where we provide information for statistical purposes, the information is aggregated and provided anonymously so that there is no privacy risk involved in its use. NOTE: We may use photos either taken by you, your family or your friends on our website or our company literature and brochures. |
| 8. How personal information held by the primary care provider can be accessed |
| There are procedures in place to enable any staff member, employee or third party whose personal information we possess and might process in some ways to have access to that information on request. The right to access includes both the information and any uses which we might have made of the information. There will only be a charge for providing such information in the event that requests are held to be “manifestly unfounded or excessive” (particularly if they are repetitive). Even then this fee will cover only the amount of administrative work involved. |
| 9. How long we keep information |
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There are strict protocols in place that determine how long the organisation will keep the information, which are in line with the relevant legislation and regulations. All Care Records and any related documents are kept no more than 3-years from the last date of entry. Employee and Payroll Records are kept no more than 6-years after the employee leaves the service. Company Accounts are kept no more than 7-years. |
| 10. Right to be forgotten |
| Interhaze Ltd recognises the right to erasure, also known as the right to be forgotten, laid down in the GDPR. Individuals should contact the manager with requests for the deletion or removal of personal data. These will be acted on provided there is no compelling reason for continued processing and that the exemptions set out in the GDPR do not apply. These exemptions include where the personal data is processed for the exercise or defence of legal claims and to comply with a legal obligation for the performance of a public interest task or exercise of official authority. |
| 11. How we keep our privacy policies up to date |
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The staff appointed to control and process personal information in our organisation are delegated to assess all privacy risks continuously and to carry out comprehensive reviews of our data protection policies, procedures and protocols at least annually. The main point of contact with regard to data protection is the Home Manager. |