This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time in the UK (‘Data Protection Legislation’). This also includes CQC regulations incorporating Key Lines of Enquiry, R1.6, E1.3, E4.6, E5.2.
Please read the following carefully to understand our practices regarding your personal data and how we treat it.
Cobham Care Limited (Cobham Care) is a company that owns and operates two specialist dementia care homes in Worthing, West Sussex, Avon House (Avon House), 40-42 Shakespeare Road Worthing BN11 4AS and Avon Manor (Avon Manor), 50-52 manor Road, Worthing BN11 4SH. Cobham Care is registered in England and Wales as a limited liability company under number: 4822667 and our registered office is at 21 Broomfield Ride Oxshott Surrey KT22 0LP.
For the purposes of the Data Protection Legislation and this notice, Cobham Care, Avon House and Avon Manor are the ‘data controllers’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
We have appointed a Head of Privacy in each of three organizations mentioned above. Each Head of Privacy is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 12 (Contact Us), below.
We obtain personal data about you, for example:
- If you contract with us to provide our services and during the provision of those services
- If you request a brochure or make an enquiry in respect of one of our services
- If you contact us by email, telephone, post or social media (for example, when making an enquiry regarding a resident in connection with one of our services); or
- From third parties and/or publicly available resources (for example, from your medical practitioners and hospitals)
The information we hold about you may include the following:
- Your personal details (such as your name and email and your residential address)
- Details of contacts we have had with you in relation to the provision, or the proposed provision of services, of our services
- Details of any services you have received from us
- Our correspondence and communications with you
- Information about any complaints and enquiries you make to us
- Information from research, surveys, and marketing activities;
- Information we receive from other sources, such as publicly available information.
We may process your personal data for purposes necessary for the performance of our contract with you and to comply with our legal and regulatory obligations.
We may process your personal data for the purposes necessary for the performance of our contract with you.
We may process your data for the purposes of our legitimate interests provided that those interests do not override any of your own interests, rights and freedoms that require the protection of personal data.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such purposes.
Please note that we may process your data for more than one lawful basis depending on the specific purpose for which we are using data.
Situations in which we will use your personal data
We may use your personal data in order to:
- Carry out obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services)
- Provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes
- Seek your thoughts and opinions on the services we provide; and notify you about any changes to our services
- In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered onto with you. We may also be unable to comply with our legal and regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
Data Retention
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention is appropriate for your personal data, we take into consideration:
- The requirement of our business and the services provided
- Any statutory or legal obligations
- The purposes for which we originally collected the personal data
- The lawful grounds on which we based our processing
- The types of personal data we have collected
- The amount and categories of your personal data; and
- Whether the purpose of the processing could reasonably be fulfilled by other means
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest on doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers and other entities within our group. The following activities are carried out by third-party services providers: IT and cloud services, payroll services, professional advisory services, administration services, and marketing services.
All our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share you personal data with other third parties, for example in the context of moving care homes or moving into hospital. We may also need to share your personal data with a regulator or to otherwise comply with the law.
In some circumstances we will transfer personal data we collect about you to the following country outside of the EEA, the United States of America, in order to perform our contract with you.
There is an adequate decision at the European Commission in relation to this country therefore it will be deemed to provide an adequate level of protection for your personal information for the purposes of Data Protection Legislation.
We have put in place commercially reasonable and 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 third parties who have a business need to know. They will process your personal data on our instructions and they are subject to a duty of confidentiality.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully
- Request correction of the personal data that we hold about you
- Request erasure of your personal data. This enables you to ask to delete or remove personal data where there is no good reason for us continuing to process it. You have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below)
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes
- Request the restriction of processing of personal data. This enables you to ask to suspend the processing of personal data about you, for example if you want us to establish its accuracy or reason for processing it
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible
If you want to exercise any of the above rights, please email our data protection points of contact:
Cobham Care Limited – alan@cobhamcare.co.uk
Avon House – avonhouse@cobhamcare.co.uk
Avon Manor – avonmanor@cobhamcare.co.uk
You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection points of contact:
Cobham Care Limited – alan@cobhamcare.co.uk
Avon House – avonhouse@cobhamcare.co.uk
Avon Manor – avonmanor@cobhamcare.co.uk
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Any changes we may make to our privacy notice in the future will be published on our website at www.cobhamcare.co.uk.
This privacy notice was last updated on 17 May 2018.
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email Data Protection Points of Contact:
Cobham Care Limited – alan@cobhamcare.co.uk
Avon House – avonhouse@cobhamcare.co.uk
Avon Manor – avonmanor@cobhamcare.co.uk
Or telephone:
Cobham Care Limited – 01372 842587
Avon House – 01903 531313
Avon Manor – 01903 230049
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone – 0303 123 113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns
