Privacy Notice
This privacy notice tells you what to expect us to do with your personal information.
Contact details
What information we collect, use, and why
Lawful bases and data protection rights
Where we get personal information from
How long we keep information
Who we share information with
How to complain
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Post
7th Floor Thameside Complex, Grays, Essex, RM17 5DX, GBTelephone
01375 370460 -
We collect or use the following information to provide patient care, services, pharmaceutical products and other goods:
Name, address and contact details
Gender
Pronoun preferences
Date of birth
NHS/HSC/CHI number
Hospital number
National Insurance number
Next of Kin details including any support networks
Emergency contact details
Photographs
Health information (including medical conditions, allergies, medical requirements and medical history)
Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
Payment details (including card or bank information for transfers and direct debits)
Records of meetings and decisions
Information about income and financial needs for funding or personal budget support
We also collect the following special category information to provide patient care, services, pharmaceutical products and other goods. This information is subject to additional protection due to its sensitive nature:
Racial or ethnic origin
Religious or philosophical beliefs
Trade union membership
Health information
Sexual orientation information
We collect or use the following information for safeguarding or public protection reasons:
Name, address and contact details
NHS/HSC/CHI number
Hospital number
Emergency contact details
Photographs
Health information (including medical conditions, allergies, medical requirements and medical history)
Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions)
Relevant information from previous investigations
Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
Records of meetings and decisions
We also collect the following special category information for safeguarding or public protection reasons. This information is subject to additional protection due to its sensitive nature:
Racial or ethnic origin
Religious or philosophical beliefs
Health information
Sexual orientation information
We collect or use the following personal information to comply with legal requirements:
Name
Contact information
Identification documents
Health and safety information
Financial information
Any other personal information required to comply with legal obligations
Right to work
Tax information
Safeguarding information
Criminal offence data
We also collect the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:
Racial or ethnic origin
Religious or philosophical beliefs
Health information
Sexual orientation information
We collect or use the following personal information for recruitment purposes:
Contact details (eg name, address, telephone number or personal email address)
Date of birth
National Insurance number
Copies of passports or other photo ID
Employment history (eg job application, employment references or secondary employment)
Education history (eg qualifications)
Right to work information
Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks )
We also collect the following special category information for recruitment purposes. This information is subject to additional protection due to its sensitive nature:
Racial or ethnic origin
Religious or philosophical beliefs
Trade union membership
Health information
Sexual orientation information
We collect or use the following personal information for dealing with queries, complaints or claims:
Names and contact details
Addresses
Payment details
Account information
Purchase or service history
Witness statements and contact details
Relevant information from previous investigations
Customer or client accounts and records
Financial transaction information
Information relating to health and safety (including incident investigation details and reports and accident book records)
Correspondence
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Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
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Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests - we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Data is used to provide company services to support customers in both personal and health needs, and to provide company services & management of staff.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Recognised legitimate interests - our pre-approved purpose for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods:
We need to share personal information with a public authority or another organisation because they need it for their public tasks or official functions (the ‘public task disclosure response condition’)., We need to respond to, or deal with, an emergency event or situation (the ‘emergencies condition’)., We need to protect the physical, mental or emotional well-being of people who need extra support, or to protect them from harm or neglect (the ‘safeguarding condition’).
Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for safeguarding or public protection reasons are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Data is used to provide company services to support customers in both personal and health needs, and to provide company services & management of staff.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Recognised legitimate interests - our pre-approved purpose for collecting or using personal information for safeguarding or public protection reasons:
We need to share personal information with a public authority or another organisation because they need it for their public tasks or official functions (the ‘public task disclosure response condition’)., We need to respond to, or deal with, an emergency event or situation (the ‘emergencies condition’)., We need to protect the physical, mental or emotional well-being of people who need extra support, or to protect them from harm or neglect (the ‘safeguarding condition’).
Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information to comply with legal requirements are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Data is used to provide company services to support customers in both personal and health needs, and to provide company services & management of staff.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for recruitment purposes are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Data is used to provide company services to support customers in both personal and health needs, and to provide company services & management of staff.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Recognised legitimate interests - our pre-approved purpose for collecting or using personal information for recruitment purposes:
We need to share personal information with a public authority or another organisation because they need it for their public tasks or official functions (the ‘public task disclosure response condition’)., We need to respond to, or deal with, an emergency event or situation (the ‘emergencies condition’)., We need to protect the physical, mental or emotional well-being of people who need extra support, or to protect them from harm or neglect (the ‘safeguarding condition’).
Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Recognised legitimate interests - our pre-approved purpose for collecting or using personal information for dealing with queries, complaints or claims:
We need to share personal information with a public authority or another organisation because they need it for their public tasks or official functions (the ‘public task disclosure response condition’)., We need to respond to, or deal with, an emergency event or situation (the ‘emergencies condition’)., We need to protect the physical, mental or emotional well-being of people who need extra support, or to protect them from harm or neglect (the ‘safeguarding condition’).
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Data is used to provide company services to support customers in both personal and health needs, and to provide company services & management of staff.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
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Directly from you
Regulatory authorities
Family members or carers
Other health and care providers
Social services
Charities or voluntary sector organisations
Schools, colleges, universities or other education organisations
Councils and other public sector organisations
Relevant regulatory authorities
Previous employers
Third parties:
Talos - Recruitment
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We retain information for a minimum of three years, unless otherwise required by statutory requirements.
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Data processors
Microsoft
This data processor does the following activities for us: Provision & storage of email & file data for company use / management
Citation / Atlas
This data processor does the following activities for us: Management of HR functions for company staff
Flourish
This data processor does the following activities for us: Management of customer care data & company user access details
Nourish
This data processor does the following activities for us: Management of company staff training data & company user access details
Moneysoft
This data processor does the following activities for us: Management of company payroll data
Sage
This data processor does the following activities for us: Management of company financial data & processing of invoices
Others we share personal information with
Other health providers (eg GPs and consultants)
Charities and voluntary organisations
Care providers
Organisations we need to share information with for safeguarding reasons
Emergency services
Professional advisors
Local authorities or councils
External auditors or inspectors
Organisations we’re legally obliged to share personal information with
Current employers
Previous employers
Suppliers and service providers
Other relevant third parties:
Talos - Recruitment provider
Gather - provides customer & staff survey services
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Duty of confidentiality
We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:
you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
we have a legal requirement (including court orders) to collect, share or use the data;
on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.
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If you have any concerns about our use of your personal information, you can make a data protection complaint to us:
Email: info@choiceandcontrol.co.uk
Telephone: 01375 370460
Post: 7th Floor Thameside Complex, Orsett Road, Grays, Essex, RM17 5DX
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AFHelpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint