CARE VISIONS HEALTHY AGEING

PRIVACY POLICY

Last updated: 14 October 2020

  1. Introduction

Welcome to our Privacy Policy.

Care Visions Healthy Ageing is one of the trading names of Care Visions Limited, a private limited company (Company No. SC367451) incorporated in Scotland. Our registered office is at 4th Floor, 115 George Street, Edinburgh, Scotland, EH2 4JN. In this Privacy Policy, we refer to ourselves as “Care Visions”, “us”, “our” or “we”.

Care Visions is the data controller in relation to your personal data.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you how and why we collect your personal data, how we look after your personal data, and about your privacy rights and how the law protects you.

This Privacy Policy explains how we collect and process your personal data when you:

  1. visit our website or use our apps;
  2. contact us directly;
  3. use or subscribe to any of our services or products;
  4. participate in our research or feedback projects;
  5. collaborate with us (e.g. where you peer review our publications); and
  6. sign up to receive updates and newsletters from us.

This website, and the services we offer, are not intended for children. We do not knowingly collect data about children. If you become aware that we may have been given data about a child, please contact us as soon as possible.

It is important that you read this Privacy Policy together with any other privacy policy or privacy 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 Policy supplements other notices and privacy policies and is not intended to override them.

  1. 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 which we have grouped together as follows:

  1. Identity Data: your name, title, address, telephone/mobile number, email address, name of organisation, date of birth, gender, marital status, next of kin / emergency contact;
  2. Financial Data: bank account and payment card details;
  3. Transaction Data: details and records about payments to and from you, including details of products and services that you have purchased from us;
  4. Health Data: disabilities, current illnesses/conditions (e.g. dementia, including current stage and cognitive, neuropsychiatric and functional symptoms), current medications (and dosages), race/ethnicity and sexual orientation;
  5. GP Details: the name, address, email and phone number of your GP/doctor;
  6. Personal Descriptors: mood, lifestyle information, quality of life and personal preferences;
  7. Images and Video Data: photographs and video footage;
  8. Technical Data: 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;
  9. Profile Data: this includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
  10. Usage Data: information about how you use our website, apps, products and services; and
  11. Marketing and Communications Data: your preferences in receiving marketing from us and our third party partners, and your communication preferences. This may include where we recommend third party services (e.g. online clubs and groups) which we believe you may be interested in.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  1. How is your personal data collected?

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

  • Direct interactions: You may give us your Identity Data, Financial Data, Medical Data, and Marketing and Communication Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our website;
  • participate in our research or feedback projects;
  • collaborate with us (e.g. where you peer review our publications and research);
  • subscribe to our services or publications;
  • request marketing to be sent to you; or
  • give us general feedback or contact us.

 

  • Those responsible for you: We may be given your Identity Data, Financial Data, Medical Data, and Marketing and Communication Data by someone who has responsibility for your care or affairs (e.g. a caregiver or someone to whom you have given a power of attorney). In this case, we will also collect and process the personal data of the individual who has responsibility for you.

 

  • Third parties or publically available sources: We may obtain your Identity Data from third parties that have referred you to us or publically available sources as set out below:
  • when you are referred to us by someone who is responsible for your care, or who has authority to act on your behalf (e.g. a carer, or someone to whom you have granted power of attorney);
  • where you are referred to us by another community organisation or service provider;
  • where you are referred to us by a GP/doctor or other health professional; and
  • where we have obtained your information from publically available sources, such as your online profile/bio (e.g. where we have located you via the internet in order to contact you about peer reviewing our publications and research).

 

  • Automated technologies and interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy or further details.

Care Visions may supplement the information that you provide to us, or which we are given, with information that we receive or obtain from other sources, such as from our professional advisors, partners, and agents of Care Visions, third parties with whom we interact, and publically available sources.

 

  1. Purposes for which we use your personal data

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

Please 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 further 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 any legitimate interests pursued
Service users, and people responsible for them

Personal data related to current and prospective service users (and individuals who are responsible for them, such as caregivers) is collected and processed so that we can provide service users with the courses, services and products that they have subscribed for. Our courses and services currently consist of programs designed to provide therapeutic and non-pharmacological interventions in the form of therapies and activities for various stages and symptoms of dementia (i.e. cognitive stimulation, reminiscence therapy, physical exercise, reality orientation, music and art therapy, multisensory stimulation, massage, aromatherapy, validation therapy, food therapy, meditation and gardening therapy). These courses and services are delivered on a one-to-one basis, in groups, and remotely via live video or pre-recorded video content.

 

We also liaise with caregivers and people who have responsibility for a service user to keep them updated about a service user’s treatment and progression.

We process health information about our service users so that we can determine the most suitable courses, services and products for them, and so that we can deal with any medical emergencies whilst a service user is availing of any of our services in person (e.g. when one of our therapists delivers services at a service user’s home, or where a service user is participating in a group session).

We will also process the data of service users and those responsible for them (e.g. caregivers) for the purposes of (a) managing any payments, fees and charges, and (b) collecting and recovering money owed to us.

·       Identity

·       Financial

·       Transaction

·       Health

·       GP

·       Personal Descriptors

·       Image and Video

 

·       Performance of our contract with you.

·       Explicit consent (health data).

·       Where necessary to protect vital interests (in the event of a medical emergency).

·       Necessary for our legitimate interests (to recover debts due to us).

 

 

 

Relationship management

To manage our relationship with you which may include:

(a)   communicating with you;

(b)   notifying you about changes to our terms or Privacy Policy; and

(c)    asking you to leave a review or take a survey.

 

·       Identity

·       Profile

·       Marketing and Communications

·       Performance of our contract with you.

·       Necessary to comply with a legal obligation.

·       Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

 

Research, innovation, feedback and promotion

We may process your personal data for research and development, feedback and promotional purposes (e.g. conducting research into the effectiveness of our services in treating dementia, conducting feedback sessions and projects, publishing articles and findings based on our research, and compiling case studies of service users).

We may from time to time also process images and video footage of service users for research and development, feedback, and promotional purposes (e.g. images and video content taken for inclusion in awareness and publicity materials).

Service users will not be identifiable in any final material or research findings that we publish, any case studies we compile, or in any promotional material, unless we have obtained their explicit consent for this purpose.

·       Identity

·       Health

·       Personal Descriptors

·       Image and Video

·       Explicit consent (when we process data about health, race/ethnicity, or sexual orientation; where a service user agrees to be identified in any research, case studies or promotional materials we publish where such identification would reveal information about their health, ethnicity/race or sexual orientation).

·       Consent (where we rely on an individual’s consent for their participation in one of our feedback or research projects; images and videos of service users used for research development or promotional purposes).

·       Necessary for our legitimate interests (to conduct research and development, and to promote our business).

Care Visions App

We process information about you when you use our App. Our App is designed to provide information and videos to caregivers that assist them in doing therapeutic activities with individuals suffering from dementia, both in their home and in a nursing or care home setting.

·       Identity

·       Financial

·       Transaction

·       Technical

·       Profile

·       Usage

·       Marketing and Communication

·       Performance of our contract with you.

·       Consent (where you use the app to opt-in to receive updates and promotional materials form us).

·       Necessary for our legitimate interests (keeping you informed of our products and services, and developing our business).

 

Collaborating with us

We may process your information where you collaborate with us (e.g. where you contribute towards courses or services provided by us (or which you jointly provide with us), or where you peer review our research and publications.

·       Identity

·       Financial

·       Performance of our contract with you.

·       Necessary for our legitimate interests (to allow you to collaborate with us, where there is no formal contract between you and us).

Administration

To administer and protect our business, this website and our apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

(a)   Identity

(b)   Financial

(c)    Transaction

(d)   Technical

(e)   Profile

(f)     Usage

(g)   Marketing and Communication

(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.

 

Website, online and app advertising

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)   Profile

(c)    Usage

(d)   Technical

(e)   Marketing and Communication

Necessary for our legitimate interests (to study how service users use our products/services, to develop them, to keep our website and apps updated and relevant, to develop our business and to inform our marketing strategy).

 

Improving our website, apps and products/services

 To use data analytics to improve our website, apps, products and services, marketing, customer relationships and experiences.

 

(a)   Technical

(b)   Usage

Necessary for our legitimate interests (to define types of service users for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

 

Keeping you informed

 To make suggestions and recommendations to you about products and services that may be of interest to you or someone for someone for whom you are a caregiver.

 

(a)   Identity

(b)   Technical

(c)    Usage

(d)   Profile

(e)   Marketing and Communications

(a)   Consent (where you have opted-in to receive updates and promotional materials form us, for example, on our website).

(b)   Necessary for our legitimate interests (to develop our products/services and grow our business).

Marketing

We may use your Identity Data, Technical Data, Usage Data and Marketing and Communication 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 updates, products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information from us, or subscribed to or purchased products or services from us and you have not opted-out of receiving that marketing. Alternatively, you may receive marketing communications where you have specifically opted-in to receive these (for example, by signing up for updates or newsletters on our website, or by signing up whilst using our apps).

You can ask us to stop sending you marketing at any time by clicking “unsubscribe” on any email marketing sent to you, by changing your preferences in our apps, or alternatively by contacting our Data Protection Manager on the details below.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Cookies

This website uses cookies to improve your experience while you navigate through the website. Out of these cookies, the cookies that are categorised as “necessary” are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyse and understand how you use this website. These cookies will be stored in your browser only with your consent.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only process your personal data for the purposes for which we collect 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 which 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.

  1. Disclosure and transfer of your personal data

We may share your personal data with the third parties set out below for the purposes set out in the table at section 4 (Purposes for which we use your personal data) above:

  • where you are a service user or person with responsibility for a service user, we may share your personal data with therapeutic and health care professionals/practitioners that are providing products and services to you, or to someone for whom you are responsible. This is so they can provide the products or services requested, communicate with you for this purpose, and provide you with feedback and updates on the provision of the products and services (e.g. how much progress a service user has made with the chosen treatment option, and what further actions require to be taken);
  • where you are a service user for whom someone else is exercising responsibility (e.g. where you have a caregiver, or a duly appointed attorney who acts on your behalf), we will disclose your information to the person exercising responsibility for you;
  • vendors who will process your personal data on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers, financial institutions, customer relationship management vendors and other cloud-based solutions providers that are used but us in the conducting our business. We contract with such vendors to ensure that they only process your personal data under our instructions and ensure the security and confidentiality of your personal data by implementing the appropriate technical and organisational measures for such processing;
  • where you (or someone for whom you have responsibility) participate in our research or feedback projects, we may disclose your personal data to our trusted third party research partners who we have engaged to conduct the research / feedback project on our behalf;
  • our professional advisors (e.g. lawyers, accountants, etc);
  • third parties to whom we are required to transfer personal data by law, such as law enforcement bodies, governmental and regulatory bodies, the courts and other competent authorities that may request personal data in connection with any inquiry, court order, or other legal or regulatory procedures which we would need to comply with; we may also share personal data to establish or protect our legal rights, property or safety, or the rights, property or safety of others, or to defend against legal claims; and
  • any third party connected with business transfers; we may transfer your personal data to third parties, in connection with a reorganisation, restructuring, merger, acquisition, or transfer of our business or assets, provided that the receiving party agrees to treat your personal data in a manner consistent with data protection law.
  1. International transfers

We may transfer your personal data to controllers or processors located outside of the United Kingdom and/or the European Economic Area (EEA). This is primarily to allow us to receive IT services (e.g. cloud storage services, email/webmail services and customer relationship management services) from vendors located in non-UK or non-EEA jurisdictions. However, we will only transfer your personal data to a vendor in a non-UK or non-EEA country where:

  1. such countries have been deemed to provide an adequate level of protection for personal data by the relevant authorities in the UK or the European Commission;
  2. where we have in place a valid data transfer agreement with the data recipient (such as the European Commission standard contractual clauses, or any equivalent clauses approved by the authorities in the UK); or
  3. where we are otherwise permitted to make the transfer under data protection law.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. Data security

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.

  1. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

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, regulatory, tax, accounting or other requirements.

When we no longer need to use your personal data, we will remove it from our systems and records, and or take steps to anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations we are subject to).

In some circumstances you can ask us to delete your data (please see “Your legal rights” below for further information).

  1. Your legal rights

Under data protection law, you have certain rights in relation to your personal data:

  1. 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.
  2. 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.
  3. 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 applicable law. Please note however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  4. 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 which 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 which override your rights and freedoms.
  5. 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:
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you don’t want us to erase it;
  • 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
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  1. 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 which you initially provided consent for us to use or where we used the information to perform a contract with you.
  2. 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.

No fee usually required

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 is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data, or access someone else’s personal data on their behalf (or to exercise any of the other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. Third-party links

This website and our apps may include links to third-party websites, plug-ins and applications. 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 or apps, we encourage you to read the privacy policy of every website you visit.

  1. Contact us

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions in relation to this Privacy Policy, including any requests to exercise your legal rights (or someone else’s legal rights on their behalf), please contact the Data Privacy Manager using the details below.

Data Security & Protection Lead (Healthy Ageing)
Care Visions Healthy Ageing
Bremner House
Castle Business Park
Stirling
FK9 4TF

Email: DataProtectionLead-HA@carevisions.co.uk

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.

  1. Keeping your information up to date

To help Care Visions keep accurate information, you must tell the Data Privacy Manager about changes to information or personal details relating to you, or to someone for whom you are exercising responsibility, in particular, any changes to contact or financial details. If you know that Care Visions holds any personal details about you, or someone for whom you exercise responsibility, that are out of date or inaccurate, you must tell Care Visions as soon as possible.

  1. Notification of changes

Care Visions may update this Privacy Policy from time to time as our privacy practices change, or as required by applicable legal or regulatory requirements. Where it is practicable, we will notify you of any significant changes. However, the last update date is given at the start of this Privacy Policy, and we encourage you to review this Privacy Policy periodically so you remain informed of how we use your personal data.

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