GDPR

Cedar Trust collects personal information which helps us care for our employees and volunteers, residents, their families and loved ones. We are committed to protecting your personal data and handling it responsibly in line with data protection law, including the General Data Protection Regulations (GDPR), and the Data Protection Act 2018 (DPA).

Personal information is any information that identifies a living individual. This privacy policy explains what information we intend to use, how we use it, the legal reasons for using your information, and your rights under the law. When we refer to “we,” “our,” or “us” in this policy, we are referring to CTCH Ltd.

As a company CTCH Ltd. is dedicated to making sure that personal information is used properly according to the law, and that confidential information entrusted to us is safe and we have updated our Privacy Policy to explain how we manage your data. The changes we have made are in line with new data protection laws, known as the General Data Protection Regulation (GDPR), which is effective from 25^th May 2018. This is part of our ongoing commitment to be transparent about how we use your personal data and keep it safe.

Our Head Office team at CTCH Ltd. are here to help safeguard the way your information is used, and uphold your information rights. If you have any concerns or questions about how your information is being used, we would like to hear from you, and can be contacted on the details below:

Email: info@cedartrust.co.uk Telephone: 01684 290 666 Address: Cedar Lodge, Grange Road, Tewkesbury, GL20 8HZ

You also have the right to contact the Information Commissioner’s Office (ICO) if you have a complaint about the way your information is being used. The ICO can be contacted on the details below:

Email: casework@ico.org.uk Telephone: 0303 123 1113 Address: Information Commissioner’s Office Wycliffe House, Water Lane Wilmslow Cheshire SK9 5AF

FOR RESIDENTS

Where we use the term “Residents” we refer to residents in our Nursing & Residential Care Homes whom we care for.

What & How We Collect Personal Information We Use

We use your personal information so that we can fulfil our contract to care for you and we collect only enough information to allow us to provide you with the best possible care.

The information we collect from you which is relevant to your stay with us and the care we provide to you includes:

• personal details(such as name, date of birth, gender, marital status, national insurance number);
• contact details(such as your previous address, personal telephone number and personal email address);
• financial information(such as your bank account details and information about your financial circumstances);
• your likes and dislikes(relating to hobbies, food, routines and other categories of likes and dislikes which help us improve your care);
• information about your care preferences(to ensure that we are providing you with the care that you want);
• details of your life history (to ensure that we help you feel at home with us it is important for us to get to know you as best we can);  
• information about your family and friends(for the purpose of visiting, next of kin and emergency contact details);
• information about external healthcare providers (such as your GP and practice details);
• video and photographs of you (such as CCTV footage, photographs for security purposes, etc):
• information about your long term wishes(such your desired arrangements in the event that you pass away while staying with us);

Due to the fact that circumstances are variable and change with time, there may some instances where information is required outside the list above.

Some of the information which we collect about you may be “special categories of personal data” that require a greater level of protection. The special categories of personal data about you which we may collect include:

• information about your racial or ethnic origin; 
• information about your religious beliefs; 
• information about your sex life andsexual orientation;
• healthcare information, including
  • any disabilities or special requirements which you may have;
  • medical records applying to the time you have spent with us;
  • your medical history
  • records required by care home regulations, like risk assessments, care plans and records of the care we provide to you; and
  • details of your support and care needs.

We may also collect personal information about you from other people and organisations, such as:

• Medical and health information, from health and social care organisations and professionals, including medical notes and reports about your health and any treatment and care you have received or need
• Social care and safeguarding reports, assessments, and referrals

How And Why We Use Your Personal Data

We use the following lawful basis condition for processing your data as a resident in our care homes:

• Article 6(1)(b) “…processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract…”
• Article 6(1)(e) “…processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller….”
• Article 9(2)(h) “…processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3…”

This means we will comply with data protection law when using your personal information and at the heart of data protection laws are the “data protection principles” which say that the personal information we hold about you must be:

• used lawfully, fairly and in a transparent way;
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• relevant to the purposes we have told you about and limited only to those purposes;
• accurate and kept up to date;
• kept only as long as necessary for the purposes we have told you about; and
• kept securely.

Set out below are the different purposes for which we collect and use your personal data along with the lawful basis on which we rely

It is important that we are able to provide continued good care to you as a Resident and also to comply with our regulatory responsibilities in doing so but we cannot do this without access to your Personal Data. If you refuse to provide us with information which we need in order to consider your admission we may not be able to provide you with a place at one of our homes. During your stay with us if you refuse to provide us with information which we request from time to time, we may not be able to provide you with continuing care and support.

We typically will only use your personal information for the purposes for which we collect it. It is possible that we will use your information for other purposes as long as those other purposes are compatible with those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose. We may also use your personal information for other purposes where such use is required or permitted by law.

Sharing Your Information

We share your personal information under certain circumstances but when we do share information, we use as little as possible, and on a need to know basis and we will only share your personal information with the relevant third parties that contribute to your care where we have a lawful basis for doing so. Your date will NOT transfer outside the EU.

The types of organisations with whom we share your personal data are as follows:

• Healthcare providers and multi-disciplinary teams: Where it is lawful and necessary to do so, we will share information about you with other healthcare providers such as your GP, hospital staff, etc.
• Friend and family: Where you have indicated that you are happy for that information to be shared.
• Regulators / Safeguarding authorities / Commissioners:We also share your personal data with these public bodies where we are required to do so by law.
• The Police and other law enforcement agencies:In limited circumstances we may be required to share your personal data with the police if required for the purposes of criminal investigations and law enforcement.
• IT service providers:We may use external IT providers who may have access to your personal data from time to time as is necessary to perform their services.
• Attorneys: Where it is lawful to do so, we may share your personal information with any individual who has authority to act on your behalf such as those granted power of attorney.

Storing Your Personal Data

• We take the privacy and security of your personal data very seriously. We ensure we handle your data with the highest level of care by having clear internal policies and procedures, physical security to our premises and IT security technologies to prevent the unauthorised access, damage and loss of your data.
• The personal data that we collect from you is only stored inside the European Economic Area (EEA), therefore ensuring we achieve the maximum privacy and security in line with UK Data Protection Laws.

Retention of Information

• We will only keep your information for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, contractual or reporting requirements. How long we keep the data for is determined by law and is largely determined by necessity but information in care records is retained for at least 7 years after we provide care to you.
• Whilst at all times compliant with legislation and acting reasonably, we reserve the right to judge what information we must continue to hold to be able to fulfil our legal and contractual obligations to you.
• Once your information is no longer required it will be securely destroyed.
• We may anonymise your personal data (so that you can no longer be identified) for the purposes of ensuring we continue to understand how to provide good care in which case we may use this information indefinitely without further notice to you.

FOR EMPLOYEES, CONTRACTORS & VOLUNTEERS (INCLUDING APPLICANTS)

What & How We Collect Personal Information We Use

We use your personal information to fulfil our obligations to you as an employer, to ensure you are paid for your work and that you are protected in the work place.

The information we collect from you, as well as creating information once you have been successful in a job application includes:

• personal details(such as name, date of birth, gender, ethnicity, age, race);
• contact details(such as your address, personal telephone number and personal email address and other contact details);
• identification information we create for you (including employee reference, pay rates, payroll number and job role);
• financial information(such as your bank account details, pension details and national insurance number);
• education(any professional registration, status or qualifications such as nursing registration and validation);
• information relating to leave(including annual leave, maternity, paternity, adoption and shared paternal leave);
• medical and health information (including sick leave, allergies or occupational health requirements);  
• video and photographs of you (such as CCTV footage, photographs for security purposes, etc):

We may also collect personal information about you from other people and organisations, such as:

• Criminal record check conducted by the Disclosure & Barring Service (DBS)
• Confidential references from referees that you have given to us, which contain information about you
• Information we receive from HMRC such as tax codes
• Our finance team receive information from the courts if you have an been issues attachment of earnings order (AEO) by the courts

Why & How We Use Your Personal Data

We use the following lawful basis condition for processing your data as an employee:

• Article 6(1)(b) “…processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract…”
• Article 6(1)(e) “…processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller….”
• Article 9(2)(h) “…processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3…”

This means we will comply with data protection law when using your personal information and at the heart of data protection laws are the “data protection principles” which say that the personal information we hold about you must be:

• used lawfully, fairly and in a transparent way;
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• relevant to the purposes we have told you about and limited only to those purposes;
• accurate and kept up to date;
• kept only as long as necessary for the purposes we have told you about; and
• kept securely.

Set out below are the different purposes for which we collect and use your personal data along with the lawful basis on which we rely

Sharing Your Information

We share your personal information under certain circumstances but when we do share information, we use as little as possible, and on a need to know basis and we will only share your personal information with the relevant third parties that contribute to your care where we have a lawful basis for doing so. Your date will NOT transfer outside the EU.

The types of organisations with whom you share your Personal Data are as follwos:

• Healthcare Professionals: Where you require emergency medical treatment to ensure you receive appropriate treatment.
• HMRC: To ensure that you are taxed correctly.
• Pension Providers & Reward Partners: Where you have asked us to.
• Organisations for Personal Applications (such as mortgages or rental agreements): Where you have asked us to, we will share your personal details, including details of your earnings, length of service, employment status, etc.
• Regulatory Body (such as the NMC): To ensure that you are registered, monitor your need to revalidate, and report misconduct
• Marketing Materials and Publications: Where you have consented we will share your
• Centralised Attachment of Earning Payment (CAPS): Where you have been issued with an attachment of earnings order (AEO), we will inform the

Storing Your Personal Data

• We take the privacy and security of your personal data very seriously. We ensure we handle your data with the highest level of care by having clear internal policies and procedures, physical security to our premises and IT security technologies to prevent the unauthorised access, damage and loss of your data.
• The personal data that we collect from you is only stored inside the European Economic Area (EEA), therefore ensuring we achieve the maximum privacy and security in line with UK Data Protection Laws.

Retention of Information

• We will only keep your information for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, contractual or reporting requirements. How long we keep the data for is determined by law and is largely determined by necessity but information in employment records is retained for at least 3 years after you stop working for us.
• Whilst at all times compliant with legislation and acting reasonably, we reserve the right to judge what information we must continue to hold to be able to fulfil our legal and contractual obligations to you.
• Once your information is no longer required it will be securely destroyed.
• We may anonymise your personal data (so that you can no longer be identified) for the purposes of research in which case we may use this information indefinitely without further notice to you.

FOR POWER OF ATTORNEYS, RELATIVES & FRIENDS

What & How We Collect Personal Information We Use

We use your personal information so that we can understand if there are power of attorneys, relatives and friends, who they are, who to contact in an emergency situation, and our residents’ visitor preferences.

We collect information from you, we also collect information from our residents or employees, this includes:

• personal details(such as name, date of birth);
• contact details(such as your address, personal telephone number and personal email address and other contact details);
• power of attorney (legal responsibility for a resident);

Why & How We Use Your Personal Data

We use the following lawful basis condition for processing your data as power of attorney, relative or friend of a resident:

• Article 6(1)(b) “…processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract…”
• Article 6(1)(e) “…processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller….”
• Article 9(2)(h) “…processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3…”

This means we will comply with data protection law when using your personal information and at the heart of data protection laws are the “data protection principles” which say that the personal information we hold about you must be:

• used lawfully, fairly and in a transparent way;
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• relevant to the purposes we have told you about and limited only to those purposes;
• accurate and kept up to date;
• kept only as long as necessary for the purposes we have told you about; and
• kept securely.

Set out below are the different purposes for which we collect and use your personal data along with the lawful basis on which we rely

Sharing Your Information

We share your personal information under certain circumstances but when we do share information, we use as little as possible, and on a need to know basis and we will only share your personal information with the relevant third parties that contribute to your care where we have a lawful basis for doing so. Your date will NOT transfer outside the EU.

• Healthcare Professionals: Where you require emergency medical treatment to ensure you receive appropriate treatment
• Marketing Materials and Publications: Where you are happy for us to do so

Storing Your Personal Data

• We take the privacy and security of your personal data very seriously. We ensure we handle your data with the highest level of care by having clear internal policies and procedures, physical security to our premises and IT security technologies to prevent the unauthorised access, damage and loss of your data.
• The personal data that we collect from you is only stored inside the European Economic Area (EEA), therefore ensuring we achieve the maximum privacy and security in line with UK Data Protection Laws.

Retention of Information

• We will only keep your information for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, contractual or reporting requirements. How long we keep the data for is determined by law and is largely determined by necessity but information in employment records is retained for at least 7 years from your last contact with us.
• Whilst at all times compliant with legislation and acting reasonably, we reserve the right to judge what information we must continue to hold to be able to fulfil our legal and contractual obligations to you.
• Once your information is no longer required it will be securely destroyed.
• We may anonymise your personal data (so that you can no longer be identified) for the purposes of research in which case we may use this information indefinitely without further notice to you.

FOR SUPPLIERS

What & How We Collect Personal Information We Use

We use your personal information as part of procurement of services and supplies

We collect information from all supplier employees we come into contact with, this includes:

• personal details(such as name);
• contact details(such as your address, personal telephone number and personal email address and other contact details);
• financial information (if you are a sole trader we collect financial information including bank account details);

Why & How We Use Your Personal Data

We use the following lawful basis condition for processing your data as a Supplier

• Article 6(1)(b) “…processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract…”
• Article 6(1)(e) “…processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller….”
• Article 9(2)(h) “…processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3…”

This means we will comply with data protection law when using your personal information and at the heart of data protection laws are the “data protection principles” which say that the personal information we hold about you must be:

• used lawfully, fairly and in a transparent way;
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• relevant to the purposes we have told you about and limited only to those purposes;
• accurate and kept up to date;
• kept only as long as necessary for the purposes we have told you about; and
• kept securely.

Set out below are the different purposes for which we collect and use your personal data along with the lawful basis on which we rely

Sharing Your Information

We share your personal information under certain circumstances but when we do share information, we use as little as possible, and on a need to know basis and we will only share your personal information with the relevant third parties that contribute to your care where we have a lawful basis for doing so. Your date will NOT transfer outside the EU.

If you are seeking to enter into a contract with us and are not a sole trader, we do to intend to share any of your personal information. Where you are a sole trader we will share financial information with our bank.

Storing Your Personal Data

• We take the privacy and security of your personal data very seriously. We ensure we handle your data with the highest level of care by having clear internal policies and procedures, physical security to our premises and IT security technologies to prevent the unauthorised access, damage and loss of your data.
• The personal data that we collect from you is only stored inside the European Economic Area (EEA), therefore ensuring we achieve the maximum privacy and security in line with UK Data Protection Laws.

Retention of Information

• We will only keep your information for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, contractual or reporting requirements.
• We retain personal information relating to suppliers for 6 years following the end of the contract or services delivered.
• Whilst at all times compliant with legislation and acting reasonably, we reserve the right to judge what information we must continue to hold to be able to fulfil our legal and contractual obligations to you.
• Once your information is no longer required it will be securely destroyed.

FOR ENQUIRIES & COMPLAINTS

What & How We Collect Personal Information We Use

You may contact CTCH Ltd seeking information about the care that is available in our different care homes or you may also contact us as a member of the public with a compliant

We collect information from you which includes:

• personal details(such as name);
• contact details(such as your address, personal telephone number and personal email address and other contact details);
• other information (information in relation to your complaint);

Why & How We Use Your Personal Data

We use the following lawful basis condition for processing your data as a Supplier

• Article 6(1)(b) “…processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract…”
• Article 6(1)(e) “…processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller….”
• Article 9(2)(h) “…processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3…”

This means we will comply with data protection law when using your personal information and at the heart of data protection laws are the “data protection principles” which say that the personal information we hold about you must be:

• used lawfully, fairly and in a transparent way;
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• relevant to the purposes we have told you about and limited only to those purposes;
• accurate and kept up to date;
• kept only as long as necessary for the purposes we have told you about; and
• kept securely.

Set out below are the different purposes for which we collect and use your personal data along with the lawful basis on which we rely

Sharing Your Information

We do not intend to share your information.

Storing Your Personal Data

• We take the privacy and security of your personal data very seriously. We ensure we handle your data with the highest level of care by having clear internal policies and procedures, physical security to our premises and IT security technologies to prevent the unauthorised access, damage and loss of your data.
• The personal data that we collect from you is only stored inside the European Economic Area (EEA), therefore ensuring we achieve the maximum privacy and security in line with UK Data Protection Laws.

Retention of Information

• We will only keep your information for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, contractual or reporting requirements.
• We retain personal information relating to enquiries for 1 year after the enquiry is made
• We retain information relating to complaints for no more than 6 years following the closure of the complaint.
• Whilst at all times compliant with legislation and acting reasonably, we reserve the right to judge what information we must continue to hold to be able to fulfil our legal and contractual obligations to you.
• Once your information is no longer required it will be securely destroyed.

YOUR RIGHTS

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correctionof the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasureof your personal information in certain circumstances. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to processingof your personal information where we are relying on a legitimate interest (or those of a third party) or public interest as our lawful basis for processing and there is something about your particular situation which leads you to object to processing on this ground. You also have the right to object if we are processing your personal information for direct marketing purposes.
• Request the restriction of processingof your personal information. This also permits you to request the suspension of processing personal information about you if you wanted us to establish its accuracy or the reason for processing it (for example).
• Request the transferof your personal information to another party in certain circumstances.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Head Office team in writing at Cedar Lodge, Grange Road, Tewkesbury, GL20 8HZ.

RIGHT TO WITHDRAW CONSENT  

In the circumstances where we are relying on your consent as our lawful basis to process your 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 contact our Head Office team in writing at Cedar Lodge, Grange Road, Tewkesbury, GL20 8HZ.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

AUTOMATED DECISION MAKING

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

CHANGES TO THIS PRIVACY STATEMENT

We reserve the right to update this privacy statement at any time, and we will provide you with a new privacy statement when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.