1. Purpose
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The purpose of this policy is to provide a template privacy policy that Simply Safe Care Group Ltd can adapt to use on its website. The privacy policy will apply to all users of Simply Safe Care Group Ltd's website.
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By using the template privacy policy provided, Simply Safe Care Group Ltd will ensure that the policy on its website is GDPR compliant.
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To meet the legal requirements of the regulated activities that Simply Safe Care Group Ltd is registered to provide:
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General Data Protection Regulation 2016
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Data Protection Act 2018
2. Scope
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The following roles may be affected by this policy:
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All staff
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The following people may be affected by this policy:
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Individuals
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The following stakeholders may be affected by this policy:
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Family
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Advocates
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Representatives
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Commissioners
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External health professionals
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Local Authority
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NHS
3. Objectives
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The objective of this policy is to provide assurance that Simply Safe Care Group Ltd have a privacy policy in place for users of the Simply Safe Care Group Ltd website that is GDPR compliant.
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This policy will assist with establishing ways of working in terms of the use, storage, retention and security of personal data and will ensure that all Data Subjects, including Individuals, understand the ways in which personal data collected by Simply Safe Care Group Ltd via its website is processed.
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Simply Safe Care Group Ltd understands that if it operates a website, it may need to update its privacy policy to ensure it is compliant with GDPR. Simply Safe Care Group Ltd will use this privacy policy as a template for its updated version. Simply Safe Care Group Ltd understands that this privacy policy only needs to be uploaded by Simply Safe Care Group Ltd to its website if it collects personal data via its website. Simply Safe Care Group Ltd will use the template Fair Processing Notice to inform all other Data Subjects, including Individuals, about how Simply Safe Care Group Ltd processes personal data other than personal data collected via the website.
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Simply Safe Care Group Ltd understands that the form attached to this policy constitutes the template privacy policy. Simply Safe Care Group Ltd understands that terms in square brackets are optional (depending on whether they apply to Simply Safe Care Group Ltd or not) or require completion by Simply Safe Care Group Ltd. Simply Safe Care Group Ltd will review the privacy policy in its entirety to determine which elements are applicable to Simply Safe Care Group Ltd's website, and which are not relevant. For example:
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If the template privacy policy below refers to personal data that is not collected by Simply Safe Care Group Ltd via its website, Simply Safe Care Group Ltd will delete references to such personal data
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If Simply Safe Care Group Ltd's website does not use cookies, Simply Safe Care Group Ltd will delete references to cookies and Simply Safe Care Group Ltd's cookie policy
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If Simply Safe Care Group Ltd does not transfer personal data outside of the EEA, Simply Safe Care Group Ltd will delete the section entitled "Where we store your personal data"
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If Simply Safe Care Group Ltd is not required to appoint a Data Protection Officer, Simply Safe Care Group Ltd will delete references to the Data Protection Officer or will consider replacing references to the Data Protection Officer with references to Simply Safe Care Group Ltd's Privacy Officer or other person nominated to have day-to-day responsibility for data protection and GDPR
If Simply Safe Care Group Ltd uses personal data collected via its website in a way that is not described in the privacy policy, it will consider incorporating additional sections.
This privacy policy directs users to a webpage with a contact form or contact details if they wish to
contact Simply Safe Care Group Ltd. Simply Safe Care Group Ltd will consider whether to provide an alternative contact method instead, such as an email address and/or phone number.
If Simply Safe Care Group Ltd has any concerns or queries in respect of the template privacy policy, it will seek legal advice.
5. Procedure
Simply Safe Care Group Ltd will consider whether or not it collects personal data via its website (for example, via enquiry forms, requests to be
sent newsletters, requests for provision of services) and whether it needs a privacy policy. Simply Safe Care Group Ltd acknowledges that the
use of cookies constitutes processing of personal data via the website.
Simply Safe Care Group Ltd will review the template privacy policy. Simply Safe Care Group Ltd will adapt the privacy policy before uploading it to its website to ensure that all aspects of the privacy policy are relevant and reflect the ways in which Simply Safe Care Group Ltd processes personal data collected via its website. Where Simply Safe Care Group Ltd has any concerns or queries in relation to their own Privacy Statement, Simply Safe Care Group Ltd will seek legal advice.
Simply Safe Care Group Ltd should use the template Fair Processing Notice to inform all other Data Subjects, including Individuals, about how Simply Safe Care Group Ltd processes personal data other than personal data collected via the website.
Data Subject
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The individual about whom Simply Safe Care Group Ltd has collected personal data
Data Protection Act 2018
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The Data Protection Act 2018 is a United Kingdom Act of Parliament that updates data protection laws in the UK. It sits alongside the General Data Protection Regulation and implements the EU's Law Enforcement Directive
GDPR
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General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union. It was adopted on 14 April 2016 and after a two- year trasition period became enforceable on 25 May 2018
Personal Data
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Any information about a living person including but not limited to names, email addresses, postal addresses, job roles, photographs, CCTV and special categories of data, as defined below.
Process or Processing
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Doing anything with personal data, including but not limited to collecting, storing, holding, using, amending or transferring it. Simply Safe Care Group Ltd does not need to be doing anything actively with personal data - at the point Simply Safe Care Group Ltd collects it, it is processing it
Special Categories of Data
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Has an equivalent meaning to "Sensitive Personal Data" under the Data Protection Act 2018. Special categories of data include but are not limited to medical and health records (including information collected as a result of providing health care services), Care Plans and information about a person's religious beliefs, ethnic origin and race, sexual orientation and political views
Cookies
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Cookies are small files which are stored on a user's computer. They are designed to hold a modest amount of data specific to a particular client and website and can be accessed either by the web server or the client's computer
Key Facts - Professionals
Professionals providing this service should be aware of the following:
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The privacy policy applies to personal data collected via Simply Safe Care Group Ltd's website
Key Facts - People Affected by The Service
People affected by this service should be aware of the following:
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Personal data provided to Simply Safe Care Group Ltd via its website will be processed in accordance with Simply Safe Care Group Ltd's privacy policy
Further Reading
As well as the information in the 'Underpinning Knowledge' section of the review sheet we recommend that you add to your understanding in this policy area by considering the following materials:
Cookies:http://www.bbc.co.uk/webwise/guides/about-cookies
Outstanding Practice
To be ‘Outstanding’ in this policy area you could provide evidence that:
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Simply Safe Care Group Ltd has modified the template privacy policy to ensure it includes all information relevant to the collection of personal data via Simply Safe Care Group Ltd's website and has uploaded it to its website
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Simply Safe Care Group Ltd should ensure that clear links are available to the privacy policy on its website and that, if a person inputs personal data into the website, they are directed to the policy and required to accept its terms
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The wide understanding of the policy is enabled by proactive use of the QCS App
Forms
The following forms are included as part of this policy:
Title of form
When would the form be used?
Created by
Website Privacy Statement
When the Provider has a website.
QCS
Cookies Example Policy Statement
When the website has no cookies information. It can be used with the Website Privacy Statement.
QCS
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WEBSITE PRIVACY STATEMENT
We are Simply Safe Care Group Ltd, a [company] incorporated in [England and Wales] [Scotland]. Our company number is [insert registered company number] and our registered address is unit 2
Hendy industrial Est Hendy
Swansea
West Glamorgan SA4 0XP
United Kingdom
("Simply Safe Care Group Ltd" / "we" / "our" / "us"). We are committed to ensuring that your privacy is protected. We comply with the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) unless and until the GDPR is no longer directly applicable in the UK, together with any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, and any successor legislation to the GDPR and the DPA (together “Data Protection Legislation”). We are the data controller of data you pass to us pursuant to this policy. Our Data Protection Officer can be contacted at [insert email address for DPO. If there is no DPO, delete reference to them].
This Privacy Policy [together with our website terms and conditions and cookie policy] sets out how we collect personal information from you and how the personal information you provide will be processed by us. By visiting the website at [Insert hyperlink] (the “Website”) you are accepting and consenting to the practices described in this Privacy Policy. If you do not consent, please do not submit any personal data to us.
What information does Simply Safe Care Group Ltd hold and how will we use it?
Information you give Simply Safe Care Group Ltd: You may give us information about you by completing enquiry forms on the website or by requesting via the website that we send you marketing information [or [insert any other reason for which a person may upload their personal data to the website]. The information you give us may include your name, email address, address/location and phone number [if there are any other types of personal data that Simply Safe Care Group Ltd collects via the website, add them to this list. This does not include all personal data processed by Simply Safe Care Group Ltd but only personal data it collects through its website].
We will retain this information while we are corresponding with you or providing services to you or to a Individual you represent. We will retain this information for [insert the relevant retention period for the types of personal data listed above. If it is not possible to insert the retention period, explain the criteria Simply Safe Care Group Ltd uses for determining how long it will retain the personal data. Refer to the Records Management Code of Practice for Health and Social Care if required].
Information Simply Safe Care Group Ltd collects about you: Simply Safe Care Group Ltd may collect the following information from you when you visit the website:
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Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
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Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from the website (including date and time), products you viewed or searched for, page response times, website errors, length of visits to certain pages, page interaction information, methods used to browse away from the page and any phone number used to call our helpline
We retain this information for [insert the relevant retention period for the types of personal data listed above. If it is not possible to insert the retention period, explain the criteria Simply Safe Care Group Ltd uses for
determining how long it will retain the personal data].
Information we receive from other sources: This includes information we receive about you when you use other websites operated by us or other services we provide. This information may include your name, email address, postal address and phone number. We will retain this information for [insert the relevant retention period for the types of personal data listed above. If it is not possible to insert the retention period, explain the criteria Simply Safe Care Group Ltd uses for determining how long it will retain the personal data].
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Cookies
The Website uses cookies to distinguish you from other users of the website. For detailed information on the cookies we use and the purposes for which we use them, please see our cookie policy [insert hyperlink to cookie policy].
Use Made of the Information
Simply Safe Care Group Ltd may use the information we receive and/or collect about you to:
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Fulfil our obligations under any contract we have entered into with you or with a Individual you represent, and to provide you or the relevant Individual with information or services you or the Individual has requested
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Send you newsletters and marketing information if you have consented to us doing so
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Notify you of products and services we feel may interest you, or permit third parties to do so if you have provided the appropriate consent
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Monitor website usage and provide statistics to third parties for the purposes of improving and developing the website and the services we provide via the website
Simply Safe Care Group Ltd processes personal information for certain legitimate business purposes, which include some or all the following:
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Where the processing enables Simply Safe Care Group Ltd to enhance, modify, personalise or otherwise improve the website, its services or communications
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To identify and prevent fraud
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To enhance the security of Simply Safe Care Group Ltd's network and information systems
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To better understand how people interact with Simply Safe Care Group Ltd's websites
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To administer the website and carry out data analysis, troubleshooting and testing; and
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To determine the effectiveness of promotional campaigns and advertising
If we obtain consent from you to do so, we may provide your personal details to third parties so that they can contact you directly in respect of services in which you may be interested.
Where we are processing personal data we have obtained via the website on the basis of having obtained consent from you, you have the right to withdraw your consent to the processing of your personal data at any time. If you would like to withdraw your consent or prefer not to receive any of the above-mentioned information (or if you only want to receive certain information from us) please let us know by contacting us via the following webpage [insert link to webpage]. Please bear in mind that if you object, this may affect our ability to carry out the tasks above for your benefit.
If you wish to have your information removed from our database or if you do not want us to contact you for marketing purposes, please let us know by clicking the "Unsubscribe" option in any email we send to you and providing the details requested or by contacting us via the following webpage [insert webpage link] and we will take steps to ensure that this information is deleted as soon as reasonably practicable.
We will not share, sell or distribute any of the information you provide to us (other than as set out in this policy) without your prior consent, unless required to do so by law.
We may carry out automated decision-making using the personal data you provide to us. We do so to [insert an explanation about the automated decision-making (including profiling) that you carry out. You should explain the logic involved and the significance and potential consequences for the Data Subject. For example, if you track their behaviour on your website to send targeted advertising, explain this process. If you do not carry out any automated decision making, you can delete this policy entry].
Third Party Sites
Our website may contain links to third party websites, including websites via which you are able to purchase products and services. They are provided for your convenience only and we do not check, endorse, approve or agree with such third-party websites nor the products and/or services offered and sold on them. We have no responsibility for the content, product and/or services of the linked websites. Please ensure that you review all terms and conditions of website use and the Privacy Policy of any such third-party websites before use and before you submit any personal data to those websites.
How Safe is your Information?
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Protecting your security and privacy is important to us and we make every effort to secure your information and maintain your confidentiality in accordance with the terms of the Data Protection Legislation. The website is protected by various levels of security technology, which are designed to protect your information from any unauthorised or unlawful access, processing, accidental loss, destruction and damage.
We will do our best to protect your personal data but the transmission of information via the Internet is not completely secure. Any such transmission is therefore at your own risk.
Disclosure of your Information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006. We may share your information with selected third parties including:
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Business partners, suppliers and sub-contractors for the performance of any contract we enter with them or you
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Third parties who may wish to contact you in respect of services or products they offer or sell which may be of interest to you, provided we receive your consent to such disclosure; and/or advertisers and advertising networks that require the data to select and serve relevant adverts to you and analytics and search engine providers that assist us in the improvement and optimisation of the website
Please note we may need to disclose your personal information where we:
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Sell any or all our business or assets or we buy another business or assets in which case we may disclose your personal data to the prospective buyer or seller
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Are under a legal duty to comply with any legal obligation or to enforce or apply our terms and conditions; or
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Need to disclose it to protect our rights, property or the safety of our customers or others, including the exchange of information with other companies, organisations and/or governmental bodies for the purposes of fraud protection and credit risk reduction
Where we Store your Personal Data [if Simply Safe Care Group Ltd does not transfer personal data outside the EEA, this policy entry can be deleted].
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") to [insert the reasons why personal data is transferred outside the EEA, for example, because it is hosted on a server outside the EEA]. By submitting your personal data, you agree to this transfer, storing or processing. Simply Safe Care Group Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. If a finding of adequacy hasn't been made by the EC Commission in respect of the country to which the data is transferred, we will only transfer it where there are appropriate safeguards in place, including the use of EU standard contractual clauses or an intragroup agreement.
Your Rights in Respect of your Data
If any of the information you provide to us via the website changes, please let us know as soon as possible so that we can make the necessary changes to the information we hold for you on our database. If you wish to make any changes to your information, please contact us via the contact us link on the website
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If you wish to access or rectify the information we hold about you, or request that such information be transmitted directly to another data controller, please contact us via the following webpage [insert webpage link]. We shall process your request to access your information within one month of receipt, or we'll let you know within that timeframe if we need more information from you. We will process your request free of charge.
To request that your information is deleted or if you wish to restrict or object to the processing of your information, please contact us via the following webpage [insert webpage link].
If you have any complaints about our use of your personal data, please contact us. You also have the right to complain to the relevant supervisory authority in your jurisdiction. In the UK, the supervisory authority is the Information Commissioner's Office. Contact details for the ICO can be found at https://ico.org.uk/.
If you have any further queries or comments on our Privacy Policy, please contact us via the following webpage [insert webpage link] or you can contact us by emailing [insert email address]. We also welcome your views about our website and our Privacy Policy.
COOKIES WEBSITE STATEMENT
Cookies are small text files which a website may put on your computer or mobile device when you first visit a Site or page. The cookie will help the website, or another website, to recognise your device the next time you visit. Web beacons or other similar files can also do the same thing. We use the term “cookies” in this policy to refer to all files that collect information in this way.
We use cookies to distinguish you from other users of the Application or the Site. This helps us to provide you with a good experience when you use the Application or browse the Sites and also allows us to improve the Service, the Application and the Site.