1. Purpose
1.1 The purpose of this policy is to provide a template privacy policy that Ashwood House Limited can adapt to use on its website. The privacy policy will apply to all users of Ashwood House Limited's website.
1.2 By using the template privacy policy provided, Ashwood House Limited will ensure that the policy on its website is GDPR compliant.
1.3 To support Ashwood House Limited in meeting the following Key Lines of Enquiry:
Key Question
Key Line of Enquiry (KLOE)
WELL-LED
W2: Does the governance framework ensure that responsibilities are clear and that quality performance, risks and regulatory requirements are understood and managed?
1.4 To meet the legal requirements of the regulated activities that Ashwood House Limited is registered to provide:
• General Data Protection Regulation 2016
• Data Protection Act 2018
2. Scope
2.1 The following roles may be affected by this policy:
• All staff
2.2 The following people may be affected by this policy:
• Service Users
2.3 The following stakeholders may be affected by this policy:
• Family
• Advocates
• Representatives
• Commissioners
• External health professionals
• Local Authority
• NHS
3. Objectives
3.1 The objective of this policy is to provide assurance that Ashwood House Limited have a privacy policy in place for users of the Ashwood House Limited website that is GDPR compliant.
3.2 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 Service Users, understand the ways in which personal data collected by Ashwood House Limited via its website is processed.
4. Policy
4.1 Ashwood House Limited understands that if it operates a website, it may need to update its privacy policy to ensure it is compliant with GDPR. Ashwood House Limited will use this privacy policy as a template for its updated version. Ashwood House Limited understands that this privacy policy only needs to be uploaded by Ashwood House Limited to its website if it collects personal data via its website. Ashwood House Limited will use the template Fair Processing Notice to inform all other Data Subjects, including Service Users, about how Ashwood House Limited processes personal data other than personal data collected via the website.
4.2 Ashwood House Limited understands that terms in square brackets are optional (depending on whether they apply to Ashwood House Limited or not) or require completion by Ashwood House Limited. Ashwood House Limited will review the privacy policy in its entirety to determine which elements are applicable to Ashwood House Limited's website, and which are not relevant.
For example:
• If the template privacy policy below refers to personal data that is not collected by Ashwood House Limited via its website, Ashwood House Limited will delete references to such personal data
• If Ashwood House Limited's website does not use cookies, Ashwood House Limited will delete references to cookies and Ashwood House Limited's cookie policy
• If Ashwood House Limited does not transfer personal data outside of the EEA, Ashwood House Limited will delete the section entitled "Where we store your personal data"
• If Ashwood House Limited is not required to appoint a Data Protection Officer, Ashwood House Limited will delete references to the Data Protection Officer or will consider replacing references to the Data Protection Officer with references to Ashwood House Limited's Privacy Officer or other person nominated to have day-to-day responsibility for data protection and GDPR
If Ashwood House Limited 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 Ashwood House Limited. Ashwood House Limited will consider whether to provide an alternative contact method instead, such as an email address and/or phone number.
If Ashwood House Limited has any concerns or queries in respect of the template privacy policy, it will seek legal advice.
5. Procedure
5.1 Ashwood House Limited 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. Ashwood House Limited acknowledges that the use of cookies constitutes processing of personal data via the website.
5.2 Ashwood House Limited will review the template privacy policy. Ashwood House Limited 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 Ashwood House Limited processes personal data collected via its website. Where Ashwood House Limited has any concerns or queries in relation to their own Privacy Statement, Ashwood House Limited will seek legal advice.
6. Definitions
6.1 Data Subject
• The individual about whom Ashwood House Limited has collected personal data
6.2 Data Protection Act 2018
• 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
6.3 GDPR
• 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 transition period became enforceable on 25 May 2018
6.4 Personal Data
• 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.
6.5 Process or Processing
• Doing anything with personal data, including but not limited to collecting, storing, holding, using, amending or transferring it. Ashwood House Limited does not need to be doing anything actively with personal data - at the point Ashwood House Limited collects it.
6.6 Special Categories of Data
• 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
6.7 Cookies
• 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:
• The privacy policy applies to personal data collected via Ashwood House Limited's website
Key Facts - People Affected by The Service
People affected by this service should be aware of the following:
• Personal data provided to Ashwood House Limited via its website will be processed in accordance with Ashwood House Limited's privacy policy
Privacy Statement
We are Ashwood House Limited, a company incorporated in England. Our company number is registered company 3581014 and our registered address is 23 Mansfield Road, Ilford, Essex IG1 3BA
("Ashwood House Limited" / "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 info@ashwoodhouse.org.
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 www.ashwoodhouse.org (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.
Information you give Ashwood House Limited: 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. The information you give us may include your name, email address, address/location and phone number.
We will retain this information while we are corresponding with you or providing services to you or to a Service User you represent. We will retain this information for no longer than is necessary or required.
Information Ashwood House Limited collects about you: Ashwood House Limited may collect the following information from you when you visit the website:
• 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
• 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 no longer than is necessary or required.
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 no longer than is necessary or required.
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 below.
Ashwood House Limited may use the information we receive and/or collect about you to:
• Fulfil our obligations under any contract we have entered into with you or with a Service User you represent, and to provide you or the relevant Service User with information or services you or the Service User has requested
• Send you newsletters and marketing information if you have consented to us doing so
• 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
• 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
Ashwood House Limited processes personal information for certain legitimate business purposes, which include some or all the following:
• Where the processing enables Ashwood House Limited to enhance, modify, personalise or otherwise improve the website, its services or communications
• To identify and prevent fraud
• To enhance the security of Ashwood House Limited's network and information systems
• To better understand how people interact with Ashwood House Limited's websites
• To administer the website and carry out data analysis, troubleshooting and testing; and
• 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 email info@ashwoodhouse.orgenter the subject header “I would like to receive the following information”. Please bear in mind 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 emailing info@ashwoodhouse.orgenter “Unsubscribe" in the subject header 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.
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.
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.
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:
• Business partners, suppliers and sub-contractors for the performance of any contract we enter with them or you
• 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:
• 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
• Are under a legal duty to comply with any legal obligation or to enforce or apply our terms and conditions; or
• 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 Ashwood House Limited 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. Ashwood House Limited 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.
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:
• Business partners, suppliers and sub-contractors for the performance of any contract we enter with them or you
• 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
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 following webpage [insert webpage link].
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 by emailing info@ashwoodhouse.org. We also welcome your views about our website and our Privacy Policy.
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