General Data Protection Regulation (GDPR) Privacy Notice
The General Data Protection Regulation (GDPR) came into force in May 2018 and will be incorporated into UK data protection laws, so will apply even after the UK leaves the EU. The GDPR consolidates and strengthens current data protection safeguards as developed under the Data Protection Act 1998.
This privacy notice, which follows ICO guidelines, underlines that Bernhard Baron Cottage Homes (BBCH) is serious about protecting personal information it collects and processes from Residents, employees and others, and provides an overview of our various policies and procedures.
The privacy notice is a public document, available to Residents and their families, staff and any third parties who might provide personal information for any purpose, and in whatever ways, including on the BBCH website and intranet if there is one in the future.
This privacy notice should be used in association with the policy on Protecting Personal Data under the General Data Protection Regulation.
This is the privacy notice of Bernhard Baron Cottage Homes (BBCH).
Our registered office is at Eastbourne Road, Polegate, East Sussex BN26 5HB.
BBCH is registered with:
the Care Quality Commission to personal care to people in the Homes without nursing;
The Charity Commission with number 1070891
Companies House with number 03580252
Aims of this notice
BBCH is required by law to tell you about your rights and our obligations regarding our collecting and processing any of your personal information. We have a range of policies and procedures to ensure that any personal information you supply is only with your active consent and will be held securely and treated confidentially in line with the applicable regulations. We have listed the relevant documents in a later section (6) and these are available for your review.
What personal information we collect
As a registered care provider, we must collect some personal information on our Residents, including personal, medical and financial information, which is essential to our being able to provide effective care and support. The information is contained in individual files, primarily electronic, and other record systems, all of which are subject to strict security and authorised access policies. Personal information that becomes inactive, eg from enquiries or prospective users who do not come to BBCH is also kept securely for as long as it is needed, before being safely disposed of.
Employees and volunteers:
BBCH operates a safe recruitment policy to comply with the regulations in which all personal information obtained, including CVs and references, is securely kept, retained and disposed of in line with data protection requirements. All employees are aware of their right to access any information about them.
All personal information obtained about others associated with the delivery of the care service, including contractors, visitors, etc will be protected in the same ways as information on Residents and employees.
How we collect information:
The bulk of Residents’, employees’ and thirds parties’ personal information is collected directly from them or through form filling, manually or electronically, for example when contacting BBCH through our website.
With Residents, we continue to build on the information provided in enquiry and referral forms, and, for example, from needs assessments, which feed into their care and support plans.
With employees, personal information is obtained directly and with consent through such means as references, testimonials and criminal records (DBS) checks. When recruiting staff, we seek applicants explicit consent to obtain all the information needed for us to employ them.
All personal information obtained to meet our regulatory requirements will always be treated in line with our explicit consent, data protection and confidentiality policies.
Our website and databases are checked to ensure they meet all privacy standards and comply with our general data protection security and protection policies.
What we do with personal information:
All personal information obtained on Residents, employees and third parties is used only to ensure that we provide a service which is consistent with our purpose of providing a person-centred care service, which meets all regulatory standards and requirements. It will only be disclosed or shared for medical purposes (for example we will provide a hospital with a care plan for a Resident) or operational purposes (for example payroll information goes to our payroll processor)
How we keep your information safe:
As already stated, BBCH has a range of policies that enable us to comply with all data protection requirements. Foremost are:
- Data protection policy
Data quality policy
Record keeping policy
Business continuity policy
With whom we might share information
We only share the personal information of Residents, employees and others with their consent on a “need to know” basis. Most information sharing of Residents’ information is with other professionals and agencies involved with their care and treatment or the families of Residents. Likewise, we would not disclose information about our employees without their clear agreement, eg when providing a reference.
The only exceptions to this general rule would be where we are required by law to provide information, eg to help with a criminal investigation. Even when seeking to notify the local authority of a safeguarding matter or the Care Quality Commission of an incident that requires us to notify it, we would only do so with consent or ensure that the information provided is treated in confidence.
Where we provide information for statistical purposes, the information is aggregated and provided anonymously so that there is no privacy risk involved in its use.
How personal information held BBCH can be accessed
There are procedures in place to enable any Resident, employee or third party whose personal information we possess and might process in some way can have access to that information on request. (See the policies listed in No. 6 above.) The right to access includes both the information and any uses which we might have made of the information.
How long we keep information
Information is only kept for the time required by law or regulations or such time as is deemed necessary for the protection of BBCH or the data subject involved.
How we keep our privacy policies up to date
The staff appointed to control and process personal information in our organisation are delegated to assess all privacy risks continuously and to carry out reviews of our data protection policies, procedures and protocols at least annually