Privacy Policy & Legal Disclaimer

Your privacy is very important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and disclose and make use of personal information. The following outlines our privacy policy.

Bridges Home Care
(A) This Policy

This Policy is provided by Bridges Home Care (“Bridges Home Care”, “we” or “us”), and is addressed to individuals outside our organisation with whom we interact, including (but not limited to) Customers and visitors to our websites (together, “you”). Defined terms used in this Policy are explained further in Section (N) below.

At Bridges Home Care we are deeply committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you or that you provide to us which will be processed by us in accordance with the UK Data Protection Act 2018.

For the purposes of this Policy, Bridges Home Care is the Controller. Contact details are provided in Section (M) below.

Please note that this Policy does not apply to the Processing by Bridges Home Care of the Personal Data of Bridges Home Care employees, temporary workers or other staff in connection with the roles they perform for Bridges Home Care. A separate privacy internal policy governs such Processing.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy. We will notify you of any significant changes.

(B) Processing your Personal Data
  • Personal details: given name(s); preferred name;
  • Contact details: home address; home telephone number; personal mobile telephone number; personal email address;
  • Medical History or records;
  • The results of tests such as NHS Test and Trace;
  • Proof or absence of Covid-19 certificate of vaccination;
  • Disability Details;
  • Prescriptions;
  • Care delivered;
  • Voice recordings obtained during telephone calls.

Lawful basis for Processing Personal Data: In Processing your Personal Data in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases:

  • we have obtained your prior express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
  • we have obtained your consent via the Council Welfare Service for your area to process your information in order to carry out Care Services;
  • the Processing is necessary in connection with any contract that you may enter into with us;
  • the Processing is required by applicable law;
  • the Processing is necessary to protect the vital interests of any individual; or
  • we have a legitimate interest in carrying out the Processing, which is not overridden by your interests, fundamental rights, or freedoms. Where we rely on this legal basis, our legitimate interests are:
    • our legitimate interest in the management and operation of our business and for training and quality purposes;
    • our legitimate interest in the promotion of our business; and
    • our legitimate interest in the provision of services to our Clients.

Processing your Sensitive Personal Data: 

  • the Processing is required or permitted by applicable law (e.g., Safeguarding Vulnerable Groups Act 2006);
  • the Processing is necessary for the detection or prevention of crime;
  • the Processing is necessary for the establishment, exercise or defence of legal rights; or
  • we have, in accordance with applicable law, obtained your prior explicit consent before Processing your Sensitive Personal Data (as above, this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Purposes for which we may Process your Personal Data: The purposes for which we may Process Personal Data, subject to applicable law, include:

  • Provision of services to you: providing our Sites and other services to you; attending appointments with you; attending telephone calls with you; and otherwise communicating with you in relation to those services.
  • Communications and IT operations: management of our communications systems; operation of IT security; and IT security audits.
  • Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations, which may include NHS Test and Trace.
  • Financial management: finance; corporate audit.
  • Surveys: engaging with you for the purposes of obtaining your views on the services we provide to you.
  • Improving our services: identifying issues with existing services; planning improvements to existing services; creating new services.
(C) Disclosure of Personal Data to third parties

We may disclose your Personal Data to:

  • legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
  • Doctors, Welfare Services and Care providers, accountants, auditors, lawyers and other outside professional advisors, subject to binding contractual obligations of confidentiality;
  • Bridges Home Care do not share any data for planning or research purposes for which the national data opt-out would apply. We review this on an annual basis and for any new processing;
  • Support our obligations to work with NHS Test and Trace and local Public Health Authority and the Data Subject be that an employee or client;
  • any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;
  • any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security;
  • any relevant third party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
  • third-party Processors to Process your Personal Data, the Processor will be subject to binding contractual obligations to
    i. only Process the Personal Data in accordance with our prior written instructions; and
    ii. use measures to protect the confidentiality and security of the Personal Data
    iii. the contractual obligations are approved by the ICO (UK Data Processing Authority).
(D) International transfer of Personal Data

Some processing takes place in Malaysia and the United States by one of our Processors.  The Malaysian entity is bound by UK/EU Model Clauses ensuring adequacy as defined in the regulation and the sub-processor in the United States is bound by UK/EU Model Clauses and the US Privacy Shield.

(E) Data Security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

You are responsible for ensuring that any Personal Data that you send to us are sent securely.

(F) Data Accuracy

Your Personal Data that we Process will be kept accurate and, where necessary, kept up to date. We take every reasonable step to ensure that:

  • your Personal Data that we Process are accurate and, where necessary, kept up to date; and
  • any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

(G) Data Minimisation

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably required in connection with the purposes set out in this Policy.

(H) Data Retention

We will keep copies of your Personal Data for up to 10 years as per national standards recommended for the Health sector unless instructed by your local council welfare department to hand over to them, or if applicable law permits or requires a longer retention period.

NHS Test and Trace data will be kept for 21 days.

Recordings of phone conversations will be kept for 6 months.

If you provide us your Personal Data and you are not a client we will retain your Personal Data for as long as we have your permission to contact you. Should you wish to withdraw that permission, you may do so using the contact details provided in Section (M) below.

(I) Your legal rights

Subject to applicable law, you may have a number of rights regarding the Processing of your Personal Data, including:

  • the right to request access to, or copies of, your Personal Data that we Process or control;
  • the right to request rectification of any inaccuracies in your Personal Data;
  • the right to request, on legitimate grounds:
  • erasure of your Personal Data that we Process or control; or
  • restriction of Processing of your Personal Data that we Process or control;
  • the right to object, on legitimate grounds, to the Processing of your Personal Data;
  • the right to have your Personal Data transferred to another Controller, to the extent applicable;
  • where we Process your Personal Data on the basis of your consent, the right to withdraw that consent; and
  • the right to lodge complaints regarding the Processing of your Personal Data with a Data Protection Authority.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (M) below.

(J) Cookies

We use Google Analytics to count visitors to our website and the Twitter Button cookie to link to Twitter.  We also use a BridgesHomeCare cookie to manage performance of the site.  We do not create visitor profiles by any means.  See Cookie Policy for more information.

(K) Terms of Use

All use of our Sites is subject to our Legal Disclaimer at the end of this Policy.

(L) Your obligations

We rely on you to provide us with complete and accurate Personal Data about you, so that we can provide appropriate services to you.

(M) Contact details

If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data by Bridges Home Care, please contact:

Bridges Home Care enquiries@bridgeshomecare.co.uk

If you wish to contact the ICO you can call them on 0303 123 1113 or the support page on https://ico.org.uk/global/contact-us/ .  BHC has the ICO registration number ZA006735

(N) Children’s Privacy

Bridges Home Care does not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to register to use the Services. No one under age 13 is allowed to provide any Personal Information to Bridges Home Care. In the event that we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us.

(O) Definitions

‘Client’ means a client of Bridges Home Care.

‘Controller’ means the entity that decides how and why Personal Data is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

‘Data Protection Authority’ means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

‘Personal Data’ means information that is about any individual, or from which any individual is identifiable. Examples of Personal Data that we may Process are provided in Section (B) above.

‘Process’, ‘Processing’ or ‘Processed’ means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

‘Processor’ means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

‘Sensitive Personal Data’ means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
 

DISCLAIMER

This website and its content are provided as is and excludes to the fullest extent permitted by applicable law any warranty, express or implied, including, without limitation, any implied warranties of merchantability, satisfactory quality or fitness for a particular purpose.

The functions embodied on, or in the materials of, this website are not warranted to be uninterrupted or without error. You, not Bridges Home Care assume the entire cost of all necessary servicing, repair or correction due to your use of this website.

Except as specifically stated in our privacy policy, or elsewhere on this website, or as otherwise required by applicable law, neither Bridges Home Care nor its affiliates or other representatives will be liable for damages of any kind arising out of your use of, your inability to use, or the performance of this website or the Content whether or not we have been advised of the possibility of such damages.

We take all reasonable steps to ensure the accuracy, correctness and reliability of the content, but we make no representations or warranties as to the accuracy, correctness or reliability of the content.

This website may contain links to other websites; we are not responsible for any content contained on these websites or any loss suffered by you in relation to your use of such websites. You waive any and all claims against Bridges Home Care regarding the inclusion of links to other websites or your use of those web sites.

Last updated: 9 February 2023