GDPR PRIVACY POLICY

Disclaimer: this sample policy is provided for general information purposes only and does not constitute legal advice. In order to be fully effective, it should be customised to suit the individual procedures of your organisation. It should be noted that, since the UK left the European Union and is no longer subject to its legislation, the provisions of the EU GDPR have been incorporated directly into UK law as the UK GDPR. In practice, the Information Commissioner's Office (ICO) has confirmed that there is little change to the core data protection principles, rights and obligations and this policy therefore remains valid.

This privacy policy tells you what will happen to any personal data that you provide to (name of organisation) as a result of using this website or contacting this organisation. We fully understand that your privacy is important to you and that you care about how your personal data is used and shared online and we will take account of, and respect, your concerns.

This policy explains how we will use, and protect, the information that we gather, whether it be through this website, by way of telephone or personal conversations or through our normal business contacts with you. Please read this privacy policy carefully and ensure that you understand it. Details are given below of contacts should you wish to ask questions but please note that acceptance of this privacy policy and our cookie policy (see “Cookies” below) is required to make full use of our site.

Our details
Organisation’s name : First Rate Home Healthcare Ltd
Address : Falcon House, 19 Deer Park Road, SW19 3UX
Telephone number : 02038709084
Email address : office@frhh.care
We are registered with the Information Commissioner’s Office (ICO).
Our Data Protection Officer (DPO) : Carlota Mpesa can be contacted at carlota@frhh.care.

Your rights

Under the General Data Protection Regulation (GDPR), you have the right to be informed about:
• The collection and use of your personal data
• Our purposes for processing that data
• The retention periods for storing your data (or a guarantee that it will be kept only for as long as necessary)
• Who it will be shared with (both in this country and, if applicable, in others: in this case, we will inform you of the safeguards which are applied in that country)
• The legal basis under which we process your data
• The right to withdraw your consent (if consent is the legal basis for processing)
• Our “legitimate interest” in processing your data (if that interest is the legal basis for processing)
• Details of any data we collect about you from a third party (such as publicly-available information)
• The right to lodge a complaint with the ICO
• Details of the existence of automated decision-making, including profiling (if applicable).
You also have the right to information that is concise, transparent, intelligible, easily accessible and presented to you in clear and plain language rather than in “legalese”. We would encourage you to get in touch with the contact given above if you have any questions about this policy statement or our procedures with regard to data processing. This will not in any way affect your right (mentioned above) to complain to the ICO. Finally, we commit to informing you if, at any time, we update our privacy information and always to seek permission if we plan to use your personal data for a new purpose.

The right to be forgotten

Also known as data erasure, the “right to be forgotten” set out in the GDPR entitles you to ask any data controllers (including this organisation) to erase your personal data and to cease further dissemination. You can make such a request either verbally or in writing and we will respond as quickly as possible, and at the latest within one month. We understand that there is a particular emphasis on the right to erasure if the request relates to data collected from children and such requests will always be given the highest priority. Please note, however, that there are certain circumstances in which the right to erasure may not apply. These include where processing is necessary for one of the following reasons:
• to comply with a legal obligation
• to exercise the right of freedom of expression and information
• for the performance of a task carried out in the public interest or in the exercise of official authority
• for the establishment, exercise or defence of legal claims.

In addition, any organisation is allowed to refuse to comply with a request for erasure if it is manifestly unfounded or excessive, taking into account whether the request is repetitive in nature. We will, however, explain and justify any such refusal.

Right to be informed

Within one month of collecting your personal data, we will inform you of the purposes for processing that data, the retention periods and with whom it will be shared. Any information which is provided to you will be concise, transparent, intelligible, easily accessible and presented in clear and plain language.

Right to rectification

Either verbally or in writing, you may ask for inaccurate personal data to be rectified, or to be completed if it is partial. We will respond as quickly as possible and certainly within the one month time period allowed under the GDPR. In the unlikely event that there is disagreement over the accuracy of the data, we will do our best to resolve this and you will, of course, have right to take the matter to the ICO if we cannot reach agreement. If that situation arises, we are prepared to consider restricting processing of the contested data during the time it takes to resolve the issue with the ICO.

Children

Under the GDPR, only children aged 13 or over are able provide their own consent. For those under this age, we will seek consent from whoever holds parental responsibility or, if we are using a different legal basis, will inform that person accordingly. We are fully aware that children have the same rights as adults over their personal data and are committed to ensuring full protection for them at all times.

Right to data portability

This organisation recognises that, under the GDPR, you must be able to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. The requested information will be provided free of charge in a structured, commonly used and machine-readable form. However, it should be noted that the right to data portability only applies:

• to personal data an individual has provided to a controller

• where the processing is based on the individual’s consent or for the performance of a contract

• when processing is carried out by automated means.

Right to object

You have the right to object to:

• processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling)

• direct marketing (including profiling)

• processing for purposes of scientific/historical research and statistics.

We will stop processing personal data for direct marketing purposes as soon as an objection is received.

Automated decision-making and profiling

Profiling refers to the automated processing of personal data to evaluate certain things about an individual. Together with making a decision solely by automated means, it is covered by the GDPR and will require the individual’s explicit consent. We will only collect the minimum amount of data needed and will retain it only for as long as is necessary. Anyone affected by an automatic decision has the right to ask for it to be reconsidered and we have additional checks in place for profiling/automated decision-making systems to protect vulnerable groups such as children.

Data breaches

While we will take all appropriate measures to prevent illegal access to your data, we have to prepare for that possibility. Should there be a significant data breach affecting your data and rights, we will notify you (and the ICO) as soon as possible. To minimise any possible danger, we will use encryption and/or pseudonymisation where it is appropriate to do so. We will also have backup systems in place in the event that an outside organisation attempts to disrupt access to our data,

Cookies

A cookie is a small text file placed on your computer or device by our site when you visit certain parts of it and/or use certain of its features. For example, we may monitor how many times you visit, which pages you go to, traffic data, location data, weblogs and other communication data whether required for billing purposes or otherwise. We may also look at the originating domain name of a user’s internet service provider, IP address, operating system and browser type. This information helps us to build a profile of our users. Where appropriate, this data will be aggregated or statistical, which means that we will not be able to identify you individually.

Cookies are also used to remember your settings (language preference, for example) and for authentication (so that you do not have to repeatedly sign in). You can set your browser not to accept cookies and there are a number of websites which explain how to remove cookies from your browser. However, it is possible that some of our website features may not function as a result.

Third party websites

Please note that there are some links on our website to other sites where you may find useful information. This does not indicate a general endorsement of those sites and, as we have no control over how data is collected, stored, or used by other websites, we would advise you to check their privacy policies before providing any data to them.

Last updated on (14/01/25) by Carlota Mpesa who can be contacted at carlota@frhh.care.