1. INTRODUCTION AND TERMS
We may process data relating to children during our Service provision in our role as Processor. We do not knowingly process personal data belonging to children as Controller.
Service User Information
If you are a Service User (or have authority to act on behalf of a Service User) of one of our customers (supported living organisations), we act as a contracted processor of your Personal Data and Special Category Data to those organisations. This organisation will be a controller of your data and have instructed us to process the same so that we may perform our Services. The types of data they share with us are further described under paragraph 4 of this policy.
For this personal data:
We advise that you read this policy in full to understand how we use your Personal Data. If you have any questions regarding how your personal data is processed, we direct you to the supported living organisation in the first instance.
2. WHO WE ARE AND HOW TO CONTACT US
Privacy Officer: Matthew Bowern
Full name of legal entity: UKEvolve Ltd
Email address: firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
4. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data in respect of our users, such as statistical data, for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the features that are most used on our Software.
For Service Users, we will collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, information about your health, and genetic and biometric data). We do not routinely collect any criminal conviction data.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
5. HOW iS YOUR PERSONAL DATA COLLECTED ?
We use different methods to collect data from and about you including through:
6. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table at Annex A.
We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. These are as follows:
7. THIRD PARTY AND SHARING INFORMATION
We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you. We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
Personal Data is stored and processed in London, UK via Digital Ocean https://www.digitalocean.com. Additional storage may be obtained through Amazon Web Services (AWS) within the EU.
In addition to our cloud storage providers, please see below the list which sets out the categories of recipients of personal data.
|SERVICE PROVIDERS WHO MAY RECEIVE YOUR PERSONAL DATA|
|Email Provider||Mailgun (within the EEA)|
In addition third parties may provide us with personal data and they should only do so where the law allows them to.
We do not undertake direct marketing.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you or your employer. This is how we decide which products, services and offers may be relevant for you or your employer (we call this marketing).
Users will not receive marketing communications from us.
We will not share your personal data with any third party for marketing purposes.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details set out at the start of this policy.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
8. INTERNATIONAL TRANFERS
We do not transfer your personal data outside the European Economic Area (EEA).
9. DATA SECURITYWe have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Data retention
10. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us using the details at the start of this policy.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
11. APPLICATIONS TO WORK WITH US
If you apply to work for us (directly or indirectly) in any role we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.
11. YOUR LEGAL RIGHTS
Under the Data Protection Laws your rights are:
Access – You are entitled to find out what details we may hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. Individuals can find out if we hold any of their Personal Data by making a formal request to us, preferably by email with the subject line “Subject Access Request”. If we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy). The information we supply will:
Rectification – We are obliged to correct or update your details. If you are aware that the personal data we hold is incorrect or requires updating, individuals can make a formal request for rectification to us, preferably by email with the subject line “Rectification Request”. We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.
Erasure – This is also known as the request to be forgotten. Under Data Protection Laws you have the right to erasure under specific circumstances. A request for your personal data to be deleted will be decided on a case-by-case basis and should be submitted in writing to us, preferably by email with the subject line “Erasure Request”.
Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data in certain circumstances. To request limits on how we process your personal data, individuals can make a formal restriction request to us, preferably by email with the subject line “Restriction Request”.
Portability – This right allows you to move, copy or transfer personal data easily from one service provider to another in a safe and secure way in a common data format, for example, Excel or CSV file. We will make reasonable efforts to transmit the personal data using a method you have request. Please submit your request for portability to us, preferably by email with the subject line “Portability Request”.
Object – You have the right to object to us processing your data in relation to direct marketing and or profiling. Individuals can raise a formal objection to processing to to us, preferably by email with the subject line “Data Objection”.
Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling.
Please note that you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by the Data Protection Laws and as summarised above. If you exercise any of your rights under Data Protection Law, we will respond as quickly as possible. This must be no later than one calendar month, starting from when we receive the request or, where applicable, upon receipt of any information necessary to process the request.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|Authorised Users/ Super Admins|
|To register you or a supported living organisation as a new customer of the business.||
|Performance of a contract with you.|
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Notifying you of systems updates
(c) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you.
(b) Necessary to comply with a legal obligation.
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to take part in a survey||
(e) Marketing and Communications
(a) Performance of a contract with you.
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content to you and measure or understand the effectiveness of our services||
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, customer relationships and experiences||
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations about services that may be of interest to you||
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
|Service Users and Authorised Users|
To provide Services to supported living organisations, including:
|Determined by the supported living organisation as Data Controller.|