Privacy notice

Brunelcare is committed to protecting and respecting your privacy.

This privacy notice explains and sets out what personal information Brunelcare collects from you, or that you provide to us, how this information is used and how it is stored. This includes information that you give us when you use our website.

Where you provide us with information which can identify you we will only use this in accordance with this privacy notice and Brunelcare’s Privacy and Confidentiality Policy.

Data protection legislation provides you with rights in relation to the information we hold about you and requires us to only use your data fairly and appropriately in ways that you understand. This notice includes:

Reasons why we hold and process your data.
What we do with your personal data.
Who gets to access and see your personal data.
What rights you have regarding your personal data.
How you can find out more information about the information we hold about you.

This privacy notice relates to Brunelcare’s customers, potential customers, customer representatives and those visiting our website. Brunelcare’s employee privacy notice can be found here.

Definitions

In this notice the following definitions are used:

‘personal information’ and ‘personal data’ refers to any information or data which may identify you. This may be information held on a computer or in paper format.
‘sensitive personal information’ and ‘sensitive personal information’ refers to special categories of information which may identify you that require additional safeguards due to the sensitivity of the data. This includes data related to physical and mental health, sexuality, religious beliefs, racial or ethnic origin and criminal offences or the allegation of criminal offences.
‘processing’ covers all actions taken relating to your information. This includes obtaining, storing, disclosing, updating or deleting information.

Brunelcare is the Data Controller as defined in data protection legislation. We are registered with the Information Commissioner’s Office (registration number Z6080582) and our entry can be found here.

Why we collect and store personal information

In order to provide our services to you, Brunelcare needs to collect your personal information, including sensitive personal data. We will only collect and ask for personal information required to provide our services to you, fulfil our contractual and legal obligations and to enable us to tailor our service offering. We will not collect more data than is needed to provide you with the services you require.

Data protection principles require us to ensure that personal information is:

Processed fairly and lawfully and only for the purposes we have specified.
Accurate, relevant, and not excessive to the needs for which data is required.
Kept for no longer than is necessary.
Protected against unauthorised use, accidental loss or other processing.

Under data protection legislation, Brunelcare requires a lawful reason to process a customer’s personal information. Brunelcare processes your information through the following lawful bases:

Your consent (you may withdraw your consent at any time).
Where we have a contractual obligation (e.g. the contract we provide to you).
Where we have a legal obligation (e.g. providing your information to a third party, such as the Adult Safeguarding or Local Authorities where we have concerns).
To protect an individual’s legitimate interests (e.g. in a medical emergency).
Where Brunelcare has a legitimate interest to process your data.

Where the information being processed amounts to sensitive personal data (e.g. related to physical and mental health, sexuality, religious beliefs and racial or ethnic origin) Brunelcare requires an additional legal basis for processing. The following additional lawful reasons are relevant depending on the information being processed:

Where you have provided consent.
To meet employment, social security and social protection law.
In your vital interests.
To support the legitimate activities of Brunelcare (i.e. to provide care and support)
Where you have already made the information public.
Where the information is required as part of legal claims.
Where there is a substantial public interest in sharing the information.
To provide health and social care activities.
Where there is a public health interest in sharing the information.

How we collect personal information about you

Brunelcare will collect personal information about you when:

You communicate with us to enquire about our services.
You sign-up to receive services from us.
You communicate with us about the service we provide.
Through recording details of the service we provide to you.
You wish to provide feedback on the services we provide or raise a concern or complaint.
Investigating complaints or alleged cases of anti-social behaviour.
Information is provided to us by an external referring partner (i.e. Local Authorities or health based services).
You attend our sites and your image is captured via our CCTV systems.
You visit our website.

We are committed to keeping your personal details up to date, and we encourage you to inform us about any changes or inaccuracies to ensure your details are up to date.

Information we may hold about you and how this is used

We will hold different types of personal information about you depending on the service we provide. The way this information is used will also depend upon the service we provide to you. Generally, we use the information we collect to help us understand your needs and to perform, plan, develop and review the services we provide.

The below table outlines the different types of personal information we may collect about you and how this is used.

Name, date of birth, national insurance number and contact details (including telephone number and email address)	To allow us to communicate with you, provide responses to queries and keep you informed of the services we provide and those we offer that may be useful to you.
Next of kin/family/representative details	To allow us to update, and provide information to, those you identify as important to you. Where you have provided details of a third party we will assume that you have authority to supply these details to us.
Photographic ID	To identify you within the service and where we provide housing services to help prevent tenancy fraud and identity theft.
Information about your needs and care requirements (including medical information, assessments and care planning documents)	To ensure you receive appropriate and effective care and support in line with agreed care plans. Where we provide housing services, to ensure our services are accessible to you and that we take account of your care and support needs when communicating with you. This may be to protect you from harm or inform adaptations to your property.
Information to assist us in delivering housing management services	Where we provide housing services this includes changes in circumstance, information about repairs and maintenance, information about housing options, changes to medical needs and reports and evidence related to complaints and anti-social behaviour.
Information to assist us in delivering care and support services	Where we provide care and support services this includes changes to medical needs, complaints information and information related to safeguarding alerts.
Information about previous housing circumstances	Where we provide housing services, to assess housing applications and help prevent tenancy fraud, identity theft and illegal subletting.
Information we have received from other sources (e.g. Local Authorities and healthcare providers).	To provide appropriate and continuous care and support to you and deliver our services to you.
Information about any additional guidance and care and support services you may need	To allow us to signpost you to external agencies dependant on the service we provide to you. Information will only be shared in line with this privacy notice.
Financial and bank details	To allow you to make payments and to keep a record of the amount of money you have paid us, any amounts outstanding and any associated recovery action.
Equality and diversity data	For monitoring purposes and to understand the make-up of our customer base.
Market research and customer satisfaction surveys	Your responses to our market research requests and customer satisfaction surveys allow us to monitor our performance and improve our services.
IP address	We may capture your IP address when you visit our website.
Google Analytics Data and Cookies	When you visit our website we may capture data such as information on the website pages you view, time spent on our website, your location and other information. This data is anonymous and helps us to improve our website experience. Further information can be found in our website Cookie Policy.
Your image	We may capture your image on our surveillance systems if you visit a Brunelcare site for the purposes of the security and safety of our sites.
Your voice	To support you and to respond to any voicemail messages or enquiries you may leave on the systems we manage.

If you visit our website, please be advised that this may contain links to and from other websites. If you choose to follow a link it will be the case that these websites have their own privacy notices and practices. Therefore, we cannot be responsible for the protection and privacy of any information you provide whilst visiting these sites and they will not be governed by this privacy statement.

How we keep your information secure

Brunelcare takes data protection extremely seriously and has implemented appropriate technical and organisational measures to protect this information. Access to data is restricted on a need-to-know basis and security arrangements are reviewed regularly to ensure their continued suitability.

How long we keep your personal information

Brunelcare will only retain your information in line with legal requirements and only where there is a need to do so. Information will be retained and securely destroyed or anonymised in line with Brunelcare’s Data Retention Policy. Retention timeframes have been determined based on legislation, guidance and current best practice.

Sharing your personal information

There will be times where we will be required to share relevant information with third parties for the purposes outlined above or where we are legally required to do so.

Brunelcare holds an up to date list of all organisations with which information is shared and the reason why this information is shared. Third parties with whom we share data will depend on the service we provide to you.

Examples of organisations with whom we share your personal information include: contractors to carry out repairs and maintenance on your property, Housing Benefit, the Department of Work and Pensions, Local Authorities, the Police, Probation services, other landlords, the courts, social services, support agencies, the NHS, lifeline services and the emergency services.

Where it is necessary to share your information, we will do so with a lawful basis under data protection law. Where information is classified as sensitive personal data this will include an additional legal basis as prescribed by legislation. The lawful bases are detailed within the section ‘Why we collect and store personal information’ above.

We require all third parties to respect the privacy of your personal data and to treat it in accordance with our policies and appropriate data protection law and principles. We do not allow third party service providers to use your personal information for their own purposes and only permit them to process your data for specified purposes in line with our instructions.

Your data protection rights

Under data protection law you have, depending on the type of information and the basis under which the data is processed, several rights in relation to your personal information:

The right to be informed – you have the right to be told how we will use your data.
The right to access your data – you have the right to ask us for copies of your personal information.
The right to rectification – you have the right to ask us to rectify personal information you think is inaccurate or to complete information you think is incomplete.
The right to erasure – you have the right to ask us to erase your personal information in some circumstances.
The right to restriction of processing – you have the right to ask us to restrict the processing of your personal information in certain circumstances.
The right to object to processing – you have the right to object to the processing of your personal information in certain circumstances.
The right to data portability – you have the right to ask that we transfer your personal information to another organisation, or to you, in certain circumstances.

Brunelcare will ensure that appropriate organisational and technical measures are in place to allow individuals to exercise their data protection rights.

If you wish to make a request for exercising your rights, please contact us using the contact details below. You will not be required to pay any charge for exercising your rights. If you make a request we will have one month to respond to you.

Questions and concerns about your personal information

If you have any queries or concerns about your personal information, how this is used, or your rights, please contact Brunelcare’s Data Protection Officer:

Email – [email protected]

Address – Data Protection Officer, Brunelcare Head Office, Saffron Gardens, Prospect Place, Whitehall, Bristol BS5 9FF

Your right to complain

If you are unhappy with how we have used your personal information or you have any concerns, you can make a complaint through Brunelcare’s formal complaints process. You can do this through the following methods:

In person – through the service supporting you or at one of our offices.

By telephone – through the contact number of the service supporting you or centrally at 0117 914 4200 (office hours, Monday to Friday).

Using our website form – https://www.brunelcare.org.uk/contact-us/make-a-complaint/

Via email – to [email protected] or through the service/person you usually have contact with.

In writing – Complaints Officer, Brunelcare Head Office, Saffron Gardens, Prospect Place, Bristol BS5 9FF (or through the service/person you usually have contact with.

In addition to Brunelcare’s complaints process, you have the right to complain directly to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data. We would however encourage you to raise your concern with us initially so that we can put this right for you.

The ICO can be contacted as follows:

In writing: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Via telephone: 0303 123 1113

ICO website: www.ico.org.uk