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Privacy Policy

Privacy Policy 2018-09-19T14:15:12+00:00

PRIVACY POLICY

PLEASE READ THIS POLICY CAREFULLY, IF YOU DO NOT ACCEPT THESE TERMS YOU ARE ADVISED NOT TO USE THE WEBSITE

This policy was last updated: 16th September 2018

Use of this website, www.transition360.org.uk, constitutes your legal agreement to the terms within this policy and your acceptance of this policy is deemed to occur upon your first use of the website.

Transition 360 may change this policy from time to time by updating this page. You should check this page before using the website to ensure that you are aware of and accept any changes.

Policy Statement

Transition 360 understands that your privacy is important to you and that you care about how your personal data is used and shared online. This Privacy Policy sets out how Transition 360 collects and processes your personal data.

We will take all reasonable steps to ensure that personal information is safeguarded and kept in accordance with the law.

By providing us with your data, you warrant that you are over 13 years of age.

About Us

Transition 360 Limited (“Transition 360) is registered in England and Wales under Company Registration Number 09678494. Our registered office address is 21 Clare Road, Halifax HX1 2HX. We are registered with the Information Commissioner’s Office (ICO) for data protection reference number ZA129050.

Where we manage personal data, we identify as a Data Controller and recognise and act on our obligations under applicable data protection laws. For any issues relating to data protection the person responsible is Mohammed Ijaz.

What personal data do we collect?

Information that you provide to us is retained and processed in accordance with UK data protection legislation. This includes data given to us from the following:

Service users: We collect personal data which is essential to our being able to provide effective care and support. The information is contained in manual and electronic files and other record systems, all of which are subject to our security measures. Please email us if you wish to be sent details of our Security Policy.

Contact: We have a Contact Us page on the website which is used to collect your name, email and phone number as well as the subject of your message and the message itself. This is so that we can contact you and provide details of our services to you, make any arrangements for provision of services and also deal with general company enquiries. Data is held on the grounds of being legitimate to our business interests. We may also use these contact details for ongoing arrangements with service users.

Emails: We retain copies of emails sent to us on our servers which is hosted in the UK. Your personal information will be held by us in accordance with this Privacy Policy and will be on the basis of being legitimate to our business interests.

Job applications: We retain copies of CVs, references and other information in relation to job applicants. Please email us to request a copy of our separate Privacy Policy for Job Applicants.

Telephone calls: Phone calls to us may be recorded (manually) and any data relating to the call may be retained by us. The data will be held on the basis of being for our legitimate business needs or in order to fulfil our contractual obligations if you are a service user.

Special categories of data

Some of the information you provide to us may be considered sensitive personal data which includes information about a data subjects ethnic or racial origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life or criminal record. This data will only be held where we have a legitimate business reason to hold such data and where there is valid reason to retain the information, in accordance with legal or contractual obligations.

On occasion we may ask for your consent to hold special categories of data. If we use consent as the reason for processing data, users have the option to withdraw consent at any time. See Rights of Data Subjects below.

Extra precautionary measures are taken to ensure the security of special categories of data.

Children

We do not market this website at those under 18 years old. Consistent with the GDPR we will never knowingly request personally identifiable information through the website from anyone under the age of 16 years old.

Information we get from other sources

From time to time, we may need to obtain information from third parties about you. This will only apply where it is necessary to provide our services and as permitted by law.

We may use personal data from the following sources:

  • HMRC, DWP and other government departments;
  • NHS health professionals, CQC and healthcare providers;
  • Social workers and local authorities;
  • emergency services.

We may receive information from these sources regarding a service user’s health and care including admission details, care records and medical records. Some of these will be joint data controllers and also have responsibilities and obligations in relation to the processing of users’ personal data. Users are advised to refer to the Privacy Policy of the individual organisation.

From time to time and in certain circumstances, we might also process personal data about relatives, some of which could include special categories of personal data. Any such data will be processed in accordance with this Privacy Policy.

How do we use your data?

Personal information is usually collected directly from service users or those making a referral to the service through form filling, manually or electronically. This is used, and built upon, in the provision of care and related arrangements.

Additionally, we may use the information we collect in the following ways:

  • To administer and improve the website;
  • To personalise the content and your experience of the website;
  • To allow us to respond to communications sent to us;
  • To process referrals or applications for services;
  • To ensure the safeguarding of users;
  • To provide third parties with statistical information about our users;
  • To deal with enquiries and complaints made by or about you relating to the website.

Users contacting the website do so at their own discretion and provide any such personal details requested at their own risk. Personal information is kept private and stored securely until a time it is no longer required or has no use. See Data Retention below.

Sharing Information

Disclosure

We will share the personal data of service users with other professionals and agencies involved with their care and treatment. We will take appropriate steps to ensure that personal data is handled safely, securely, and in accordance with a user’s rights.

We may disclose your personal information if we are required to do so by law, in connection with any legal proceedings, and in order to establish, exercise or defend our legal rights, or if otherwise legally permitted.

Data Processors

We may use Data Processors who act on our instruction in relation to the management of your data and they must adhere to all data protection laws and regulations. We will ensure that any Data Processors used only operate on our written instructions and comply with their obligations under the GDPR. You will be informed of any other Data Controllers who have access to your data and who may determine processing activities separately to us, or as a Joint Data Controller.

Payment processing

We do not process any payment information through the website. All payments are handled in accordance with this Policy and personal information provided to us is kept securely.

Data Retention

We keep your personal information in accordance with our Data Retention Policy which reflects our needs to provide services to you as contracted and also as required to meet legal, statutory and regulatory obligations. The need to hold information is regularly reviewed and data will be disposed of when no longer required. Please email us to request a copy of the Data Retention policy.

Data Security

Personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.

We take appropriate steps to ensure the safe processing of personal data, however, we cannot guarantee the security of data transmitted through our website or by email.  Any transmission is at your own risk.

Data Storage

Data stored electronically may be saved on a cloud-based system which may be hosted in a different country. Your data may be transferred in accordance with the relevant data protection laws.

Rights of Data Subjects

Transition 360 recognises a data subjects rights and will uphold these in accordance with data protection laws. You are entitled to see the information held about you and you may ask us about any of the following:

Subject access requests

Data subjects (i.e. individuals) have the right to access personal data that is held by submitting a subject access request (SAR) to Transition 360. We will endeavour to respond quickly to any such requests, which legally require us to respond within one month of receiving the request and necessary information. A subject access request can be made by sending an email to info@transition360.org.uk

Right to rectification

Data subjects have the right to request that we amend or change personal information that is inaccurate or incorrect.

Right to erasure

Data subjects have the right to ask us to delete personal information from our systems without giving any reason and at any time. We will act on any such request without delay.

Right to restrict processing

Data subjects have the right to rectification or erasure of personal data in the following circumstances:

  • Personal data is not accurate;
  • The processing of data is unlawful – data subjects may request that processing is restricted;
  • Data is required to exercise legal rights or defend legal claims;
  • Data is unlawful but there may be lawful grounds for processing, which override this right.

Right to data portability

Data subjects have the right to obtain and request the transfer of their data to different service providers.

Right to object

Data subjects have the right to object to the processing of data at any time based on their particular situation. This includes objecting to profiling unless it is in the ‘public interest’ or exercised lawfully by an official authority. We will only process data under lawful grounds.

Right not to be subject to decisions based on automated processing

We do not use any automated processing that results in any automated decision based on a data subject’s personal information.

Using your rights

If you wish to invoke any of these rights, you should contact the person responsible for data protection by emailing us at info@transition360.org.uk.

Data Breaches

We will report any unlawful breach of data as required by the GDPR within 72 hours of the breach occurring, if it is considered that there is an actual, or possibility, that data within our control including the control of our data processors, has been compromised. If the breach is classified as ‘high risk’ we will notify all data subjects concerned using an appropriate means of communication. We will report any relevant breaches to the ICO, see below.

 

COOKIES POLICY

This website uses Cookies to enable users to view the contents on the internet.

What are Cookies

Cookies are small files saved to the user’s computer hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server, to provide the user with a tailored experience when navigating the website. Session cookies may be used to validate your access to different parts of the website.

Disabling Cookies

If you are uncomfortable with the use of cookies, you can disable cookies on your device by changing the settings in the preferences or options menu in your browser.  You can set your browser to reject or block cookies or to tell you when a website tries to put a cookie on your device. You can also delete any cookies that are already stored on your device.  However, please be aware that if you do delete and block all cookies from our website, parts of the site may not fully function.

How we use Cookies

The Transition 360 website uses cookies to show content on the internet. Cookies are a user’s identification card for our servers. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer or device. This complies with UK legislation which requires that explicit consent is given by users before reading files are left, or applied, on a user’s computer or device.

To the extent that cookies data constitutes personally identifiable information, we process such data on the basis of your consent.

Types of Cookies

The types of Cookies we use are:

  • Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
  • Statistics cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
  • Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
  • Some cookies may be unclassified.

Cookies can be placed for a user’s session or will be persistent. See below table.

Cookies we use

The Cookies we use are shown in this table below.

Cookie Provider Type Use Retention Period
fontSize transition360.org.uk HTTP Size of Font 1 Year
themes HTML WordPress Theme Persistent
timestamp HTML WordPress Timestamp Persistent

Consent to Cookies

If you accept the use of Cookies on this website, you consent to the processing of data about you by us and any third parties as identified above in accordance with this policy and our Privacy Policy. You have the right to withdraw your consent at any time by sending an email to us at info@transition360.org.uk

Further information

Guidelines for the processing and handling of data and use of Cookies is available from the Information Commissioner’s Office, the UK supervisory authority on data protection, see ico.org.uk.

Information is also available at www.ec.europa.eu/ipg/basics/legal/cookies/index_en.html.

Important Information

Questions and queries

If you have any concerns about how we handle your data, you can contact the person responsible for data protection matters by email to info@transition360.org.uk

Changes to this policy

We reserve the right to change this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website.

You will be deemed to have accepted any changes to the terms of the Privacy Policy on your next visit of the website following the amendment.

Complaints

If you want to raise a concern about the use of your data, you can contact us by email to info@transition360.org.uk. Alternatively, you can formally raise a concern or complaint to the Information Commissioner’s Office (ICO) directly on 0303 123 1113, or see the options for reporting issues on https://ico.org.uk/concerns/

Copyright © 2018 Transition 360 Limited