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  1. Introduction

    We are committed to protecting your personal data, our policy below states how we collect, store, and use personal data.

    Kings Lodge Complex Care will be referred to in this privacy notice as "Kings Lodge" / "We" / "Our" / "Us". We are committed to ensuring that your privacy is protected.

    We comply with the UK General Data Protection Regulation (“UK GDPR”) unless and until the UK GDPR is no longer directly applicable in the UK. We also follow all national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, and any successor legislation to the UK GDPR and the DPA 2018 (together “Data Protection Legislation”).

    This Privacy Policy sets out how we collect personal information from you and how the personal information you provide will be processed by Us. By visiting the website at http://www.complexneeds.com/ (the “Website”) you are accepting and consenting to the practices described in this Privacy Policy.
    Any questions in relation to Data Protection should be directed to the Data Protection Officer (see the Section “How to Contact Us”).
     
  2. Information About us

    Our Site is owned and operated by Alum Care Ltd, a company incorporated in England and Wales. Our company number is 05294296.

    Kings Lodge is the data controller when it uses your information for these commercial purposes. Its registered address is:

    King's Lodge Centre for Complex Needs, King's Cross Lane, South Nutfield, Redhill, Surrey, RH1 5PA

    Any questions in relation to Data Protection should be directed to the Data Protection Officer (see the Section “How to Contact Us”).
     
  3. What data do We Collect and how do We use it?

    Information you give Kings Lodge:

    You may give us information about you by completing enquiry forms on the website.

    When you enquire about our care services your personal information including your name, address, telephone numbers and email address.

    We will retain this information while we are corresponding with you or providing services to you or to a Resident you represent.

    Information Kings Lodge collects about you: Kings Lodge may collect the following information from you when you visit the website:
     
    • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
       
    • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from the website (including date and time), products you viewed or searched for, page response times, website errors, length of visits to certain pages, page interaction information, methods used to browse away from the page and any phone number used to call our helpline.

    Where you are resident in our residential care home or receiving care services
    • Personal details including your title, full name, maiden name, marital status, date of birth, gender, contact details including address (billing address or correspondence address), telephone numbers, email addresses, contact details for next of kin, your GP and other allied health professionals.
    • Financial information including bank account information to enable payment of services.
    • Transaction data including details of payments from you for the services we have provided.
    • Information about your life, including social history, health and well-being, treatment and care. This may also include information about your marital status, ethnicity and sexual orientation and details of medical treatments.
    • Notes and reports about your health and care provision including case assessments and medication provided.
    • Compliments, complaints, accidents and incidents information.
    • Contributions to resident questionnaires and surveys.

    Where you are the relative, next of kin, attorney or deputy to one of our residents
    Personal details including title, full name, relationship to the resident, contact details including address, telephone numbers, email addresses.

    When you visit one of our care homes
    • Name of the visitor, purpose of their visit and car registration details if car parking was used.
    • Information relating to the prevention and detection of crime and the safety of residents and workers including CCTV recording.

    Cookies

    The Website uses cookies to distinguish you from other users of the website. For detailed information on the cookies, we use and the purposes for which we use them, please see our Cookie Policy https://www.complexneeds.com/cookie-policy
    We may use the information we receive and/or collect about you to:
     
    • Fulfil our obligations under any contract that we have entered into with you or with a Resident that you represent, and to provide you or the relevant Resident with information or services that you or the Resident has requested
       
    • Monitor website usage and provide statistics to third parties for the purposes of improving and developing the website and the services we provide via the website
       
  4. Lawful basis for processing

    We will only use your personal data when the law allows Us. Most commonly, we will use your personal data in the following circumstances:
    • Where We need to perform the contract, we are about to enter into or have entered into with you.
    • Where we need to comply with a legal or regulatory obligation.
    • Where it is necessary for our legitimate interests (or those of a third party) in providing Our services to you and your interests and fundamental rights and not overridden by those interests.
    • In rare cases we may need to use your personal data in the following circumstances:
      • Where we need to protect your vital interests e.g., in an emergency life or death situation where the emergency services are called to treat you when you are with us.
      • Where we need to perform a task carried out in the public interest e.g., in certain safeguarding situations.
    • We rely on consent as a legal basis for processing your personal data in relation to sending marketing communications to you via email or to legitimise dealing with Special Category Data. You have the right to withdraw consent at any time by contacting the Us, although this will not prevent processing where the law allows us to process for a different reason in addition to consent.
       
  5. How do We use the information about you?

    We process your personal data to manage the services We provide you, to carry out our obligations arising from any contracts entered into between Us and you, to provide you with information or services you have requested and to process payments and refunds.
     
    • Your care record will contain detailed information about your health and well being including illnesses, medical appointments, and treatments. It will also contain details of your attorney, deputies, your close family and next of kin. We will share these with medical and allied health professionals who have a legal and legitimate need to use the information to support the care provided to you.
    • We share information within Kings Lodge to provide necessary administrative and managerial support.
    • We use either personal or anonymised data to review the performance of our care services as part of our continuing work to improve our services and meet the needs of our residents.
    • We may use your details to contact you about any changes to our care services.
    • We share information with NHS Clinical Commissioning Groups (CCGs), local and health authorities, medical professionals and regulators regarding residents’ health and care including admission details, care records and medical records.
       
    We are required from time to time to provide specific information about you without your or your representative’s consent. This may include:
    • Reporting health or safety issues including infectious diseases
    • Where there is a legal or statutory requirement, court order or public authority instructing Us to do so
    • Supporting police investigations, professional conduct hearings and safeguarding investigations in the public interest.

       
    • In exceptional circumstances, We may be required to share information without your or your representative’s consent. Circumstances may include:
      • Where a serious crime or fraud has been committed.
      • If there is a serious risk to the public, residents or employees.
      • Where there is a need to protect a vulnerable adult who is not able to decide if their personal data should be shared
      Kings Lodge processes personal information for certain legitimate business purposes, which include some or all of the following:
       
      • Where the processing enables Kings Lodge to enhance, modify, personalise or otherwise improve the website, its services or communications
      • To identify and prevent fraud
      • To enhance the security of the network and information systems of Kings Lodge
      • To better understand how people interact with the websites of Kings Lodge
      • To administer the website and carry out data analysis, troubleshooting and testing.

      If We obtain consent from you to do so, We may provide your personal details to third parties so that they can contact you directly in respect of services in which you may be interested.

      Where we are processing personal data that We have obtained via the website on the basis of having obtained consent from you, you have the right to withdraw your consent to the processing of your personal data at any time.
      If you would like to withdraw your consent or prefer not to receive any of the above-mentioned information (or if you only want to receive certain information from Us) please let us know by using the details set out in Section “How to Contact Us”. Please bear in mind that if you object, this may affect our ability to carry out the tasks above for your benefit.

       
  6. How do We protect your data?

    Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected through Our Site.

    We will do our best to protect your personal data but the transmission of information via the Internet is not completely secure. Any such transmission is, therefore, at your own risk.

    Where we engage third parties to process personal data on our behalf, they do so upon writing and are contracted to implement appropriate technical and organisational measures to ensure the security of data.
     
  7. Where We Store your Personal Data

    Although we have left the EU, UK GDPR still requires the following: The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") By submitting your personal data, you agree to this transfer, storing or processing.

    Kings Lodge will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

    If a finding of adequacy hasn't been made by the EC Commission in respect of the country to which the data is transferred, we will only transfer it where there are appropriate safeguards in place, including the use of EU standard contractual clauses or an intragroup agreement.
     
  8. How long do We keep your data?

    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will only keep your information for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, contractual or reporting requirements.

    How long We keep the data for is determined by law and is largely determined by necessity. Once your information is no longer required it will be securely destroyed.

    We may anonymise your personal data (so that you can no longer be identified) for research and analysis purposes in which case we may use this information indefinitely without further notice to you. Where we process data based solely on your consent, you have the right to withdraw that consent at any time.

    Whilst at all times compliant with legislation and acting reasonably, we reserve the right to judge what information we must continue to hold to be able to fulfil our legal and contractual obligations to you.

    Even if we delete your Personal Information, we reserve the right to retain your personal data where such retention is necessary for compliance with a Statutory obligation (for example to maintain a copy for legal, tax or regulatory purposes,) but in such event, we will do so only as long as necessary to fulfil those Statutory obligations
     
  9. How do We share your data?

    We are committed to not sharing your data and will only do this if it is in your legitimate interest to ensure We provide you with the support and information required to make an informed decision about our product(s).

    We will not sell your data to any unconnected third parties.

    We may contract with third parties to supply products and services to you on our behalf. These may include payment processing and the delivery of goods.

    In some cases, third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with:

    We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006. We may share your information with selected third parties including:
    • Business partners, suppliers and sub-contractors for the performance of any contract we enter with them or you.

    In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

    Please note, we may need to disclose your personal information where we:
    • Sell any or all of our business or assets or we buy another business or assets in which case we may disclose your personal data to the prospective buyer or seller
    • Are under a legal duty to comply with any legal obligation or to enforce or apply our terms and conditions; or
    • Need to disclose it to protect our rights, property or the safety of our customers or others, including the exchange of information with other companies, organisations and/or governmental bodies for the purposes of fraud protection and credit risk reduction
       
  10. How Can You Control Your Data?

    When you submit information via Our Site, you may be given the ability to opt out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails or by emailing us.

    You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data. You may restrict your Internet browser’s use of Cookies. For more information, see Our Cookie Policy.

    You may withdraw your consent for Us to use your personal data at any time by contacting Us and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
     
  11. Summary of Your Rights

    As a data subject, you have a number of rights and control over how your data is used.
    • You can request access to, deletion of, or correction of, your personal data held by Us.
    • You can ask for a copy of the data you have given Us.
    • You can require Us to amend or change incorrect or incomplete data.
    • You can require Us to delete or stop processing your data, where the data is no longer necessary for the purposes of the processing.
    • You can object to the processing of your data where We are relying on its legitimate interests as the legal ground for the processing.
    • You can ask Us to stop processing data for a period if the data is inaccurate or there is a dispute about whether or not your interests override the company's legitimate grounds for processing data.

    To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Notice, please contact Us using the details set out in the Section “How to Contact Us”.

    If any of the information you provide to Us via the website changes, please let us know as soon as possible so that We can make the necessary changes to the information we hold for you on our database, by using the details set out in Section “How to Contact Us”.
     
  12. How to Contact Us

    If you have any questions about Our Site or this Privacy Policy, please contact Us by email at Our Data Protection Officer can be contacted at DPO@complexneeds.com with the subject line Data Protection or by telephone on +44 (0) 1737 822221, ask for the Data Protection Officer. or by post to the Data Protection Officer King's Lodge Centre for Complex Needs, King's Cross Lane, South Nutfield, Redhill, Surrey, RH1 5PA

    Please ensure that your query is clear, particularly if it is a request for information about the data, We hold about you.
  13. How to complain

    If you are unhappy with the way that we have processed or handled your data, please contact Us (see Section 12 How to Contact Us).

    If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint to the Information Commissioner’s Office (ICO). The ICO is the supervisory body authorised by the Data Protection Act 2018 to regulate the handling of personal data within the United Kingdom. The contact details for the Information Commissioner’s Office are:

    Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
    Telephone: 0303 123 1113 Website: https://ico.org.uk/concerns/

    Our registration number with the Information Commissioner's Office is: ZA614637
     
  14. Changes to Our Privacy Notice

    We may change this Privacy Notice as we may deem necessary from time to time, or as may be required by English law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Notice on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.