Privacy Policy

1. Who we are and what we do

Who we are

We are Care in Mind (“Care in Mind”, “us”, “we”, “our”). We are a limited company registered in England and Wales under registration number 06906017 and we have our registered office at 2 Hilliards Court, Chester Business Park, Chester, CH4 9PX. We are registered with the UK supervisory authority, Information Commissioner’s Office (“ICO”) in relation to our processing of Personal Data under registration number Z2225703.

What we do

We are a specialist mental health package provider for young people aged 16-30 in a residential care setting. We are committed to protecting the privacy and security of the Personal Data we process about you.

Controller

Unless we notify you otherwise, we are the controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.

2. Purpose of this privacy notice

The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below under the ‘How to contact us’ section.

3. Who this privacy notice applies to

This privacy notice applies to you if:

1. You visit our website
2. You receive services from us
3. You enquire about our services
4. You sign up to receive newsletters and/or other promotional communications from us

4. What Personal Data is

‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.

‘Special Category Personal Data’ is more sensitive Personal Data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health or data concerning someone’s sex life or sexual orientation.

5. Personal Data we collect

The type of Personal Data we collect about you will depend on our relationship with you. For the type of Personal Data we collect see the table below in the section entitled ‘Purposes, lawful bases and retention periods’.

The personal information we collect about you may include (but is not limited to):

• your name, address and contact details including telephone number, job title and email address;
• marketing data such as your preferences for receiving communications from us;
• post content to our website or via our social media channels;
• information about the services we provide to you; and
• technical data including Internet Protocol (IP) address details including your public browser type and version.

Via Social media

Depending on your settings and the relevant policies and terms of service, when using social media and messaging services like LinkedIn and Facebook you might give us permission to access information about you from those accounts or services. Please refer to their privacy policy for more information.

We use this personal information for various reasons including to:

• create and manage you’re support with us;
• verify your identity; Business Important.
• communicate with you when providing our support to you;
• notify you of any changes to our support that may affect you;
• improve our support services; and
• send you marketing material.

How we collect your Personal Data

We collect most of the Personal Data directly from you in person, by telephone, text or email and/or via our website. However, we may also collect your Personal Data from third parties such as others to whom you have provided consent.

6. Purposes, lawful bases and retention periods

We may process your information on the following lawful bases and for the following purposes (including but not limited to):

7. Sharing your Personal Data

We may share your Personal Data with our carefully selected third parties, for example, we may use a supplier to provide services which support the services which we provide to you. In this case, we remain responsible for your personal data and will ensure we have a written agreement in place with any third party provider. We currently use third-party suppliers:

• for invoice purposes
• to set up direct debits and payments
• for software for internal business purposes
  for marketing and business development purposes

We may also share your Personal Data with:

• law enforcement or other authorities if required by applicable law; and
• third parties if there is a change in the ownership of CovertSwarm or any of our assets.

8. International Transfers

Your Personal Data may be processed outside of the UK. This is because the organisations we use to provide our service to you are based outside the UK.

We have taken appropriate steps to ensure that the Personal Data processed outside the UK has an essentially equivalent level of protection to that guaranteed in the UK. We do this by ensuring that:

Your Personal Data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation), or

We enter into an International Data Transfer Agreement (“IDTA”) with the receiving organisation and adopt supplementary measures, where necessary. (A copy of the IDTA can be found here international-data-transfer-agreement.pdf (ico.org.uk)).

9. Your rights and how to complain

You have certain rights in relation to the processing of your Personal Data, including to:

Right to be informed

You have the right to know what personal data we collect about you, how we use it, Business Important.

for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this.

Right of access (commonly known as a “Subject Access Request”)

You have the right to receive a copy of the Personal Data we hold about you.

Right to rectification

You have the right to have any incomplete or inaccurate information we hold about you corrected.

Right to erasure (commonly known as the right to be forgotten)

You have the right to ask us to delete your Personal Data.

Right to object to processing

You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material.

Right to restrict processing

You have the right to restrict our use of your Personal Data.

Right to portability

You have the right to ask us to transfer your Personal Data to another party.

Automated decision-making. You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making.

Right to withdraw consent

If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so.

Right to lodge a complaint

You have the right to lodge a complaint with the relevant supervisory authority, if you are concerned about the way in which we are handling your Personal Data. The supervisory authority in the UK is the Information Commissioner’s Office who can be contacted online at:

Contact us | ICO

Or by telephone on 0303 123 1113 Business Important.

For supervisory authorities in other countries within the EU see the link below:

https://edpb.europa.eu/about-edpb/about-edpb/members_en

How to exercise your rights

You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

If you wish to exercise your rights, you may contact us using the details set out below within the section called ‘How to contact us and our Data Protection Officer’. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated.

10. Children’s Privacy

We do not offer our products and services to children and we do not knowingly collect Personal Data of children without parental consent, unless permitted by law. If you are a child, you must have your parent’s permission to use our services. If you learn that a child has provided us with their Personal Data without parental consent, you may contact us, as described below, and if appropriate, we will securely and permanently delete it, in accordance with applicable law.

11. How to contact us and our Data Protection Officer

If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, please contact us as follows:

Care in Mind, Hope House, Hercules Office Park, Bird Hall Lane, Stockport SK3 0UX

rachel.scullion@careinmind.com

We have also appointed a Data protection Officer (“DPO”). Our DPO is Evalian and can be contacted as follows:

Evalian Limited, West Lodge, Leylands Business Park, Colden Common, Hampshire, SO21 1TH, UK

dpo@evalian.co.uk Business Important.

Please mark your communications FAO the ‘Data Protection Officer’.

12. Changes to this privacy notice

We may update this notice (and any supplemental privacy notice), from time to time . We will notify of the changes where required by applicable law to do so.