Data Protection Policy
- Business details
This is the privacy notice for the Lindemann Healthcare group which covers Thorburn Manor Limited, Lorimer House Limited, Morningside Manor Limited & Jubilee House Limited.
Our registered office is at 29 York Place Edinburgh, EH1 3HP
The above Homes are registered with the Care Quality Commission to provide personal care to elderly resident within each of our residential Homes
- Aims of this notice
Lindemann Healthcare is required by law to tell you about your rights and our obligations regarding our collecting and processing any of your personal information, which you might provide to us. We have a range of policies and procedures to ensure that any personal information you supply is only with your active consent and will always be held securely and treated confidentially in line with the applicable regulations. We have listed the relevant documents in a later section (6) and can make any available.
- What personal information we collect about: a) service users b) employees and c) third parties
- Service users. As a registered care provider, we must collect some personal information on our service users, including financial information, which is essential to our being able to provide effective care and support. The information is contained in individual files (manual and electronic) and other record systems, all of which are subject to strict security and authorised access policies. Personal information that becomes inactive, eg from enquiries or prospective users who do not enter the service is also kept securely for as long as it is needed, before being safely disposed of.
- Employees and volunteers. The service operates a safe recruitment policy to comply with the regulations in which all personal information obtained, including CVs and references, financial informaiton is, like service users’ information, securely kept, retained and disposed of in line with data protection requirements. All employees are aware of their right to access any information about them.
- Third parties. All personal information obtained about others associated with the delivery of the care service, including contractors, visitors, etc will be protected in the same ways as information on service users and employees.
- How we collect information
The bulk of service users’, employees’ and thirds parties’ personal information is collected directly from them or through form filling, mainly manually, but also electronically for some purposes, eg when contacting the service through its website.
With service users, we might continue to build on the information provided in enquiry and referral forms, and, for example, from needs assessments, which feed into their care and support plans.
With employees, personal information is obtained directly and with consent through such means as references, testimonials and criminal records (DBS) checks. When recruiting staff, we seek applicants explicit consent to obtain all the information needed for us to decide to employ them.
All personal information obtained to meet our regulatory requirements will always be treated in line with our explicit consent, data protection and confidentiality policies.
- What we do with personal information
All personal information obtained on service users, employees and third parties is used only to ensure that we provide a service, which is consistent with our purpose of providing a person-centred care service, which meets all regulatory standards and requirements. It will not be disclosed or shared for any other purpose.
- How we keep your information safe
As already stated, the service has a range of policies that enable us to comply with all data protection requirements. The foremost are:
- Data protection policy
- Record Keeping
- Consent to Care and Treatment
- Complaints policy
- Safe staff recruitment and selections
- Compliance with the General Data Protection Regulation
- With whom we might share information
- We only share the personal information of service users, employees and others with their consent on a “need to know” basis, observing strict protocols in doing so. Most information sharing of service users’ information is with other professionals and agencies involved with their care and treatment. Likewise, we would not disclose information about our employees without their clear agreement, eg when providing a reference.
- The only exceptions to this general rule would be where we are required by law to provide information, eg to help with a criminal investigation. Even when seeking to notify the local authority of a safeguarding matter or the Care Quality Commission of an incident that requires us to notify it, we would only do so with consent or ensure that the information provided is treated in confidence.
- Where we provide information for statistical purposes, the information is aggregated and provided anonymously so that there is no privacy risk involved in its use.
- How personal information held by the care provider can be accessed
- There are procedures in place to enable any staff member, employee or third party whose personal information we possess and might process in some way to have access to that information on request through a subject access request. The right to access includes both the information and any uses which we might have made of the information.
- How long we keep information
- There are strict protocols in place that determine how long the organisation will keep the information, these are set out in our retention schedule.
- Your rights
- Under the Data Protection Law (GDPR) you have a number of rights. These are:
- Right to Confirmation and Access
- The right to confirm what personal data is being held and to what purpose it is being used.
- To obtain copies of the personal data that is being held about you.
- Right to Be Forgotten (Right to Erasure). Where it is legal for us to do so and does not impact on our ability to provide care or comply with our duty to other employees or service users.
- The right to object to processing of data
- The right to rectification of data
- The right to withdrawal of Consent and/or Limit Processing
- Right to Data Transfer and request data format
- The Right to Complain
- If at any time you feel that we have failed to safeguard your information appropriately you have the right to complain.
- In the first instance we would ask you to contact us and allow us to investigate and identify any issues you may have, by contacting us by email our Data Protection Officer on HR@lindemann.healthcare.
- You do however have the right to complain directly to the Information Commissioners Office (ICO) and they can be contacted here:
- Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, +44 (0) 303 123 1113, Email: email@example.com. Website: https//ico.org.uk.
- We operate a Privacy by Design and By Default policy. This means that before we use your data we have already considered the potential impact on you were your data to be lost, stolen, shared or compromised.
- Consequently, we may also need to sometimes undertake further security and screening questions when undertaking our routine dealings with you these are there to protect your personal data and security.
- Whilst we undertake all reasonable precautions, encryption, software updates and patches, we cannot guarantee the safety of data transmitted over the internet.
- How we will respond to a data breach
- In the event of a data breach of your personal data, which means:
- “The unintended loss, destruction amendment or disclosure of personal data”
- We will first do all that is necessary in order to minimise the impact on you, identify any potential malicious third-party, identify any third-parties that may also be impacted and take all reasonable efforts to ensure that you are notified.
- In the event that we are notified by a third-party of a breach, in their systems, we will undertake the same level of efforts.
- We will undertake this communication either directly with you as an individual or by sending out a public notification.
- At the same time, we will comply with the current law in respect of informing the appropriate supervisory authority which is currently the Information Commissioners Office (ICO). We are under a legal requirement to report data breaches to the ICO.
- How we keep our privacy policies up to date
- The staff appointed to control and process personal information in our organisation are delegated to assess all privacy risks continuously and to carry out comprehensive reviews of our data protection policies, procedures and protocols at least annually.