Last updated: 11th November 2024
Please read this privacy notice (‘Notice’) carefully to understand how Millbrook Healthcare Group Ltd looks after your Personal Data.
We have set this Notice out in a layered format so you can click quickly navigate to the specific areas set out below.
1. WHO WE ARE AND WHAT THIS PRIVACY NOTICE COVERS
What This Privacy Notice Covers
This Notice covers how we look after and handle your Personal Data as a user of our Community Equipment Service.
Who We Are
Millbrook Healthcare Group Ltd (MHC) is a provider of Community Equipment Services across England and Wales (collectively referred to as “MHC”, “we”, “us” or “our” in this privacy policy). We process your data on behalf of your Local Authority or NHS as a Processor and also act as a Controller for some of the data you provide us.
MHC’s registered office is at Nutsey Lane, Calmore Industrial Estate, Totton, Southampton, Hampshire, SO40 3XJ.
Data Protection Officer
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise rights, please email [email protected].
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). It’s our priority to ensure you are satisfied with our data processing practices. If you do find you have a complaint, we would appreciate the chance to try and resolve any issues you have before you approach the ICO.
Changes to the privacy policy and your duty to inform us of changes
We keep this Notice under regular review. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
2. PERSONAL DATA WE COLLECT ABOUT YOU
As a service user we process the following types of personal data about you:
- Identity Data: includes basic details such as your title, full name, home address, date of birth, NHS number, and any access codes for doors or locks.
- Contact Data: includes your telephone number or mobile number, and email address.
- Equipment Data: includes information about the current equipment in your possession, repairs, maintenance, orders, notes about home assessments for installations, and sometimes a photograph of your equipment as proof of delivery.
- Call Data: includes a recording of our call conversation, and the date and time of the call.
- Safeguarding Data: includes information about missed appointments, neglect, harm or abuse.
- Feedback Data: includes any feedback or complaint you provide us about your experience.
- Carer Data: includes basic details about your carer(s) or next of kin, including their full name, contact number, contact email, and their relationship to you.
- Health Data: includes information about a service user’s capacity.
3. HOW WE COLLECT YOUR PERSONAL DATA
We receive your person data both directly from you and from other sources as follows:
- When you are referred to our service by the NHS or your Local Authority.
- When we become the new service provider of a contract with the NHS or your Local Authority in your catchment.
- Through any contact we have with you when you contact us, visit us for an appointment, or we visit you at home.
4. HOW WE USE YOUR PERSONAL DATA
The table below explains how we use your data and the lawful basis relied on to use your data.
|
How we use your Personal Data |
Type of data |
Lawful basis |
|
To deliver, install, repair or collect your equipment. To assess your home environment to install your equipment by our trusted assessor (when required). |
(a) Identity (b) Contact (d) Equipment |
(a) Carrying out a task in the public interest |
|
To respond to your enquires, and inform you of your appointments via phone call, email or SMS (depending on your preference). Where a service user lacks capacity, we liaise with the service user’s carer or next of kin when providing our service. |
(a) Identity (b) Contact (c) Carer (d) Health |
(a) Carrying out a task in the public interest (b) Processing is necessary for the management of healthcare systems or services |
|
We record all inbound and outbound calls made to our customer service teams and monitoring centre to ensure we maintain quality customer service, to resolve customer complaints promptly, and to train staff. |
(a) Identity (b) Call (c) Technical |
(a) Necessary for our legitimate interests (to maintain quality assurance)
|
|
To investigate any concerns or complaints you have made about the service. |
(a) Identity (b) Contact (c) Feedback |
(a) Legitimate interests (to ensure we provide high quality care that meets service users’ expectations and our contractual obligations) |
|
To investigate and report potential safeguarding concerns to your relevant Local Authority and/or law enforcement. |
(a) Identify (b) Safeguarding |
(a) Legitimate interests (detection and prevention of crime & to protect vulnerable people) (b) Necessary in order to protect the vital interests of a service user (c) Processing is necessary for public interests |
|
To administer and protect our business assets which includes troubleshooting, analysis, testing, system maintenance, support, reporting and hosting of data. |
(a) All data categories |
(a) Necessary for our legitimate interests (to maintain the running of our service, and network security) (b) Processing is necessary for the management of healthcare systems or services |
|
In the event Millbrook Healthcare Group Ltd or its assets are acquired by or merged with another company including through bankruptcy, we will share your Personal Data with any of our legal successors. We will also disclose your Personal Data to third parties: (a) when required by applicable law; (b) in response to legal proceedings; (c) in response to a request from a competent law enforcement agency; (d) to protect our rights, privacy, safety or property, or the public; or (e) to enforce the terms of any agreement or the terms of our Website. |
(a) All data categories |
(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to protect our assets and staff) |
5. DISCLOSURES OF YOUR PERSONAL DATA
We only share your necessary Personal Data with the below service providers to deliver our services. All providers, and their selected staff are required to keep your Personal Data confidential and secure at all times.
Business Asset Services Providers:
These are external companies we use to help us provide our day-to-day service such as IT software providers, website operation, cloud hosting providers.
Professional Service Advisers:
These are professional service advisers who help us meet our legal and regulatory compliance requirements which includes auditors (financial and cyber security), legal practitioners, banks and insurers.
Public Services:
We share your data with your Local Authority or local NHS who we provide our service on behalf of.
6. INTERNATIONAL TRANSFERS
We do not transfer any of your data outside of the UK. All your data is stored securely on our private cloud hosted in the UK.
7. DATA SECURITY
Our security measures are in-line with NHS Digital and Government standards, and we are certified by the Cyber Essentials accreditation scheme. In addition, we limit access to your Personal Data to those employees, contractors and other third parties on a need-to-know basis only. They will only process your Personal Data under our instructions and are subject to a duty of confidentiality.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have the following rights in relation to your personal data:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we rely on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with some of our services. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact email us at: [email protected]
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. COMPLAINTS
The complaints team are available to assist you with any comments, concerns and complaints. The team act independently of any of the services we provide ensuring your concerns are thoroughly investigated and responded to in a timely manner. If you wish to make a complaint or provide feedback, please contact us at: [email protected]
