Privacy Notice: Home Improvement Agency

Last Updated: 26th July 2023

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 NOTICE COVERS
  2. PERSONAL DATA WE COLLECT ABOUT YOU
  3. HOW WE COLLECT YOUR PERSONAL DATA
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. COMPLAINTS

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 client of our Home Services Division which covers our Home Improvement Agency (HIA) and Ceiling Track Hoist and Stairlift service (CTHSL).

Who We Are 

Millbrook Healthcare Group Ltd (MHC) is a provider of Technology Enabled 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 dpo@millbrookhealthcare.co.uk.

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: this includes information such as your title, full name, home address, date of birth, and NI number.
  • DFG Data: information about previous Disability Facilities Grants you’ve applied for.
  • Property Data: this includes information about whether you’re an owner or tenant, what type of premises you live in (flat, detached home, town house), what alterations and/or installations are required, who else lives at the property, and who else owns the property.
  • Contact Data: includes your main contact number and email address (based on your contact preference).
  • Financial Data: may include information about the results of any means tested benefits you have had; information about your current assets such as savings, shares, properties, or other investments; or revenue from grants, loans or other business ventures.
  • 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.
  • Call Data: includes recordings of inbound and outbound calls made between us and you.
  • Health Data: includes information about your current health condition(s), diagnoses, details about your mobility, and information around what care or support you currently have in place.
  • Safeguarding Data: includes information about neglect, harm or abuse.
  • Gender and Ethnicity Data: includes information about your gender and ethnicity.
  • Feedback Data: includes any feedback or complaint you provide us about your experience.

    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 us by your local authority.
    • When we become the new service provider of a HIA contract with your local authority.
    • Through any contact we have with you when you contact us, or when we visit you.

      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 determine if you’re eligible for a Disability Facilities Grant (DFG) and, if so, how much funding you will receive.

      We carry out a financial status assessment by assessing your:

      ·       means tested benefits; or

      ·       current financial assets (if means tested benefits does not apply);

      ·       and any previous disability funded grants you have had.

      Part of this process requires us to assess whether you’re a child or not to determine whether your assets are means tested. We process your DOB information to determine this.

      All of this information is shared with public bodies (see section 5) as part of the DFG process.

      (a) Identity

      (b) DFG

      (c) Contact

      (d) Property

      (e) Financial

      (a) Carrying out a public task on behalf of the Controller.

      We process data about a service user’s carers or next of kin to facilitate the DFG process where the service user has mental capacity issues.

      (a) Carer

      (a) Legitimate interests (to facilitate the DFG process).

      If you’re a tenant, we share some of your data with your landlord to get their permission for adaptation works.

      (a) Identity

      (b) Property

      (a) Consent

      To contact you regarding your grant application and to respond to your enquires.

      (a) Identity

      (b) Contact

      (a) Carrying out a public task on behalf of the Controller.

      We share some of your data with contractors (see section 5) so they can assess and quote for the works that need to be completed and so they can ensure health safety standards are met during the work.

      (a) Identity

      (b) Property

      (c) Health

       

      (a) Consent

      Once works are completed, we assess the works to check it meets your health needs as identified by your occupational therapist.

      (a) Property

      (b) Health

      (a) Carrying out a public task on behalf of the Controller.

      To determine the priority of your appointment.

      (a) Health

      (a) Carrying out a public task on behalf of the Controller

      (b) Processing health data is necessary for reasons of public interests in the area of public health carried out on behalf of the Controller

      To ensure our service is accessible to everyone in your local catchment.

      (a) Gender and Ethnicity

      (a) Carrying out a public task on behalf of the Controller

      (b) Processing Gender and Ethnicity data is necessary for reasons of substantial public interests carried out on behalf of the Controller

      To investigate any concerns or complaints you have made about our 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)

      If we witness any safeguarding concerns, we will share this information with your Local Authority and/ or law enforcement.

      (a) Identify

      (b) Safeguarding

      (a) Necessary in order to protect the vital interests of a service user

      (b) Legitimate interests (detection and prevention of crime)

      We record all inbound and outbound calls made to service centres to ensure we maintain quality customer service, to resolve customer complaints promptly, and to train staff.

      (a) Contact

      (b) Call

      (a) Necessary for our legitimate interests (to meet our contractual and quality compliance obligations)

      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 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 external service providers to deliver our services. All providers and their staff are required to always keep your Personal Data confidential and secure.

      Business Asset Service Providers:

      These are external companies that we use to help us provide our day-to-day service such as IT software providers, website operation, and 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.

      Landlords:

      If you’re a tenant of your property, we are required to get in touch with your landlord to get their permission for any works to be completed. As per the table above, we will share some of your basic information with them to enable them to identify which property you live in.

      Contractors:

      We share some of your basic information with contractors so they can assess and quote for the works to be carried out to your property.

      Public Bodies:

      We may share some of your data with health services, social care, funding partners, local authorities where they assist with paying for some / all of your grant, or where we need to apply for building approval.

      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 Plus 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

      We 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.

      Our retention periods are maintained in-line with the NHS Records Management Code of Practice 2021 and any applicable legal, regulatory, tax, accounting or other statutory requirements we are required to meet.

      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 are relying 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 our services and may need to end the contract between us. 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 us at: dpo@millbrookhealthcare.co.uk

      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.

      If you would like to action any of your requests, please email dpo@millbrookhealthcare.co.uk.

      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: feedback@millbrookhealthcare.co.uk