This privacy notice explains how and why we collect and use your personal data when you come into contact with us, including when you use our services, visit our website, partner with us, provide services to us, sign up for our newsletter or get involved in our fundraising activities. It is important that you read this privacy notice so that you are fully aware of how and why we use your personal data.

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We want to make sure 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.

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1. Who are we?

When we refer to “we” or “us” in this privacy notice we are referring to St Augustine's Community Care Trust (charity number 1186457, company number 12124874, trading as Homelink).

We are a controller of your personal data, which means we are responsible for deciding how we hold and use data about you. We are registered with the Information Commissioner’s Office with registration number Z5266820.

We have appointed a privacy manager. If you have any questions about this privacy notice or our data protection practices please contact the privacy manager, Jacqui Parris, CEO on 0208 755 5776 or Jacqui.parris@homelinkdaycare.co.uk.​

 

2. Definitions 

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Personal data means any personal information from which you can be identified, such as your name, your home address, your personal email contact details, or your telephone number. Personal data does not include information where your identity has been removed (anonymous data).

 

Special category data means personal data about your race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation. These types of personal data require a higher level of protection.

 

Criminal offence data means personal data relating to criminal convictions and offences (for example, information about criminal activity, allegations, investigations and proceedings) and can include information about unproven allegations and information relating to the absence of convictions. It also covers related security measures, such as personal data about penalties and conditions or restrictions placed on an individual as part of the criminal justice process. Criminal offence data also requires a higher level of protection. 

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3.  Our clients (Day Service and Home Respite)

When you contact us about using our Day Service or Home Respite, we will collect some personal data from you to register you as a new client and to manage our relationship, including:

• full name and title

• home address 

• personal contact details (including email and telephone number)

• date of birth

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While you are using our Day Service or Home Respite, we may also collect additional personal data from you including:  

• bank account and credit card details

• emergency contact details 

• bank account information

• credit card details

• biographical and behavioural information

• photographs and case studies

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We rely on the following lawful grounds in order to use your personal data:

• it is necessary for us to enter into, or perform, a contract with you; 

• you have given your consent; or

• we have a legitimate interest and we are satisfied that your interests and fundamental rights do not override our interest.

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We will also collect and use special category data about you.  This includes information about your health, such as health conditions and medications, and potentially other data if you decide to share it with us and it is captured in our notes, including your gender, sexual orientation, ethnicity or religion, and/or criminal offence data. We will only collect and use special category or criminal offence data if we have your explicit consent, if there is a substantial public interest, or if it is necessary for the provision of health care or treatment or the provision of social care.

We may share your personal data in the following ways:

• With our funders so that we can report to them on our activities.  This data will be summarised and pseudonymised and no-one other than us will be able to trace the data back to you personally.

• If you are using other services (for example, social services) we may ask for your consent to discuss your personal data with those other service providers so that we can provide you with better care.

• If you have asked us to refer you to another service, we will share your contact details with the other service.

• If there is a safeguarding incident that involves you, or if we have serious concerns about your welfare, we may share your personal data with relevant third parties such as regulators and social services (see section 6 for more information). 

• If you use our bus service, we will share your name, home address and key health information with The Greenwood Centre which runs the bus service.

• If you want to take part in an online event we are running with a third party provider, we may share your name and email address with that provider.

• We may share photographs and case studies that feature you with funders, in marketing materials and on social media.  We will only share your personal data in this way with your consent.

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If you are the next of kin of one of our clients, we may hold your name, contact details and relationship with our client so that we can contact you in emergencies.  We will only use your personal data for this purpose, and to do this we rely on the lawful basis that we have a legitimate interest and we are satisfied that your interests and fundamental rights do not override our interest.  We will not share this personal data with anyone else.

 

4.  Our clients’ carers and Carer Support

If you are a carer of one of our clients or you use our Carer Support service, we will collect some personal data from you to manage our relationship, including your:

• full name and title

• date of birth

• home and/or business address 

• personal and/or business email contact details

• home, mobile and/or business telephone number

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During the course of our relationship, we may also collect additional personal data from you, such as:

• records of conversations either directly with you or as part of our support groups

• biographical information about you

• photographs and case studies

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We rely on the following lawful grounds in order to use your personal data for these purposes:

• it is necessary for us to enter into, or perform, a contract with you; 

• you have given your consent; or

• we have a legitimate interest and we are satisfied that your interests and fundamental rights do not override our interest.

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We may also collect and use special category data and/or criminal offence data about you if you decide to share this information with us and it is captured in our notes (for example, information about your health). We will only collect and use special category or criminal offence data if we have your explicit consent, if there is a substantial public interest, or if it is necessary for the provision of health care or treatment or the provision of social care.

We may share personal data about you with our funders so that we can report to them on our activities.  This data will be summarised and pseudonymised and no-one other than us will be able to trace the data back to you personally.

We may also share photographs and case studies that feature you with funders, in marketing materials and on social media.  We will only share your personal data in this way with your consent.

 

5.  Partners, service providers and other professionals

If you are a partner, service provider or professional who we come into contact with in the course of our work, we may collect the following information about you:

• full name and title

• identity of your employer

• home and/or business address 

• personal and/or business email contact details

• home, mobile and/or business telephone number

We will not share this information with anyone else and will only use it to manage our relationship with you.  In order to use your personal data for this purpose we rely on the lawful ground that we have a legitimate interest and we are satisfied that your interests and fundamental rights do not override our interest.

 

6.  Safeguarding, whistleblowing and complaints

We may collect personal data if we have to deal with complaints, or whistleblowing and safeguarding reports. This personal data may relate to clients, members of the public, staff and volunteers at partner organisations, or anyone else named in or involved with an incident or referred to in a complaint.  

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We may collect the following personal data for these purposes:

• your name, job title, email address and telephone number if you make a report or complaint to us; and

• your name, gender, age, details of family life and details of the concerns or alleged misconduct if you are identified in a report or complaint.

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We may receive this personal data from you directly, or indirectly from people who raise concerns.

We use your personal data for these purposes if we are satisfied that have a legitimate interest to investigate complaints or issues, and we are satisfied that your interests and fundamental rights do not override our interest.

If we collect and use special category and/or criminal offence data about you for these purposes (e.g. if this information features in, or is relevant to, the concerns that are raised) we will always ensure that there is a substantial public interest to support this.

 

7.  Marketing and fundraising

We would like to keep in touch with our supporters and potential supporters about the work that we do, events that we organise and ways in which you can support us (for example, by volunteering your time, by giving a financial donation, or by giving us donations-in-kind).

We will only send you marketing communications by email with your consent.  If you consent to receive email marketing from us, we will add your name and email contact details to our marketing database in order to send the emails to you.

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From time to time, we may also send marketing communications to you by post if we are satisfied that we have a legitimate interest to do so, for example, by posting our newsletter to you.  

We may sometimes make marketing telephone calls to you. We do not regularly carry out telephone marketing and we never use automated calling systems. We will only contact you in this way if we are satisfied that we have a legitimate interest to do so and we will always check the telephone preference service and our own marketing preference records before we make any telephone marketing calls to you.  

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You can contact us at info@homelinkdaycare.co.uk or on  020 8255 1992  at any time to opt out from any of our marketing activities or change your communication preferences.  You can also opt out of email marketing by clicking the ‘unsubscribe’ link in any of our emails.

If you donate to us, we may collect your name, address, contact details and bank and payment card details.  We will use this information to process your donation and to make Gift Aid claims to HM Revenue & Customs (HMRC).

 

8.  Using our website https://homelinkdaycare.co.uk/ 

Our website is not intended for children and we do not knowingly collect data relating to children.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

When you use our website, we may collect the following types of personal data:

• technical data such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the website.

• usage data about how you use our website; and

• data that you provide when you fill in a form on our website or apply for a vacancy through our website. 

Our Cookies Policy has information about how we use cookies on our website and can be provide upon request. 

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We will only collect and use your personal data in this way if:

• it is necessary to enter into, or perform, a contract with you; 

• you have given your consent;

• we need to comply with a legal obligation; or

• it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

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We also collect, use and share aggregated data such as statistical or demographic data, which could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. 

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We do not collect any special category data or criminal offence data about you through our website (including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data or information about criminal convictions and offences).

 

9.  Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our privacy manager.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

 

10.  Sharing your personal data

We only ever use your personal data if we are satisfied that it is lawful and fair to do so. 

As well as any specific sharing we have mentioned elsewhere in this policy, we may disclose your personal data:

• to external service providers such as our IT and system administration providers;

• to our professional advisers, for example, our accountants, auditors, bankers, insurers and lawyers;

• if we are under a legal duty to disclose or share your personal data, for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime;

• where we need to share your personal data with a regulator, for example, making returns to HMRC or reports to the Charity Commission; or

• as part of a sale, transfer or merger of parts of our organisation or our assets (if a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy policy).

 

11.  Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

12.  Transferring personal data outside the UK

We use some cloud-based servers to store data, and this involves transfer of data outside the UK.  Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at that the country has been deemed to provide an adequate level of protection for personal data and/or we use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific safeguards used by us when transferring your personal data out of the UK.

 

13.  Data retention

We will only keep 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 a legal claim connected 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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

 

14.  Your rights

You have the right to:

• Request access to your personal data (commonly known as a 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.

• Ask us to correct personal data that we hold about you which is incorrect, incomplete or inaccurate.

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In certain circumstances, you also have the right to:

• Ask us to erase your personal data from our files and systems where there is no good reason for us continuing to hold it.

• Object to us using your personal data to further our legitimate interests (or those of a third party) or where we are using your personal data for direct marketing purposes.

• Ask us to restrict or suspend the use of your personal data, for example, if you want us to establish its accuracy or our reasons for using it.

• Ask us to transfer your personal data to another person or organisation. 

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You also have rights in relation to automated decision making which has a legal effect or otherwise significantly affects you. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces significant legal effects concerning you.

 

If you have given your consent to us processing your personal data, you have the right to withdraw your consent at any time.

 

To withdraw your consent, please contact our CEO, Jacqui Parris on 0208 755 5776 or at Jacqui.parris@homelinkdaycare.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data and, subject to our retention policy, we will dispose of your data securely.

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If you want to exercise any of these rights, please contact our CEO, Jacqui Parris in writing at Jacqui.parris@homelinkdaycare.co.uk

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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.

 

15.  Queries or Complaints

Our CEO oversees compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact our CEO, Jacqui Parris on 0208 755 5776 or at Jacqui.parris@homelinkdaycare.co.uk

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues - https://ico.org.uk/make-a-complaint/.