FamilyCarersNet Limited (“We“, “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. This includes any personal data we collect from our websites including www.familycarersnet.co.uk, www.youngcarersnet.co.uk and www.suffolkcarersmatter.org.uk, (“Websites”, or individually “Website”), or our The Pod mobile App (“App”), and any other communications we have with you. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (collectively the “Data Protection Laws”) the Data Controller is FamilyCarersNet Limited.
If you are providing personal information about any other person (and in particular are referring a carer to us), you confirm that he/she consents to our use of his/her personal data, and that you have notified him/her of this Policy.
YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all of the following types of information from you in the course of your use of our App, the Websites and providing our services:
- Information that you provide by filling in contact forms on the Website or filling in forms as part of the registration process. This includes information provided at the time of registering to use the Website, the App, subscribing to our service, or requesting further information or services. We may also ask you for information when you directly telephone us or report a problem with the Website.
- Information that you provide to us (or to our third party service providers who are engaged by us to provide you with our services or to assist us with providing you with our services) including any sensitive health-related personal data (“Special Categories”).
- Specifically, personal details such as name, email address, date of birth, photos or any information input by when using the Website or the App, completing our registration and contact forms, communication with other users through the Website (including via the Pod), payment details if you are a Pod Member, posting discussion topics, responses to discussion topics or blogs and articles, reviews and using our services.
- Information provided to us by a third party referring you to receive our services or provided by a carer who is caring for you.
- If you contact Us (via phone, e-mail or other means), We may keep a record of that correspondence.
- We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.
- Details of your visits to the Website and use of the App including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
The provision of your name, email address, username and county is required from you to enable Us to register you as a member to receive our services (including via the App), to provide you with access to the Pod.
We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.
Information We Collect From Other Sources
We operate a referral scheme via the Website where third parties may refer carers to receive our services. We will obtain personal data about the carer including your name, e-mail address, date of birth. If you are a referred carer, we will only contact you directly to confirm your details on the basis that you have given your consent to the third party to be referred to us.
We are also a member of certain information sharing partnerships consisting of local authorities, charities and health/well-being organisations who may refer your personal details to us (“Information Sharing Partnership”). Such Information Sharing Partnerships involve us entering into referral scheme agreements which set out procedures and obligations in respect of securely collecting and referring your personal data between parties.
Please contact us if you would like more information about how your data is processed under these Information Sharing Partnerships.
USES MADE OF YOUR INFORMATION
Lawful bases and purposes of processing
We rely on “performance of a contract” as the lawful basis on which We collect and use your personal data in order to provide our services, including notifying you about changes to our service and to carry out our obligations arising from any contracts entered between you and Us.
We rely on “consent” as the lawful basis on which We collect, use and share your personal data in relation to any surveys you participate to. Where you are a carer who has been referred by a third party, we also rely on “consent” as the lawful basis on which we collect and use your personal data to send you materials about our services and prompt you to register with us.
We rely on “legitimate interest” in the following circumstances:
– To ensure that content on the Website and/or the App is presented in the most effective manner for you and for the device(s) you use to access, participate in interactive features and view the Website and/or the App.
– You have previously contacted us via the Website or by calling or e-mailing us, to correspond with you in relation to providing our services.
– To provide you with information and offers that you request from Us or which We feel may interest you.
– Where you are a carer who wishes to receive advice and support through our professional third parties, to share your personal information with such professional third parties.
– to provide you with information or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
– to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you.
– to operate, protect, improve and optimise the Website, our business, and our users’ experience, such as to perform analytics, conduct research, personalise or otherwise customise your experience, and for advertising and marketing.
– to make suggestions and recommendations to you and other users of the Website
– to review, scan, analyse, and store your communications with other members, whether done manually or through automated means.
In respect of any Special Categories of data we collect and process, we also process this in accordance with Article 9(2)(b) and (g) of the GDPR, where processing is necessary for us to carry out our obligations in the field of social protection law and for reasons of substantial public interest on the basis of the Care Act 2014.
In addition to the above uses We may use your information (and, where you have consented, permit selected third parties to use your information), to notify you about goods or services which may be of interest to you. Where We do this, We will contact you by electronic means (e-mail or SMS). If you do not want Us to use your data in this way please either (i) do not tick the relevant box situated on the form on which We collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform Us at any time by contacting Us at the contact details set out below.
DISCLOSURE OF YOUR INFORMATION
The Pod is a social community platform which allows registered users to post materials, commence discussions. All posts, including any personal information contained within your posts will be available to other users.
We routinely disclose your personal data to third parties as follows:
- We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers, distribute the App, and store our data).
- We may pass information related to your use of our Website and/or the App to analytics and search engine providers that assist Us in the improvement and optimisation of the Website and/or the App.
- We may pass your information to third party companies or individuals to assist Us with fraud prevention and risk assessment, to assist us with customer service, and to facilitate the payments and reimbursements you request.
- Where you are a carer who wishes to receive advice and support through our professional third parties or partner organisations, we will share your personal information with such professional third parties and partner organisations.Where you have been identified as a vulnerable adult, we may disclose your personal data to local authorities including schools and the National Health Service in order to comply with our legal obligations and to accomplish a public task under The Care Act 2014.We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may also disclose your personal data to third parties:
- in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
- if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
- if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements; or
- to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with to provide the Website and/or the App; or
- in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you.
Other than as set out above and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We process payment transactions, these will be encrypted using SSL technology. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
Keeping your personal data up to date
If your personal details change you may update them by accessing your account on the Website or on the App, or by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.
Where you contact us, we will endeavour to update your personal data within fourteen(14) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
How long we keep your personal data
We will hold the data set out above for a reasonable time having regard to the nature of the personal data and the purpose for which it was collected. In particular:
- Where we hold your personal data in connection with the performance of a contract in regards to providing our services, We will hold your data so long as the provision of services are in force and for a period of at least 7 years after.
- Where we hold your personal data in connection with the negotiation or performance of a contract with one of our professional third parties or partner organisations, we will hold your data, and in particular any communications between you and us in relation to the negotiation or performance of the contract by either party for so long as that contract is in force and for a period of at least 7 years from the date of our last correspondence with you in relation to the same.
- Where you (i) have submitted an enquiry form via the Website; or (ii) have contacted us by e- mail or by phone to obtain further information about our services, We will hold your personal data for a period of 12 months from the date of our last correspondence with you in relation to the same.
- Where you have been referred to us by a third party who has contacted us or submitted a form on our Website, we will hold your personal data for six months (6) from our last correspondence with you.
Where we store your personal data
All information We hold about you is stored on our supplier’s secure servers within the EEA.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data and to certain other supplementary information that this Policy is already designed to address
- require Us to correct any mistakes in your information which We hold
- require the erasure of personal data concerning you in certain situations
- receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal data concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal data
- otherwise restrict our processing of your personal data in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to Us
- let Us have enough information to identify you (e.g., user name, registration details),
- let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let Us know the information to which your request relates
HOW TO COMPLAIN
We hope that We can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We may collect information about your mobile phone, computer or other device from which you access the Website and/or the App including where available your IP address, operating system and browser type, for systems administration, data security and App functionality and to report aggregate information to third party affiliates. This is statistical data about our users’ App use and browsing actions and patterns and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.
A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
The cookies We use include:
- “Analytical” cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps Us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
- “Strictly necessary” cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
- “Functionality” cookies. These are used to recognise you when you return to our Website. This enables Us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- “Targeting” cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed to our affiliates’ websites. We will use this information to make our Website, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to firstname.lastname@example.org or write to Us at FamilyCarersNet Limited, Acorn House, 8a Looms Lane, Bury St Edmunds, Suffolk. IP33 1HE.