Haylie House Residential Care Home is committed to data protection and data privacy. With the General Data Protection Regulation (GDPR) enforceable from 25 May 2018, we have undertaken a GDPR readiness programme to review our entire business, the way we handle data and the way in which we use it to provide our services and manage business operations. The following privacy notice explains what data we collect from you or that you provide to us, how we process it and what we do to keep it safe.
Haylie House Residential Care Home provides residential care for the elderly and is the data controller of your personal information. By personal data we mean data relating to an individual by which they can be identified.
We hold data from the following groups to allow us to undertake our business:
Employees’, permanent and temporary, personal data to meet legal obligations and to perform vital internal functions.
Residents to whom we provide services and care at Haylie House Residential Care Home
Residents’ next of kin and relatives’ data which is shared with us to help us provide care and services
Businesses and contractors we work with to help provide appropriate services
100 club members who support the monthly draw
Trustees of Haylie House Residential Care Home
This notice details the personal data we may retain and process. We are committed to ensuring that information is secure, accurate and relevant. To prevent unauthorised access or disclosure, we have implemented suitable physical, electronic, and managerial procedures to safeguard and secure personal data we hold. Data that is no longer needed is archived for seven years and after that period it is securely destroyed. Financial details are deleted as soon as they are no longer required.
We have issued this notice to describe how we handle personal information that we hold. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. This notice sets out the personal data that we collect and process about you, the purposes of the processing and the rights that you have in connection with it.
If you are in any doubt regarding this notice, please contact the Care Home Manager, 01475 673373, firstname.lastname@example.org
We use CoolCare which is a double encrypted ‘cloud’ based data storage system. This is a secure and confidential data entry and data management system which will ensure consistency in the management of staff, residents, relatives and suppliers’ personal data. It also provides a secure interface to payroll.
Types of personal data we collect
For the purpose of this notice, the term ‘employee’ includes all staff employed at Haylie House Residential Care Home in any capacity both permanent and temporary.
During your employment with us, or when making an application for employment, we may process personal data about you and your dependents, beneficiaries and other individuals whose personal data has been provided to us.
The types of personal information we may process include, but are not limited to:
Identification data – such as your name, gender, photograph, date of birth, staff member IDs
Contact details – such as home and business address, telephone/email addresses, emergency contact details
Employment details – such as job title/position, employment contract, performance and disciplinary records, grievance procedures, sickness/holiday records
Background information – such as academic/professional qualifications, education, CV, criminal records data (for vetting purposes, where permissible and in accordance with applicable law)
Spouse & dependents information, marital status
Financial information – such as banking details, tax information, withholdings, salary, benefits e.g. clothing allowance
References relating to previous roles and employment conduct may be undertaken prior to commencement of employment. We will only gather references from referees provided to us by the employee, or prospective employee
Sensitive personal data (‘special categories of personal data’ under the General Data Protection Regulation) includes any information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, genetic data, biometric data for the purposes of unique identification, trade union membership, or information about your health/sex life. Generally, we try not to collect or process any sensitive personal information about you, unless authorised by law or where necessary to comply with applicable laws. In some circumstances, we may need to collect some sensitive personal information for legitimate employment-related purposes: for example:
Data relating to your racial/ethnic origin, gender and disabilities for the purposes of:
a) equal opportunities monitoring;
b) to comply with anti-discrimination laws; and
c) for government reporting obligations;
Data relating to your physical or mental health to:
a) provide work-related accommodations,
b) health and insurance benefits to you and your dependents; or
c) to manage absences from work.
If you are a temporary employee, contract worker or consultant, the type of personal information we process is limited to that needed to manage your specific work assignment
Purposes for processing personal data
If you are applying for a role with us you will be asked to give your consent in writing for us to hold personal data about you in order that we can process your employment application. The personal data we collect and use for recruitment purposes is to determine your suitability for a specific role. This includes assessing your skills, qualifications and verifying your information, carrying out reference and background checks including Protecting Vulnerable Groups(PVG) with Disclosure Scotland and to generally manage the hiring process and communicate with you about it.
If you are accepted for a role with us, the data collected during the recruitment process will form part of your ongoing employee record. At this point you will be asked to complete a further consent form.
We collect and process personal data relating to our employees to meet our obligations under the employment contract and to comply with our legal obligations. We take the security of your data seriously and are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.
Once you become an employee, we collect and use this personal information for managing our employment or working relationship with you – for example, your employment records and contract information (so we can manage our employment relationship with you), your bank account and salary details (so we can pay you), your equity grants (for benefits plan administration) and details of your spouse and dependents (for emergency contact and benefits purposes).
Where we process special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring. Data that we use for these purposes is anonymised or is only collected with the express consent of employees, which can be withdrawn at any time.
We have policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed without authorisation and only accessed or used for specific legal purposes.
You have some obligations under your employment contract to provide the organisation with data. You may also have to provide the organisation with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide this data may mean that you are unable to exercise your statutory rights.
The types of personal information we may process for the purpose of employees creating a ‘care plan’ for each resident include, but are not limited to:
Name, date of birth and contact details
Name of next of kin
Name of social worker
Relevant health issues
Pre-assessment of care and health needs
Social worker booking form
All of the above plus religion
Signed contract between Haylie House and resident/power of attorney
Power of Attorney details
Next of kin details
Details of dentists and other health services such as podiatrist
Financial information for the bases of Fee Notes – Local Authority, Private, Fully Private Care
Copy of living will
Copy of burial/cremation plan and name of preferred undertaker
DNR wishes(signed certificate)
Adults with incapacity certificate (if applicable)
Note of medical history and medications
Assessments including mental health, moving and handling, falls and risk assessments
Signed consent for sharing information and photographs, including with multi-disciplinary teams
Each resident’s TV licence details
Post residency we retain all documentation for a period of seven years when it is confidentially shredded.
Relatives and next of kin
The types of personal information we may process to ensure that we work closely with families for the care and well being of their relatives include, but are not limited to:
Power of Attorney details
Businesses and Contractors
The types of personal information we may process to maintain robust business and accountancy records include, but are not limited to:
Lists of transactions
Certificates of contract
100 Club members
The types of personal information we may process to run and manage the 100 club include, but are not limited to:
Contact details including name, address, telephone number and email address
Date of joining
Trustees of Haylie House Residential Home
Contact details including name, address, telephone number and email address
The types of personal information we hold in the visitors’ book and which we may process for health and safety purposes include, but are not limited to:
Date and time in/time out of visit
Purpose of visit
Legitimate business purposes
We may also collect and use personal information when it is necessary for other legitimate purposes, such as to help us conduct our business more effectively and efficiently – for example, for general IT security management, accounting purposes or financial planning. We may also process your personal information to investigate violations of law or breaches of our own internal policies.
We may also use your personal data where we consider it necessary for complying with laws and regulations, including collecting and disclosing employee personal information as required by law (e.g. for tax, health and safety, anti-discrimination laws), under judicial authorisation, or to exercise or defend our legal rights.
Legal basis for processing personal data
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the way we collect it. We will normally collect personal data from you only where we need it to perform a contract with you e.g. to manage the employer/employee relationship or where we have entered a care agreement with you or the local Council and where we have your freely given consent to do so, or where the processing is in our legitimate interests and only where this interest is not overridden by your own interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Any processing based on consent will be made clear to you at the time of collection or use. Consent can be withdrawn at any time by contacting the Care Home Manager, 01475 673373 email@example.com
Who we share your personal data with
We take care to allow access to personal data only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the data is used in a manner consistent with this notice and that the security and confidentiality of the data is maintained.
Transfers to third-party service providers
In addition, we make certain personal data available to third parties who provide services to us. We do so on a "need to know basis" and in accordance with applicable data protection and data privacy laws. This may include Citation, Care Inspectors, Social Work and Scottish Social Services Council (SSSC).
For example, some personal data will be available to service providers and third-party companies who provide us with employment law advice and health and safety support.
Transfers to other third parties
With your freely given and explicit consent we may also disclose personal data to third parties on other lawful grounds including:
To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process
In response to lawful requests by public authorities (including for national security or law enforcement purposes)
As necessary to establish, exercise or defend against potential, threatened or actual litigation
Where necessary to protect the vital interests of our employees
Personal data will be stored in accordance with applicable laws and kept for as long as needed to carry out the purposes described in this notice or as otherwise required by law. Generally, this means your personal information will be retained until the end or your employment, employment application, or work relationship with us plus a reasonable period of time thereafter to respond to employment or work-related inquiries or to deal with any legal matters (e.g. judicial or disciplinary actions), document the proper termination of your employment or work relationship (e.g. to tax authorities), or to provide you with ongoing pensions or other benefits.
For more information, please see our Data Management Policy which will shortly be organised, and which will outline our current document retention schedule.
You may exercise the rights available to you under data protection law as follows:
The right to be informed
The right of access
The right to rectification
The right to erasure of information but excluding disciplinary information
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. You can read more about these rights at:
To exercise any of these rights, please contact the Care Home Manager, 01475 673373, firstname.lastname@example.org
Issues and complaints
We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This notice was written with clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed.
If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office in their capacity as the statutory body which oversees data protection law – www.ico.org.uk/concerns.
Updates to this notice
This notice may be updated periodically to reflect any necessary changes in our privacy practices or/and to comply with the law. In such cases, we will inform you by letter. We encourage you to check this notice periodically to be aware of the most recent version. This version June 2018.
Please address any questions or requests relating to this notice to the Care Home Manager, 01475 673373, email@example.com.
Annex A – Third-party processors
Key third-party processors
The following is our key third-party processor who may, during your employment, be provided with your personal data.
We seek HR and employment law advice from Citation.
We outsource our Health and Safety management to Citation, who may hold records on the following:
Incidents involving our employees
Risk assessments relating to our employees