APP PRIVACY POLICY
Introduction
Care Vision CMS (UK) Ltd (“Care Vision”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.
This privacy policy aims to give you information on how Care Vision collects and processes your personal data through your use of Care Vision’s cloud-based content management software called ‘Care Vision’ (“App”), as well the services accessible through the App (“Services”). The App is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this policy so that you are fully aware of how and why we are using your data. This policy supplements any other notices and privacy policies and is not intended to override them.
1IMPORTANT INFORMATION AND WHO WE ARE
Who we are
When we process your personal data as a controller, Care Vision CMS (UK) Ltd is the controller and is responsible for your personal data.
How to contact us
Our data privacy manager is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
- Email: rishi@care-vision.co.uk
- Post: Privacy Manager, Melbury House, 34 Southborough Road, Bromley, Kent, United Kingdom, BR1 2EB
Changes to the privacy policy
We keep our privacy policy under regular review and reserve the right to make changes or update this policy at any time. This version was last updated on 12 June 2019.
Your duty to inform us of changes
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.
Third-party links
Our website www.carevisioncms.co.uk and our App 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. We encourage you to read the privacy policy of every website you visit.
2DOES THIS PRIVACY POLICY APPLY TO YOU?
As a supplier of a cloud-based content management system and related services for the care sector, we deal
predominantly with organisations that provide social care, and their staff. Our dealings are strictly in the
course of us
providing (and them using) the App and the Services. If you fall within the foregoing description and we process
your personal data, then this privacy policy will apply to you.
We recognise that our App and Services will be used by social care organisations in their provision of care
services and in running their businesses generally. This will involve processing personal data of the
organisations’ residents and service users, as well as its care staff. Further information is provided below in
section 11 (Residents, Service Users and Care Staff).
3THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about the care staff individuals that work at the social care organizations using the App, and we have grouped these kinds of data as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
- Technical Data includes device ID & MAC address, operating system and platform, and other technology on the devices used to access this website or App.
- Profile Data includes usernames and passwords, interests and preferences, feedback and survey responses.
We also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data 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 App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes 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). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
4HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your Identity and Contact when using our App and our Services.
5HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party, e.g. a social care organization) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and
which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where
appropriate.
Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data. Please contact us if you need details about the specific
legal ground we are relying on to process your personal data where more than one ground has been set out in the
table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To install the App, register you as a new client and set up user accounts | (a) Identity (b) Contact |
Performance of a contract with you |
| To provide our Services | (a) Identity (b) Contact |
(a) Performance of a contract with you
(b) Necessary for the legitimate interests of |
| To manage our relationship with you which will include: (a) Notifying you of changes to the App or any Services (b) Notifying you about changes to our terms or privacy policy (c) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing Communications and |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our Services) |
| To administer and protect our business, our website and our App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT
services, network security, to prevent fraud and in the context of a business reorganisation or group
restructuring exercise) (b) Necessary to comply with a legal obligation |
| To use data analytics to improve our website, our App, our Services, marketing, client relationships and experiences | (a) Technical (b) Profile (c) Usage |
Necessary for our legitimate interests (to define types of clients for our Services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and
advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may
want or need, or what may be of interest to you. This is how we decide which products, services and offers may
be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or purchased Services
from us, in which case we may contact you based on our legitimate interests. You will be given an opportunity to
opt out of our marketing when we make contact.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any
time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as
a result of a product/service purchase or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the website or App may become inaccessible or not function properly. For more information about the cookies we use, please refer to our cookie policy.
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 us.
6DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table in section 5 above.
- Service providers acting as processors based in the EU who provide IT and system administration services. Amazon Web Services is used to provide the cloud-based hosting infrastructure that the App and the Services run on.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area.
8DATA 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.
9DATA RETENTION
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.
10YOUR LEGAL RIGHTS
You always 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 (www.ico.org.uk). We would, however, appreciate the chance
to deal with your concerns before you approach the ICO so please contact us in the first instance.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
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.
11RESIDENTS, SERVICE USERS AND CARE STAFF
In providing the App and the Services to social care organisations, we may process personal data of their
residents and service users, as well as their care staff (in addition to the information already described
above). Where Care Vision processes such personal data, it does so as a data processor on behalf of the care
provider, who will be the controller and whose privacy policy will apply to such processing.
The types of personal data and information that may be processed will depend on the features of the App and the
Services used by the social care organisation but could include:
- in the case of residents and service users, Special Categories of Personal Data such as health information and other sensitive information;
- in the case of care staff, employment and personnel information, criminal conviction information and Special Categories of Personal Data such as race or ethnicity.
