We are publishing this update to our existing privacy notice on a temporary basis in relation to the unprecedented challenges we face because of the Coronavirus pandemic (COVID-19).
This privacy notice is to explain and provide you with information on how we collect and hold data about you.
Inter-County Nursing & Care Services Ltd is committed to protecting your personal information. As a data controller we have a responsibility to make sure you know why and how your personal information is being collected. This is in accordance with relevant data protection law. You can view Inter-County’s ‘Privacy Notice for Clients’ on our website (www.inter-county.co.uk) which has more information about how we collect, use and protect personal data generally, as well as your rights as a data subject.
It is necessary for us to collect data about you in order to best respond and help coordinate the service in response to COVID-19.
Whilst we may already hold data about you, you may have provided this information for a specific reason and normally we would seek to inform you that the data provided would be used for a different reason. Due to the rapidly emerging situation regarding the current pandemic, this will not always be possible. Additionally, at this time we may ask you for more information, where it is necessary to ensure your safety and well-being. We will, however, ensure that this is limited to what is proportionate and necessary to manage the spread of the virus and safeguard those most vulnerable. The use of this information is subject to national guidance issued by the Department for Health and Social Care and Local Government.
Information about clients’ COVID-19 (coronavirus) status may be shared with NHS and other partners involved in their care and treatment, along with:
The provision of your medical, physical or mental condition is necessary to enable us to create a care plan and to provide you with suitable care and support services. Without this information, we will not be able to assess your care needs or provide any care services to you.
The provision of your name, home address is required so that we can arrange a care worker to attend your home to deliver the services and so that we can invoice you for the fees. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
We regularly share your medical information with appropriate external social or health care professionals (including your GP and pharmacist) and any individuals you have nominated as your representative. This data sharing enables us to establish the type of care and support you need. It also allows us to design the right care package to suit your individual circumstances, including if (in future) you decide to receive care from an alternative provider.
We will share personal information with law enforcement or other authorities if required by law. This includes information required by public bodies to evidence our compliance with the applicable regulatory framework. We are also required to share personal information with external social or health care professionals, including public bodies and local safeguarding groups (in some circumstances) to ensure your safety.
We use a limited number of external organisations to support the administration of the service, including duty rosters, care planning and IT services. These companies are based within the UK and all services are provided under specific contractual terms, which are compliant with UK data protection legislation.
We will not share, sell or trade your personal information with any other third party. We will ask your permission to use personal data on any social media or marketing platforms and will obtain your written consent before doing so.
The lawful basis upon which we collect and use your personal data and special category data is:
GDPR Article 6(1)(c): processing is necessary for us to demonstrate compliance with our regulatory framework and the law
GDPR Article 6(1)(b): processing is necessary for the performance of our contracts to provide individuals with care and support services
GDPR Article 9(2)(h): processing is necessary for the provision of social care of the management of social care systems and services
We will only keep your information for as long as it necessary. We will consider Government guidance and the on-going risk presented by Coronavirus for our response to this emergency.
As a minimum the information outlined in this privacy notice will be kept for the duration of the COVID-19 response. However, in most cases, data will be kept for longer to meet evidential requirements under British statute and common law.
If possible, we will anonymise your personal data so that you cannot be identified. This cannot be done where data is needed to provide direct services to individuals. When the information is no longer needed for this purpose it will be either deleted or anonymised for statistical purposes.
The Information Commissioner’s Office has published its own FAQ’s on data handling during the pandemic: https://ico.org.uk/for-organisations/data-protection-and-coronavirus/
If you have any questions about the collection or use of your personal data, please
email us at email@example.com, call us on 01908 379148 or write to the Company’s Data Protection Officer at:
Inter-County Nursing & Care Services
The Old Court House
20 Simpson Road
You can find details of our registration with the Information Commissioner online here: www.ico.org.uk/esdwebpages/search.
Our ICO registration number is Z6318171
We aim to resolve all complaints about how we handle personal information. However, you also have the right to lodge a complaint about data protection matters with the Information Commissioner’s Office.
Contact them by post at:
Information Commissioner’s Office
You can also phone 0303 1231 113.
You can make a complaint or find out more information on the Commissioner’s Office website: https://ico.org.uk/make-a-complaint/.