Privacy Policy
Privacy Statement – Vivant Care Online, Telephone and Face-to-Face Enquiries
1. Purpose of our privacy statement
1.1 Under the Data Protection Act 2018 and the General Data Protection Regulation, we are required to explain to you why we are asking for this information about you, how we intend to use the information you provide and whether we will share this with anyone else.
2. Who are we?
2.1 We are Vivant Care, a trading name of Sanctuary Care and a part of Sanctuary Group (‘Sanctuary’) one of the UK's leading providers of housing, care and commercial services. Our address is Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ.
3. Our Data Protection Officer
3.1 Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
3.2 If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing data.protection@sanctuary.co.uk.
4. Why are we collecting your information?
4.1 The information that you provide to us via webforms or live chat online, telephone or face-to-face enquiry is completely voluntary and will be used to best understand how our care homes may best support you or your loved one.
5. What information are we collecting?
5.1 The only information which we are collecting about you is the information which you provide to us via our online webform or live chat, telephone or face to face. This information may be used by us to send you further marketing information via any of the following methods:
- Press releases
- E-newsletters or e-bulletins
- Printed materials e.g. newsletters, leaflets, brochures, posters, displays etc.
- Website content
- Videos e.g. YouTube
- Social media content e.g. Facebook, Twitter, LinkedIn etc.
- Advertising
5.2 Some of the information which we collect will include personal data. We may also collect special categories of personal data (also called sensitive personal data), which may include information about: your health; political opinions; religious or philosophical beliefs; trade union membership; genetic/biometric data; sex life or sexual orientation and racial or ethnic origin, if you are happy for us to do so.
6. What we are going to do with your information
6.1 The information you provide to us will be used for the following purposes:
6.1.1 It will be stored and used by us in accordance with this privacy statement and also in accordance with your rights under the Data Protection Act 2018 and the General Data Protection Regulation;
6.1.2 It will be collected and used by us fairly and openly for the purpose of sharing more information about our care homes and services we provide and
6.1.3 It may be used to improve the services you receive from us.
6.2 Some of the information which we collect may be special categories of personal data (also called sensitive personal data), such as information about your ethnic background or any disability you may have. By providing us with this information, you consent to our use of this information for this purpose.
7. What is the legal basis for using your information?
7.1 In accordance with the data protection laws, we need a ‘legal basis’ for collecting and using information about you. There are a variety of different legal basis for processing personal data which are set out in the data protection laws.
7.2 The lawful basis on which we rely in order to use the information which we collect about you for the purposes set out in this notice will be:
7.2.1 that you have provided your explicit consent to our use of your information.
7.3 The lawful basis on which we rely in order to use the special categories of personal data which we collect about you will be:
7.3.1 that you have provided your explicit consent to our use of your information.
8. Sharing your information
Members of Sanctuary Group
8.1 Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary in order to best provide the services to you in accordance with the contract between us.
8.2 Your information will only be accessed by other companies in the Group where it is necessary to do. The obligations which are set out in this notice shall apply to the other members of the Group to the same extent that they apply to us.
8.3 For more information on which companies make up Sanctuary Group, please go to www.sanctuary.co.uk/about-sanctuary.
Contractors and sub-contractors
8.4 It may be necessary to share information about you with our contractors and sub-contractors for the purposes you have consented to. The contractors and sub-contractors shall be contractually required to ensure that they adhere to the security requirements imposed by the Data Protection Act 2018 and/or the General Data Protection Regulation (as applicable).
8.5 Our contractors and sub-contractors will not share your information with any other parties and will only be able to use the information when completing work on behalf of us.
Regulators and other legal obligations
8.6 We may also be required to share your information with our regulators who are permitted access to this information by law and with other organisations where we have a legal obligation to share the information with them.
Other organisations
8.7 We may from time to time share your information with other organisations, such as:
8.7.1 the police for the purpose of detection and prevention of crime;
8.7.2 Local authorities, including Safeguarding teams, for the purpose of providing relevant information about you;
8.7.3 The NHS and other healthcare professionals for the purpose of providing relevant information about you;
8.7.4 Organisations with a function of auditing and/or administering public funds etc. for the purpose of detection and prevention of fraud; and
8.7.5 Media organisations, care sector organisations, our regulators and other stakeholder organisations.
Tailored advertising
8.8 Sanctuary uses the Flashtalking platform to create and deliver tailored online advertising, for device recognition and to enable advertising campaign analysis, applying both cookie-based and cookieless technologies to identify and connect devices. Learn more about Flashtalking’s use of data and your choices in their consumer privacy statement at www.flashtalking.com/consumer-privacy.
Live chat
8.9 Sanctuary uses a live chat service provided by SnapEngage to allow our Enquiry Support Team to answer your queries about our care homes and to provide you with relevant marketing materials if you would prefer to chat online with us. Learn more about SnapEngage’s use of your data in their privacy policy: Privacy Policy | SnapEngage
Mediahawk
8.10 We track sources which are effective at helping visitors find out about our website and make calls to us. We use IP addresses, geo-location data, caller telephone number, and voice recordings.
Profiling
8.11 We may lead or ask other organisations to carry out some of our consumer and market analysis to improve our marketing processes. This involves sharing personal information relating to our customers with third parties who specialise in profiling and segmenting people (putting people into groups of different types of customer, based on different kinds of information collected about them, to help us to better target our products to them). These companies match the information we give them with information they get from other sources to improve the accuracy of their analysis. We use the results of this analysis to help us target marketing and offers.
9. Transferring your information abroad
9.1 We use a third party processor, Campaign Monitor, for some of our email campaigns and we transfer your information to Campaign Monitor for the purpose of sending e-marketing and communication emails to you. Campaign Monitor is a global business that is headquartered in Australia and uses a data centre located in the United States of America, so their processing of your personal data will involve a transfer of data outside the EEA.
9.2. Whenever we transfer your personal data out of the EEA in this way, we ensure a similar degree of protection is afforded to it by ensuring that we use specific contract clauses approved by the European Commission which give personal data the same protection it has in Europe. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
10. Security of your information
10.1 The information that you provide will be stored securely on our systems and the form that you complete will be shredded. Our security measures and procedures reflect the seriousness with which we approach security and the value we attach to your information.
10.2 Only relevant members of staff will access the information you provide to us.
11. Can we use your information for any other purpose?
11.1 In limited circumstances, we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.
12. Storing your information and deleting it
12.1 We will store the personal data you provide to us for three years.
13. Your rights
13.1 In relation to the information which we hold about you, you are entitled to:
13.1.1 Ask us for access to the information;
13.1.2 Ask us to rectify the information where it is inaccurate or is incomplete;
13.1.3 Ask us to erase the information and take steps to ask others who we have shared your information with to also erase it;
13.1.4 Ask us to limit what we do with your information;
13.1.5 Object to our use of your information and ask us to stop that use;
13.1.6 Instruct us to provide you with the information we hold about you in a structured and commonly used format or transmit that information directly to another organisation (for example, if you want the information to be sent to another care provider).
13.2 Our obligations to comply with the above rights are subject to certain exemptions.
13.3 Where we are using your information because you have provided your consent to that use, you are entitled to withdraw your consent at any time. The lawfulness of our use of your information before consent was withdrawn is not affected.
13.4 To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing data.protection@sanctuary.co.uk.
13.5 You also have the right to complain to the Information Commissioner's Office (the ‘ICO’) if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.