Castel Froma Neuro Care is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us.

Castel Froma Neuro Care is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to current and former employees, workers, volunteers, apprentices and contractors. It does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

It is important that you read this notice and any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. You are also required to read and comply with our privacy notices applicable to resident visitors, family members, friends, volunteers and all other individuals who conduct business on Castel Froma Neuro Care premises.

Data Protection Principles

We will comply with the data protection principles when gathering and using personal information, as set out in the data protection policy in the staff handbook.

The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection.

We will collect, store, and use the following categories of personal information about you:

  • Personal contact details such as your name, title, addresses, telephone numbers, and personal email addresses;
  • Date of birth;
  • Gender;
  • Marital status and dependants;
  • Next of kin and emergency contact information;
  • National Insurance number;
  • Employment contract information;
  • Bank account details, payroll records and tax status information;
  • Salary, annual leave, pension and benefits information;
  • Start date;
  • Location of employment or workplace;
  • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process);
  • Employment records (including job titles, work history, working hours, training records and professional memberships);
  • Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information;
  • Performance information;
  • Disciplinary and grievance information;
  • Details of your time and attendance records;
  • Information in applications you may make for other positions within the business;
  • Information about your use of our information and communications systems;
  • Your use of public social media (only in very limited circumstances, to check specific risks for specific functions within our organisation; you will be notified separately if this is to occur);
  • Details in references about you we give to others;
  • Compensation history;
  • Copy of driving licence;
  • CCTV footage and other information obtained through electronic means; and

We may also collect, store and use the following “special categories” of more sensitive personal information:

  • Information about your health, including any medical condition, health and sickness records;
  • Information about criminal convictions and offences, including the results of Disclosure and Barring Service (DBS) checks;
  • Information about your race or ethnicity, religious or similar beliefs and sexual orientation; and
  • Genetic information and biometric data.

How is your personal information collected?

We collect personal information about employees, workers, volunteers, apprentices and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies, the Home Office, pension administrators, other employees, the DBS or other background check agencies.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us, for example through:

  • Internal systems such as door entry systems, time management systems and time clock records;
  • IT systems such as keystrokes and mouse movements, screen capture and application logs; and
  • Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, remote access systems, email, intranet and Internet facilities, telephones, voicemail, mobile phone records, data loss prevention tools, next-generation firewalls, unified threat management systems, eDiscovery technology and mobile device management systems.

How we will use the information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  1. Where we need to perform the contract we have entered into with you, or to take steps to enter into a contract.
  2. Where we need to comply with a legal obligation (e.g. our obligations to you as your employer under employment protection and health safety legislation or to comply with statutory guidance and codes of practice).
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).
  2. Where it is needed in the public interest.

Situations in which we will use your personal information

We need all the categories of information in the list above (see “The kind of information we hold about you”) primarily to allow us to perform our contract with you* and to enable us to comply with legal obligations**. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties***, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. We have indicated by asterisks the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.

  • Making a decision about your recruitment or appointment (***).
  • Determining the terms on which you work for us (** and ***).
  • Checking you are legally entitled to work in the UK (**).
  • Paying you and, if you are an employee, deducting tax and National Insurance contributions (* and **).
  • Providing the following benefits to you: Private Health Plan with Simply Health (* and **).
  • Liaising with your pension provider (* and **).
  • Administering the contract we have entered into with you (* and **).
  • Business management and planning, including accounting and auditing (** and ***).
  • Conducting performance reviews, managing performance and determining performance requirements (***).
  • Making decisions about salary reviews and compensation (* and ***).
  • Assessing qualifications for a particular job or task, including decisions about promotions (***).
  • Gathering evidence for possible grievance or disciplinary hearings (** and ***).
  • Making decisions about your continued employment or engagement (** and ***).
  • Making arrangements for the termination of our working relationship (* and **).
  • Education, training and development requirements (***).
  • Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work (** and ***).
  • Ascertaining your fitness to work (** and ***).
  • Managing sickness absence (** and ***).
  • Complying with health and safety obligations (** and ***).
  • To prevent fraud (** and ***).
  • To monitor your use of our information and communication systems to ensure compliance with our communication policies (***).
  • To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution (***).
  • Equal opportunities monitoring (**).
  • To conduct data analytics studies to review and better understand employee retention and attrition rates (***).

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose

We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

  1. In limited circumstances, with your explicit written consent.
  2. Where we need to carry out our legal obligations and in line with our data protection policy.
  3. Where it is needed in the public interest, such as for equal opportunities monitoring, and in line with our data protection policy.
  4. Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Our obligations as an employer

We will use your particularly sensitive personal information in the following ways:

  • We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We envisage that we will hold information about criminal convictions.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences in the following ways:

  • In order to assess suitability for employment.
  • In order to comply with safeguarding obligations.
  • As required by law.

We are allowed to use your personal information in this way in order to comply with legal obligations and/or to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.

Automated Decision Making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

  1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
  2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
  3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

Data Sharing

We may have to share your data with third parties, including third-party service providers.

We require third parties to respect the security of your data and to treat it in accordance with the law.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

”Third parties” includes third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers: pension administration, benefits provision and administration (Simply Health), IT services (Network Limited), Occupational Health, HR software, training providers and other relevant government agencies. 

How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of a restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Data Security

We have put in place measures to protect the security of your information. Details of these measures are available on request from the HR Manager.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. 

Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our data retention policy which is available from the HR Manager.

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 requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of Castel Froma we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

Rights of access, corrections, erasure and restriction

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the HR Manager in writing.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the HR Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Point of contact

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO, Colette Ryan, as follows: Colette.ryan@castelfroma.org.uk or 01926 427216.

You 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.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact Colette Ryan, HR Manager by email to Colette.ryan@castelfroma.org.uk or by telephone on 01926 427216.

Castel Froma Neuro Care is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your placement with us.

Castel Froma Neuro Care is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to residents, prospective residents and guests. It does not form part of any contract of to provide services. We may update this notice at any time.

It is important that you read this notice and any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data Protection Principles

We will comply with the data protection principles when gathering and using personal information, as set out in the data protection policy.

The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection.

We will collect, store, and use the following categories of personal information about you:

  • Personal contact details such as your name, title, addresses, telephone numbers, and personal email addresses;
  • Date of birth;
  • Gender;
  • Marital status and dependants;
  • Next of kin and emergency contact information;
  • NHS number;
  • Placement date;
  • Location of placement;
  • Your nationality;
  • Social history and personal preferences;
  • Details relating to the methods through which your care is being funded;
  • Your capacity to make decisions and/or whether we need to liaise with person(s) you have entrusted with power of attorney; and

We may also collect, store and use the following “special categories” of more sensitive personal information:

  • Information about your health, including any medical condition and health records;
  • Information about any medication you require in order to administer this and document any special medical care required;
  • Information about your race or ethnicity, religious or similar beliefs and sexual orientation; and
  • Genetic information.

How is your personal information collected?

We collect personal information about residents, prospective residents and guests through an assessment process, either directly from residents or sometimes from a next of kin. We may sometimes collect additional information from third parties including funding bodies or other medical professionals.

We will collect additional personal information in the course of your placement, for example through:

  • Updates on medical condition/diagnoses and treatment.

How we will use the information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  1. Where we need to perform the contract we have entered into with you, or to take steps to enter into a contract.
  2. Where we need to comply with a legal obligation (e.g. our obligations to you under health and safety legislation, to comply with statutory guidance and codes of practice or where we are legally obligated to as part of our industry compliance requirements).
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).
  2. Where it is needed in the public interest.

Situations in which we will use your personal information

We need all the categories of information in the list above (see “The kind of information we hold about you”) to allow us to perform our contract with you* and to enable us to comply with legal obligations**. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties***, provided your interests and fundamental rights do not override those interests. We may also process personal data in the vital interests of the data subject ****. The situations in which we will process your personal information are listed below. We have indicated by asterisks the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.

  • Making a decision about your placement (*** and ****).
  • Administering the contract we have entered into with you (* and **).
  • Providing nursing care (* and ****).
  • Providing funding bodies with information about the services we are providing to you (** and ****).
  • Where your condition may represent a threat to the interests, rights and freedoms of other people e.g. if you have a communicable disease and we believe your condition may represent a risk to other residents (****).
  • To comply with the Health & Social Care Act and the CQC standards (**).
  • Where we are required to be able to demonstrate skills and competencies of our staff to comply with legal requirements (**).
  • Carrying out clinical assessments during your placement (****).
  • Administering medication (****).
  • Providing information to third parties when it is in the vital interest of the data subject, e.g. medical professionals and GPs (****).
  • Dealing with legal disputes (** and ***).
  • Complying with health and safety obligations (** and ***).
  • To prevent fraud (** and ***).
  • Using imagery for social media, website or other marketing material (consent).

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.

Change of purpose

We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

  1. In limited circumstances, with your explicit written consent.
  2. Where we need to carry out our legal obligations and in line with our data protection policy.
  3. Where it is needed in the public interest, such as for equal opportunities monitoring, and in line with our data protection policy.

We may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Automated Decision Making

There are no automated decision making being made using your personal data.

Data Sharing

We may have to share your data with third parties, including third-party service providers.

We require third parties to respect the security of your data and to treat it in accordance with the law. 

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer our relationship with you or where we have another legitimate interest in doing so.

We use consistent third-parties who act as data processors on our behalf to provide specific services.  We may share your data with them to enable us to undertake the activities as set out above. They may also introduce you to us or us to you e.g. social services, patient care teams within hospitals.

Which third-party service providers process my personal information?

”Third parties” includes third-party service providers (including contractors and designated agents).

 

  • Medical professionals e.g. ambulance service, GP hospital, mental health team;
  • Care services e.g. social services and mental health services;
  • Funding services;
  • Police (for matters involving the law); and
  • Government agencies (HMRC, CQC).

Theses providers are set out below:

Organisation Activity undertaken Personal data shared
Funding assessors e.g. CCG Processing payments relating to funding Your details and details of your care requirements
Pharmacy services Obtaining medication Your details, health and prescription requirements
GP, Health care professional, Dentists Ad-hoc medical requirements Your details and details of medical condition
Social services / mental health team / other NHS bodies Health (before, during or after your care) Your details, details of your care requirements, concerns or issues with regards to your safety i.e. safeguarding
Emergency services Protection of life or the wellbeing of others e.g. medical emergency Limited information relative to the situation. Information relating to an individual care needs e.g. medication, diagnoses etc.

How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. 

What about other third parties?

We may also need to share your personal information with a regulator or to otherwise comply with the law.

Data Security

We have put in place measures to protect the security of your information. Details of these measures are available on request from the Data Protection Officer.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our data retention policy which is available from the Data Protection Officer.

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 requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a resident, Castel Froma Neuro Care we will retain and securely destroy your personal information in accordance with applicable laws and regulations. 

Rights of access, corrections, erasure and restriction

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your placement with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Be informed about the collection and use of your personal data.
  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the data portability of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer in writing.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Point of contact

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO, Colette Ryan, as follows: Colette.ryan@castelfroma.org.uk or 01926 427216.

You 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.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact Colette Ryan, HR Manager by email to Colette.ryan@castelfroma.org.uk or by telephone on 01926 427216.

At Castel Froma Neuro Care, we are committed to protecting and respecting your privacy.

The data controller is Castel Froma Neuro Care of Lillington House, 93 Lillington Road, Leamington Spa, CV32 6LL. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

If you have any queries about this policy, please contact the Data Protection Officer, at Castel Froma Neuro Care on 01926 427 216 or email info@castelfroma.org.uk.

General Data Protection Regulation (GDPR)

Under the GDPR, we have a legal duty to protect any information we collect from you. We use leading technologies and encryption software to safeguard your data and keep strict security standards to prevent any unauthorised access to it.

Information we may collect from you

We collect the following information when you make a donation, submit an online form or otherwise give us personal information:

  • Information that you provide by filling in forms on this website www.castelfroma.org.uk this includes information provided at the time of registering to use this website, subscribing to our mailing list, requesting material or further services. We may also ask you for information when you report a problem with our website;
  • If you contact us, 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 transactions you carry out through this website and of the fulfilment of your orders; and details of your visits to this website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

Where we store your personal data

Castel Froma Neuro Care is committed to ensuring the security of your information. We have strict physical, electronic and managerial procedures in place to secure and store your personal information.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted.

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 this 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.

We use information held about you in the following ways:

  • To give you the information you have requested;
  • To inform you about our fundraising activities;
  • To ensure that content from this website is presented in the most effective manner for you and for your computer;
  • To provide you with information, products 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 carry out our obligations arising from any contracts entered into between you and us;
  • To allow you to participate in interactive features of our service, when you choose to do so; and
  • To notify you about changes to our service.

Disclosure of your information

Your personal information is not shared with third parties.

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 terms and conditions, other agreements or to protect the rights, property, or safety of Castel Froma Neuro Care, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Your rights

You have the right to know what information is being held about you. You can ask us what information we hold by contacting the Data Protection Officer at Castel Froma Neuro Care.

You have the right to ask us not to process your personal data. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at the above address.

Please keep your information up to date by letting us know at the above address if the information we hold is incomplete or incorrect.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page, please check back periodically.

Cookies

Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer. By using this website, you agree we can set and use cookies. These cookies allow us to distinguish you from other users of our website.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Data Protection Officer, at Castel Froma Neuro Care, Lillington House, 93 Lillington Road, Leamington Spa, CV32 6LL or by emailing info@castelfroma.org.uk.

About cookies

  1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
  2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
  3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

  1. We use cookies for the following purposes:
    1. status – we use cookies to help us to determine if you are logged into our website (cookies used for this purpose are: wordpress_logged_in*, wp-settings-{time}-[UID], PHPSESSID);
    2. personalisation – we use cookies to store information about your preferences and to personalise our website for you (cookies used for this purpose are: charitable_session); and
    3. analysis – we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: _ga, _gat, _gid, p.gif, collect, r/collect).

Cookies used by our service providers

  1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
  2. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
  3. We use Stripe to act as a payment provider for online donations. This service uses cookies for operating their service. You can view the privacy policy of this service provider at https://stripe.com/cookies-policy/legal.

Managing cookies

  1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
    1. Chrome;
    2. Firefox;
    3. Opera;
    4. Internet Explorer;
    5. Safari; and
    6. Edge.
  2. Blocking all cookies will have a negative impact upon the usability of many websites.
  3. If you block cookies, you will not be able to use all the features on our website.

Cookie preferences

  1. You can manage your preferences relating to the use of cookies on our website by clicking the preferences button in the left-hand corner of our website.

Our details

  1. This website is owned and operated by Castel Froma Neuro Care.
  2. We are registered in England and Wales.Registered Charity Number: 1100965, Company Number: 04777559, CQC Registration Number: 5928
  3. Our principal place of business is at Bericote Lane, Blackdown, Royal Leamington Spa, Warwickshire, CV32 6QP.

You can contact us:

  1. by post, to the postal address given above;
  2. using our website contact form;
  3. by telephone, on the contact number published on our website; or
  4. by email, using the email address published on our website.