This policy applies to current and former employees, workers and contractors. This policy does not form part of any contract of employment or other contract to provide services. We may update this policy at any time but if we do so, we will provide you with an updated copy of this policy as soon as reasonably practical.

 

It is important that you read and retain this policy so that you are aware of how and why  we are using that information and what your rights are under the data protection legislation.

 

When The Farthings Nursing Home processes your personal data, we comply with the Data Protection Act 2018 (‘DPA’) and the UK GDPR (the DPA and UK GDPR are together referred to as the ‘Data Protection Legislation’).

 

Your personal data includes all the information we hold that identifies you or is about you, for example, your name, email address, postal address, date of birth, location data, and in some cases, opinions that we document about you, as well as special categories of data including, but not limited to, medical and health records and information about your religious beliefs, ethnic origin and race, sexual orientation and political views. It may also include opinions about you, opinions given by you and any other information from which we learn something about you [Update as necessary to reflect the personal data that is being processed about employees].

 

Everything we do with your personal data counts as processing it – including collecting, storing, amending, transferring and deleting it. We therefore comply with the data protection legislation to make sure that your information is properly protected and used appropriately.

 

This privacy policy provides information about the personal data we process, why we process it and how we process it.

Our Responsibilities

The Farthings Nursing Home is the controller of the personal data you provide. We have appointed Karen Phillips as Manager and they will have day to day responsibility for ensuring that we comply with the data protection legislation and for dealing with any requests we receive from individuals exercising their rights under the data protection legislation. [This can be updated to reference another job title as having responsibility for compliance with data protection legislation where no DPO has been appointed. If possible, avoid referencing a named individual in case that individual ceases to have responsibility or leaves The Farthings Nursing Home].

Why do we process your personal data?

We process your personal data for HR, employment and administrative purposes. We need your personal data to make sure you have all you need to be able to work at The Farthings Nursing Home, to make sure you are safe and secure at work and to make sure you receive all the benefits and rights to which you are entitled.

 

We process your personal data on a number of grounds including, but not limited to, our legitimate interests, our contract with you, our legal obligations and our rights and responsibilities as your employer. More information about the types of data we process and the grounds for processing are set out in the table below.

 

[Update the table below as necessary to ensure that it correctly reflects the different types of personal data being processed about employees. Some types of data may need to be deleted and others may need to be added. The grounds for processing are likely to be correct for most organisations but each should be considered and amended if necessary]:

Type of Data	Grounds for Processing
Identity data such as your first name, middle names, last name, date of birth and gender	Legal obligation
Marital status and title	Legitimate interests
Contact data such as your postal address, email address and telephone numbers	Legitimate interests
Immigration checks	Legal obligation
Financial data including your bank account details, payroll records and tax status information	Legal obligation
National Insurance number	Legal obligation
Next of kin and emergency contact information	Legitimate interests
Information about your dependants	Contractual requirement
Background data such as your education, career background and work experience	Legitimate interests
Personal information such as your skills and qualities	Legitimate interests
Salary, annual leave and pension information	Legal obligation
Benefits information including life assurance and ill health cover	Contractual requirement
Start date and, if different, the date of your continuous employment	Legal obligation
Leaving date	Legal obligation
Your reason for leaving	Legitimate interests
Location of employment or workplace	Legal obligation
Copy of passport	Legal obligation
Employment records including job titles and work history	Legitimate interests

Type of Data	Grounds for Processing
Training records	Legal obligation or legitimate interests, depending on the type of training
Information about working hours and holidays	Legal obligation
Maternity and paternity leave information	Legal obligation
Performance information	Legitimate interests
Disciplinary and grievance information	Legal obligation
Accident records	Legal obligation
CCTV images (more information is set out below)	Legitimate interests
Information about your ethnicity/racial background	Provision of this information is voluntary and therefore collected on the grounds of your consent [If this information is not collected on the grounds of consent (including if the employee is required to provide the information), this will need to be updated to reflect one of the grounds for processing special categories of data. If the processing is collected anonymously, it is not personal data and can therefore be deleted from this table]
Special categories of data to the extent we need such information to make sure you are comfortable and safe at work including information relating to your health and medical conditions	Required for us to meet our obligations and exercise our rights as your employer
Any other information included on any CV, application or covering letter you provided to us	Consent on the basis that the information was provided voluntarily

Where we rely on your consent to process your information you may withdraw your consent at any time. This will not affect the lawfulness of any processing we carried out prior to you withdrawing your consent.

Who will receive your personal data?

We only transfer your personal data to the extent we need to. Recipients of your personal data include:

[insert any potential recipients or categories of recipients such as payroll providers, pension providers, insurers, healthcare providers, hosted data centres, third parties that provide, for example, benefits/perks,]

We do not transfer your personal data outside of the EEA. [If The Farthings Nursing Home transfers personal data outside of the EEA, delete this sentence and include the paragraph below instead].

We may transfer your personal data outside of the EEA to [name of recipient of data outside EEA]. [A finding of adequacy has been made in respect of [relevant country], which means the UK Government is satisfied that any data transferred to [relevant country] will be adequately protected]. [We will transfer your personal data on the basis of safeguards included in a written agreement between The Farthings Nursing Homeand the recipient of your personal data [This paragraph should be included if The Farthings Nursing Home transfers personal data outside the EEA. There are a number of optional clauses within this paragraph. The Farthings Nursing Home will need to consider the location of the recipient and the grounds on which personal data is transferred and update this paragraph accordingly].

How long will we keep your personal data?

We will retain your personal data for [confirm retention period if you have opted for one overarching retention period. If you have multiple retention periods for employees, you may refer to a separate retentions schedule which could be attached to this policy or available on request. There must be valid reasons to retain the personal data for the chosen period of time. Personal data must not be retained ‘just in case’ it is needed in the future. Further guidance about appropriate retention periods for employee and HR personal data is included in the Data Security and Data Retention Policy and Procedure]. Your information will be kept securely at all times. Following the end of the relevant retention period, your files and the personal data covered by the retention period will be permanently deleted or destroyed.

What are your rights?

You benefit from a number of rights in respect of the personal data we hold about you. We have summarised the rights which may be available to you below, depending on the grounds on which we process your data. More information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-

data-protection-regulation-gdpr/individual-rights/). These rights apply for the period in which we process your data. There are certain caveats and exemptions to some of your rights which may mean that, in some circumstances, you may not be entitled to exercise them. If we believe that is the case upon receipt, we will let you know.

1.  Access to your data

You have the right to ask us to confirm that we process your personal data, as well as access to and copies of your personal data. You can also ask us to provide a range of information about the ways in which we process your data, although most of that information corresponds to the information set out in this privacy policy.

 

2.  Rectification of your data 

If you believe personal data that we hold about you is inaccurate or incomplete, you can ask us to rectify that information.

3.  Right to be forgotten

 

In some circumstances, you have the right to ask us to delete personal data we hold about you.

4.  Right to restrict processing

 

In some circumstances, you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we do not have to delete it.

5.  Data portability

 

You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller.

6.  Right to object

You are entitled to object to us processing your personal data:

If the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority

For direct marketing purposes (including profiling); and/or

For the purposes of scientific or historical research and statistics

[You may specify here that you do not intend to use personal data to send direct marketing and/or for scientific or historical research and statistics, if that is the case]

Automated decision making

 

Automated decision making means making a decision solely by automated means without any human involvement.

 

[Automated decision making includes, for example, an online credit reference check that makes a decision based on information inputted without any human involvement. It would also include the use of an automated clocking-in system that automatically issues a warning if a person is late a certain number of times (without any input from HR, for example). Choose between the following two clauses for the privacy policy:]

 

We do not carry out any automated decision making using your personal data. [If The Farthings Nursing Home carries out automated decision making, delete this sentence and complete the section below].

 

We carry out the following types of automated decision making using your personal data: [If The Farthings Nursing Home does not carry out automated decision making, delete this sentence and include the sentence above. If it does carry out automated decision making, provide further information here].

Your right to complain about our processing

 

If you think we have processed your personal data unlawfully or that we have not complied with UK GDPR, please get in touch with us so that we can help. You may also report your

 

concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO

website: h ttps://ico.org.uk/concerns/.

Any questions?

 

If you have any questions or would like more information about the ways in which we process your data, please contact [insert name/job role/email address].

 

Signed:		Signed:
On behalf of The Farthings Nursing Home		Employee
Date:		Date:

Template Data Privacy Policy – External – GDPR09

 

The Farthings Nursing Home

Privacy Policy – External

 

[This policy should be circulated to non-employees, including Residents, although The Farthings Nursing Home should consider the extent to which the provisions are applicable to Residents and other contacts. If necessary, The Farthings Nursing Home should use more than one privacy policy for non-employees.]

 

When The Farthings Nursing Home processes your personal data, it is required to comply with the Data Protection Act 2018 (‘DPA’) and the UK GDPR (the DPA and UK GDPR are together referred to as the ‘Data Protection Legislation’).

 

Your personal data includes all the information we hold that identifies you or is about you, for example, your name, email address, postal address, date of birth, location data and in some cases, opinions that we document about you, as well as special categories of data, including but not limited to, medical and health records, Care Plans and information about your religious beliefs, ethnic origin and race, sexual orientation and political views. It may also include opinions about you, opinions given by you and information from which we learn something about you [Update as necessary to reflect the personal data that is being processed about the data subjects to whom this data privacy policy will be provided].

 

Everything we do with your personal data counts as processing it – including collecting, storing, amending, transferring and deleting it. We comply with the data protection legislation to make sure that your information is properly protected and used appropriately.

 

This privacy policy provides information about the personal data we process, why we process it and how we process it.

Our responsibilities

 

The Farthings Nursing Home is the controller of the personal data you provide. We have appointed Karen Phillips as Manager and they will have day to day responsibility for ensuring that we comply with the data protection legislation and for dealing with any requests we receive from individuals exercising their rights under the data protection legislation. [This can be updated to reference another job title as having responsibility for compliance with data protection legislation where no DPO has been appointed. If possible, avoid referencing a named individual in case that individual ceases to have responsibility or leaves The Farthings Nursing Home].

What personal data do we process about you?

 

[Note: The Farthings Nursing Home should include as much information as possible about the types of data it processes. Some examples are included below but these will need to be reviewed and updated on a case-by-case basis]

 

We process your personal data in order to provide you with the services you have requested, to fulfil the contract we have entered into with you and/or to receive services or goods from you. We may also process your personal data to respond to any queries or comments you submit to us and to correspond with you on a day-to-day basis. [Note, this paragraph tries to cover all bases including provision and receipt of services. The Farthings Nursing Home may feel it is more appropriate to use more than one privacy policy for non-employees].

 

If we do not receive the personal data from you, we may be unable to fulfil our obligations to you.

 

More information about the personal data we process is set out below: [Residents]

[Personal data that we may process about you (depending on the extent of the information you have provided to us) includes:

Identity data such as your first name, middle names, last name, marital status, title, date of birth and gender

Contact data such as your address, email address and telephone numbers Financial data including your bank account and payment card details

Special categories of data including information about your medical background and health and diversity/equality information such as your race and ethnicity

Opinions about you, opinions given by you and other information from which we learn something about you

We process most of your information on the grounds of consent from you, legitimate interests (such as [please insert a description of the legitimate interests you are pursuing when you process personal data], performance of a contract we have entered into with you, protection of vital interests of an individual or, in the case of special categories of data, processing for the provision of health or social care or treatment or the management of health or social care systems or services. [Please delete any that are not appropriate, particularly if The Farthings Nursing Home chooses to use more than one data privacy policy depending on the type of data subject].

[Suppliers]

[Personal data that we may process about you includes:

Identity data such as your first name, middle names, last name, marital status, title, date of birth and gender

Contact data such as your billing address and delivery address (whether residential or your company address), email address and telephone numbers

Financial data including your bank account and payment card details (except to the extent the financial information is company rather than personal information); and

Transaction data including details about payments made to you (where you are an individual)]

We process most of your information on the grounds of our legitimate interests (including a business relationship with you or the company for which you work) and fulfilment of our contract with you (where you are an individual). Any information we process about the company for which you work rather than you as an individual is not covered by this data privacy policy.

[Candidates]

[Personal data that we are likely to process about you includes:

Identity data such as your first name, middle names, last name, marital status, title, date of birth and gender

Contact data such as your postal address, email address and telephone numbers

Background data such as your education, career background and work experience

Personal information such as your skills and qualities

 

Any other information that you include on any CV, application or covering letter you send to us. If this information includes special categories of data, we will process that information on the grounds of consent because you have chosen to provide it to us.]

We process most of your information on the grounds of our legitimate interests to determine whether or not we have a suitable vacancy for you, or on the grounds of our legal obligations.

 

If we obtain consent from you to the processing of your personal data, you can withdraw your consent at any time. This will not affect the lawfulness of any processing we carried out prior to you withdrawing your consent.

Who will receive your personal data?

 

We only transfer your personal data to the extent we need to. Recipients of your personal data include:

[insert any potential recipients or categories of recipients]

We do not transfer your personal data outside of the EEA. [If The Farthings Nursing Home transfers personal data outside of the EEA, delete this sentence and include the paragraph below instead].

 

We may transfer your personal data outside of the EEA to [name of recipient of data outside EEA]. [A finding of adequacy has been made in respect of [relevant country], which means the UK Government is satisfied that any data transferred to [relevant country] will be adequately protected]. [We will transfer your personal data on the basis of safeguards included in a written agreement between The Farthings Nursing Home and the recipient of your personal data. [This paragraph should be included if The Farthings Nursing Home transfers personal data outside the EEA. There are a number of optional clauses within this paragraph. The Farthings Nursing Home will need to consider the location of the recipient and the grounds on which personal data is transferred and update this paragraph accordingly].

How long will we keep your personal data?

 

We will retain your personal data for [confirm retention period if you have opted for one overarching retention period. If you have multiple retention periods for different types of external contacts (which is likely to be the case), you may refer to a separate retentions schedule which could be attached to this policy or available on request, or separate out the different external contacts and the corresponding retention periods within this policy. There must be valid reasons to retain the personal data for the chosen period of time. Personal data must not be retained ‘just in case’ it is needed in the future. Further guidance about appropriate retention periods for employee and HR personal data is included in the Data Security and Data Retention Policy and Procedure]. Your information will be kept securely at all times. Following the end of the relevant retention period, your files and the personal data covered by the retention period will be permanently deleted or destroyed.

What are your rights?

You benefit from a number of rights in respect of the personal data we hold about you. We have summarised the rights which may be available to you below, depending on the grounds on which we process your data. More information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-

These rights apply for the period in which we process your data. There are certain caveats and exemptions to some of your rights

 

which may mean that, in some circumstances, you may not be entitled to exercise them. If we believe that is the case upon receipt, we will let you know.

1.  Access to your data

You have the right to ask us to confirm that we process your personal data, as well as access to and copies of your personal data. You can also ask us to provide a range of information about the ways in which we process your data, although most of that information corresponds to the information set out in this privacy policy.

2.  Rectification of your data

If you believe personal data that we hold about you is inaccurate or incomplete, you can ask us to rectify that information.

3.  Right to be forgotten

In some circumstances, you have the right to ask us to delete personal data we hold about you.

4.  Right to restrict processing

In some circumstances, you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we do not have to delete it.

5.  Data portability

You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller.

6.  Right to object

You are entitled to object to us processing your personal data:

If the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority

For direct marketing purposes (including profiling); and/or

For the purposes of scientific or historical research and statistics

[You may specify here that you do not intend to use personal data to send direct marketing and/or for scientific or historical research and statistics, if that is the case]

Automated decision making

Automated decision making means making a decision solely by automated means without any human involvement.

 

[Automated decision making includes, for example, an online credit reference check that makes a decision based on information inputted without any human involvement. Choose between the following two clauses for the privacy policy:]

 

We do not carry out any automated decision making using your personal data. [If The Farthings Nursing Home carries out automated decision making, delete this sentence and complete the section below].

 

We carry out the following types of automated decision making using your personal data: [If The Farthings Nursing Home does not carry out automated decision making, delete this sentence and include the sentence above. If it does carry out automated decision making, provide further information here].

Your right to complain about our processing

If you think we have processed your personal data unlawfully or that we have not complied with UK GDPR, please get in touch with us so that we can help. You may also report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (‘ICO’). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO

website: h ttps://ico.org.uk/concerns/.

Any questions?

If you have any questions or would like more information about the ways in which we process your data, please contact info@tfcare.co.uk.