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DATA PROTECTION
PRIVACY POLICY
Introduction:
This privacy policy lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. This Privacy Policy applies to personal information processed by or on behalf of the practice.
This Policy explains
● Who we are, how we use your information and our Data Protection Officer
● What kinds of personal information about you do we process?
● What are the legal grounds for our processing of your personal information (including when we share it with others)?
● What should you do if your personal information changes?
● For how long your personal information is retained by us?
● What are your rights under data protection laws?
The General Data Protection Regulation (GDPR) became law on 24th May 2016. This is a single EU-wide regulation on the protection of confidential and sensitive information. It enters into force in the UK on the 25th May 2018, repealing the Data Protection Act (1998).
For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"), and the Data Protection Act 2018 the organisation responsible for your personal data is QMADS.
This Policy describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
How we use your information and the law.
QMADS will be what’s known as the ‘Controller’ of the personal data you provide to us.
We collect basic personal data about you which does include any special types of information or location-based information. This also includes name, address, contact details such as email and mobile number etc.
Why do we need your information?
The professionals who provide you with support services maintain records about your company and information about your registered manager and yourselves (as nominated individuals, or your business partners) to ensure that your application can be approved by CQC to be registered. These records help to provide you with the best possible service on an ongoing basis and from time to time may be updated to ensure we provide the best service to you.
These records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Records which QMADS hold about you may include the following information;
• Details about you, such as your address, carer, legal representative, contact details
• Your GP information
• Notes about about your career
• Details about your company
• Types of services provided by you or the company that may be commercially sensitive.
• Relevant information regarding other professionals attached to your business.
To ensure you receive the best possible service, your records are used to facilitate the service you receive. Information may be used within QMADS to monitor the quality of the service provided.
How do we lawfully use your data?
We need to know your personal, commercially sensitive and confidential data in order to provide you with regulatory registration services as you are the provider of regulated activities, under the General Data Protection Regulation we will be lawfully using your information in accordance with Article (5) of GDPR: -
1. Personal data shall be:
(a) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);
(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
(e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
(f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
This Privacy Policy applies to the personal data of our patients and the data you have given us about your carers/family members.
Categories of personal data
The data collected by QMADS staff in the event of registration with CQC will be as much personal information as is necessary or possible to obtain in order to process your application.
Sources of the data
QMADS will either receive or collect information when someone contacts the organisation with a view to request services to assist with registering with CQC.
Recipients of personal data
The information is used by QMADS to process applications to CQC and will be shared with CQC as part of the registration process. We may share information accordingly to ensure duty of service to you and with other parties involved in your application (as sub processors) with your consent.
How do we maintain the confidentiality of your records?
We are committed to protecting your privacy and will only use information collected lawfully in accordance with:
● Data Protection Act 2018
● The General Data Protection Regulations 2016
● Human Rights Act 1998
● Common Law Duty of Confidentiality
Every member of staff who works for QMADS has a duty and obligation to keep information about you confidential.
We will only ever use or pass on information about you if others involved in your application have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. you have entrusted us to share in your best interest), where the law requires information to be passed on.
Our policy is to respect the privacy of our clients, their associates and our staff and to maintain compliance with the General Data Protection Regulations (GDPR) and all UK specific Data Protection Requirements. Our policy is to ensure all personal data related to our clients will be protected.
All employees and sub-contractors engaged by our organisation are asked to sign a confidentiality agreement. QMADS will, if required, sign a separate confidentiality agreement if the client deems it necessary. If a subcontractor acts as a data processor for QMADS an appropriate contract (art 24-28) will be established for the processing of your information.
In Certain circumstances you may have the right to withdraw your consent to the processing of data. Please contact the Data Protection Officer in writing if you wish to withdraw your consent. If some circumstances we may need to store your data after your consent has been withdrawn to comply with a legislative requirement.
Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual clients cannot be identified.
With your consent we would also like to use your information to
We would however like to use your name, contact details and email address to inform you of services that may benefit you, with your consent only. There may be occasions were authorised piloting of new facilities where we would like you to take part in new innovations, improving services or identifying trends. We may use your information for comments posted to our website for feedback purposes.
At any stage where we would like to use your data for anything other than the specified purposes and where there is no lawful requirement for us to share or process your data, we will ensure that you have the ability to consent and opt out prior to any data processing taking place.
This information is not shared with third parties or used for any marketing and you can unsubscribe at any time via phone, email or by informing the QMADS DPO as below.
Where do we store your information Electronically?
All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information may be located on servers within the European Union.
The organisation uses the Google Suite to manage client information regarding your company and personnel. This system is provided by Google who act as a data processor on behalf of the organisation.
No third parties have access to your personal data unless the law allows them to do so and appropriate safeguards have been put in place. We have a Data Protection regime in place to oversee the effective and secure processing of your personal and or special category (sensitive, confidential) data.
Who are our partner organisations?
We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations;
• Care Quality Commission
• Other Data processors who will be determined through our arrangements with you - with your informed consent.
You will be informed who your data will be shared with and in some cases asked for consent for this to happen when this is required.
How long will we store your information?
We are required under UK law to keep your information and data for the full retention period not exceeding 25 years including for company accounting purposes.
How can you access, amend move the personal data that you have given to us?
Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communication to help us resolve any issues which you raise.
Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example for a pilot project), or consent to market to you, you may withdraw your consent at any time.
Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this with a electronic data transfer and transfer of your hard copy notes.
Access to your personal information
Data Subject Access Requests (DSAR): You have a right under the Data Protection legislation to request access to view or to obtain copies of what information QMADS holds about you and to have it amended should it be inaccurate. To request this, you need to do the following:
· Your request should be made to QMADS in writing –
· There is no charge to have a copy of the information held about you
· We are required to respond to you within one month
· You will need to give adequate information (for example full name, address, date of birth, and details of your request) so that your identity can be verified, and your records located information we hold about you at any time.
What should you do if your personal information changes?
You should tell us so that we can update our records please contact the Organisation Manager (Tariq Minhas) as soon as any of your details change, this is especially important for changes of address or contact details (such as your mobile phone number), the practice will from time to time ask you to confirm that the information we currently hold is accurate and up-to-date.
Objections / Complaints
Should you have any concerns about how your information is managed at QMADS, please contact the Organisation Manager or the Data Protection Officer as above. If you are still unhappy following a review by the organisation, you have a right to lodge a complaint with a supervisory authority: You have a right to complain to the UK supervisory Authority as below.
Information Commissioner:
Wycliffe house
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 01625 545745
If you are happy for your data to be extracted and used for the purposes described in this privacy Policy, then you do not need to do anything. If you have any concerns about how your data is shared, then please contact the organisation Data Protection Officer.
If you would like to know more about your rights in respect of the personal data we hold about you, please contact the Data Protection Officer as below.
Data Protection Officer:
The Organisation Data Protection Officer is Tariq Minhas. Any queries regarding Data Protection issues should be addressed to him at: -
Email: business@qmads.co.uk
Contact: 0208 111 1188
Changes:
It is important to point out that we may amend this Privacy Policy from time to time. If you are dissatisfied with any aspect of our Privacy Policy, please contact the Data Protection Officer.
QMADS LTD
Suite 6 - Epsom Workhub, The Ebbisham Centre, 6-7 Derby Square, High Street, Epsom, Surrey, KT19 8AG
Excellence since 2012 | QMADS is registered in England and Wales under Company No. 08313940 | VAT No. 258796146 | Copyright © 2021 | All rights reserved.
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