Tutela Jersey Limited for the purpose of this notice, are the data controllers and we are pleased to provide you with the following Privacy Notice.
We take great care in looking after the personal data you share with us. We want to assure you that you can be confident that your data is safe and secure with us.
We are committed to doing the right thing when it comes to how we collect, use and protect your personal data.
sets out the types of personal data that we collect
explains how and why we collect and use your personal data
explains when and why we will share personal data within our service and with other organisations/agencies
explains the rights and choices you have when it comes to your personal data.
Using our Services means:
Contracting us to care for you or a family member in accordance with the developed ‘care plan’.
using our website (“our Website”) where this Policy is posted; or
If you contact us or we contact you about our services.
Personal Data we Collect:
When you use our home care services you may provide us with information that is classed as personal data. We may also collect from you, your personal data and we may also receive from other sources, who may be contracting our care on your behalf e.g. social services and/or social security departments administering the long term care benefit.
When you use our home care services you may provide us with:
Name, postal and billing addresses (if different), phone number, family or Advocate details.
Bank account details.
Service type, assistance needed, agreed costs and contact days.
When your care plan is developed, we may collect your GP’s name and contact details, emergency contact name and details, any other agencies involved in your care.
Allergies, medical history, additional information such as mobility, sight, hearing etc.
Your specific care requirements, log of visits, medication and other health or mental health assessments.
When you contact us or we contact you about our services, we may collect:
Personal data you provide about yourself anytime you contact us about our services (for example, your name and contact details), including contacting us by phone, email or post or when you speak with us through social media.
Your feedback and contributions to client surveys or reviews.
How we use personal data:
This section explains in detail how and why we use personal data.
In order to collect and process personal data about you we need to have a lawful basis. The main lawful basis we rely on includes consent (where you have given permission to leave your care plan accessible), contract (where processing is necessary for the performance of a contract with you) and our legitimate interests (where processing is in the interest of our company and we believe you would have a reasonable expectation for us to do this). We may also use vital interest to share your information when immediate attention is needed for your own safety, such as calling for an ambulance or your GP.
We use personal data to:
Make our Services available to you:
We want to serve you better as a customer, so we use personal data to provide clarification or assistance in response to your communications.
Manage and improve our websites.
Personalise your Tutela experience:
We invite you to take part in and manage client surveys, reviews and other activities that improve our service to you.
We carry out surveys or ask for your feedback to improve our services. However, if we contact you about this, you do not have to take part in the activities. If you tell us that you do not want us to contact you for surveys or feedback, we will respect this choice. This will not affect your ability to use our services.
Claims & complaints:
In order to resolve complaints, legal claims or disputes involving you or us we will need to process your information and possibly retain it for a longer period than specified in our retention schedule. For example, if you have an accident or there is an incident where our staff have involvement.
If you are using one of our social media pages, please remember that our page is provided via social media platform sites, such as Facebook or Instagram, which has their own functionality, terms and privacy policies. Please ensure you have read these carefully and have checked your own personal settings to ensure you are happy with how your information will be used by the social media site. Our social media pages may make use of these functions, but we do not control them and are not responsible for them. We will not assume responsibility for data shared or the responsibilities of a data controller, that responsibility will remain with the social media provider.
We will monitor the social media site on occasion and, as soon as practically possible, any inappropriate entries will be removed.
Sharing personal data with third parties:
We may on occasions pass your Personal Information to specific third parties exclusively to process work on our behalf. Tutela requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice. For example:
We may need to share information with your GP, the hospital and Social Services. If you have an accident or we notice an injury, we have a legal obligation to share this information with the Jersey Care Commission, similarly if there is a safeguarding concern, we are mandated by policy to share this information with safeguarding services.
We do not broker or pass on information gained from your engagement with us without your consent. However, we may disclose your Personal Information to meet legal obligations, regulations or valid governmental request as cited above.
How we protect personal data
We know how important it is to protect and manage your personal data. This section sets out some of the measures we have in place.
We apply physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data.
We protect the security of your information while it is being transmitted by password protecting or encrypting it.
We use computer safeguards such as firewalls and data encryption to keep this data safe.
We only authorise access to employees and trusted partners who need it to carry out their responsibilities.
We regularly monitor our systems for possible vulnerabilities and attacks.
We also retain hard copy files containing your information. These files are kept in locked cabinets at a secure location. These are mainly archived older files – that are not supported by ‘Log My Care’.
How long we keep personal data
We will not keep your personal data longer than we need to, how long this is, depends on several factors, including:
Why we collected it in the first place.
Whether there is a legal/regulatory reason for us to keep it, or
Whether we need it to protect you or us.
You can at any time ask us to provide you with the retention schedule relating to your own personal data. We will provide this information in accordance with our policy and procedure for Data Subject Access Requests.
Your rights as a data subject
At any point whilst we are in possession of, or processing your data, you have the following rights:
Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete. If you believe we hold inaccurate or missing information, please let us know and we will correct it.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. There are several situations when you can have us delete your personal data, this includes (but is not limited to):
When we no longer need to keep your personal data.
You have successfully made a general objection.
You have withdrawn your consent to us using your personal data (and we do not have any other grounds to use it).
Right to restriction of processing – where certain conditions apply you have a right to restrict the processing. There are several situations when you can restrict our use of your personal data, this includes (but is not limited to):
you have successfully made a general objection.
you are challenging the accuracy of the personal data we hold.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing. If on balance, your rights outweigh our interests in using your personal data, then we will at your request either restrict our use of it or delete it.
Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
Subject Access Rights
You have the right to see the personal data we hold about you. This is called a Data Subject Access Request (DSAR).
If you would like a copy of the personal data, we hold about you can write to us at:
Tutela Jersey Limited (add address)
You can also email us at email@example.com
To access what personal data is held, identification will be required.
We will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license or passport. A minimum of one piece of photographic ID listed above and a supporting document is required such as a utility bill not older than three months. If we are dissatisfied with the quality of ID provided, further information may be sought before personal data can be released.
We will respond to your request within a four-week period, once your identification has been verified.
In the event that we refuse your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
We always seek a positive resolution to any complaints you may have. However, you also have the right to complain to the Jersey Office of the Information Commissioner about how we have used your personal data.
Office of the Information Commissioner – Jersey
2nd Floor, 5 Castle St, St Helier, Jersey JE2 3BT
Telephone 01534 716530 or email: firstname.lastname@example.org