Privacy Notice

Privacy Notice for Priory UK No1 Limited (including Partnerships in Care Limited, trading as Carefirst)

We will update this Privacy Notice from time to time. When we do change the notice (in a significant way), we will post an update on our website.

We take data protection and confidentiality very seriously. This Privacy Notice covers:

• How we collect and use personal data
• What personal data we collect
• How we store your personal information
• Protection of your personal information
• How we use your personal information
• Disclosure to third parties
• Accuracy and retention of personal information
• Access to Personal Information
• Additional rights

We collect personal data about our service users (patients, residents or students in our care) and colleagues so please make sure that you read the relevant sections of this notice and get in touch if you have any questions.

Definitions that are used in this notice:

Personal data - any data that can be used to identify you.

Affiliate

Privacy questions

If you have any questions or concerns about this Privacy Notice or how we process your information or if you would like to make a complaint about a possible data breach please contact us:

Email:
personaldata@priorygroup.com

Postal address:
Data Protection Officer
Priory
5th Floor, 80 Hammersmith Road
London
W14 8UD

We take data security extremely seriously and all such communications are examined and replies issued where appropriate as soon as possible. If you are unsatisfied with the reply you receive, you may refer your complaint to the Information Commissioner’s Office (www.ico.org.uk)

This privacy notice is for service users who are receiving services from Carefirst.

1. Collection and use of personal data
You may be asked to provide your personal information anytime you are in contact with us. We and our affiliates may share this personal information with each other but will always use it in accordance with this Privacy Notice. We may also combine it with other information to provide and improve our services. You are not required to provide the personal information that we may request, but, if you chose not to do so, in some cases we will not be able to provide you with our services or respond to any queries you may have.

Here are some examples of the types of personal information we may collect and how we may use it:

• Name
• Date of birth
• Address
• Telephone number
• Email address
• Physical and mental health information
• Financial information
• NHS number
• National Insurance number
• Passport details, residency status and nationality
• Marital Status
• Racial or ethnic origin
• Political opinions
• Religion

2. What personal data we collect
When you contact us, we may collect a variety of information, including your name, postal address, telephone number, email address, contact preferences or credit card information.

During the course of your relationship with us we will keep information about you in your personal records like your name, address and date of birth together with details of any counselling that you are having.

We are required to formally state the lawful basis for processing the data and information we collect about you. We have reviewed the purposes of our processing activities, and have identified the most appropriate lawful basis (or bases) for the activities we carry out as being by virtue of your consent and / or in accordance with the performance of our contractual obligations.

3. How we store your personal information
The personal information we collect is stored in a variety of paper and electronic forms.  Regardless, we have appropriate and adequate technical and administrative processes in place to make sure that all your information is kept secure. 

4. Protection of your personal information
We take the security of your personal information very seriously. To make sure your personal information is protected, we have a series of technical and administrative measures in place.  Access is limited only to those of our employees who need to access it to provide services to you.

All members of staff are required to undertake annual data protection and confidentiality training and our privacy and security guidelines are communicated to all employees.  These privacy safeguards are monitored and strictly enforced.

We send any information that we need to share with any third parties either as a legal requirement or through an anonymised process securely.

All data is stored on servers within data centres in the UK, although at times they may be temporarily outside the UK but within the EU.

5. How we use your personal information
The personal information we collect and store about you allows us to provide services to you.  We also use it to help us develop, operate, deliver, and improve the quality of the care we provide or, more generally, the type of services that we offer.

From time to time, we may use your personal information to send important notices to you or to those acting on your behalf, such as changes to our terms, conditions and policies. Because this information is important to your interaction with us, you may not opt out of receiving these communications.

We may also use personal information for internal purposes such as auditing, data analysis, and research to improve our services and our communication with you.

If you don’t want to be contacted by us after you are no longer using our services, you can opt out anytime by letting us know. 

We will not sell, share or give information to third parties for marketing purposes.

6. Disclosure to third parties
We will only share your personal information with third parties in the following circumstances:

• Where you have given your consent to the information being shared;
• Where there are issues or concerns like the health and safety of yourself or others; or
• Where there is a legal requirement or responsibility to share the information.

Your personal information may also need to be shared with third parties to make arrangements for the funding and/or payment of services received (for example if your counselling is funded by an insurer or other third party).

7. Accuracy and retention of personal information
We make it easy for you to keep your personal information accurate, complete, and up to date. If any of your information changes please let us know so that we can update our records.

We are legally required to hold certain information about you for a set period of time.  All personal information will be deleted or securely destroyed at the appropriate time and we will not keep your personal information for longer than is required or permitted by law.

8. Access to Personal Information
You are entitled to see what personal information we hold about you at any time.  This Privacy Notice outlines the information we hold about you and why. If you wish to access your personal information, please contact us at the address set out below. 

We are not required to process any request for access which is frivolous or vexatious, jeopardize or otherwise affects the privacy of others, are impractical, or for which access is not otherwise required by law.  We will let you know in writing if any of these circumstances apply to your request.

9. Additional rights
You may also have the right to:

• object to processing of personal data that is likely to cause, or is causing, damage or distress
• prevent processing for the purposes of direct marketing
• object to decisions being taken by automated means
• in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed

If you believe you have any of these additional rights or you wish to exercise them, please let us know.

Employee Privacy Notice in respect of Priory UK No 1 Limited and all its subsidiaries (the “Priory”)

What is a Privacy Notice?

We want to ensure you understand what information we collect about you, how we will use it and for what purpose. We are also required by data protection legislation to explain certain matters to you. This notice sets out and overrides anything previously communicated to you which is different. For the avoidance of doubt, this privacy notice does not form part of your contract of employment or engagement and we may update it at any time.

What information about you will we collect and use?

During your employment/engagement with the Priory, it is routine for us to collect, process and store personal information about you.

The personal information will include:

• personal information such as name, gender, date of birth, dependants, next of kin, job title, NHS number etc.;
• contact details such as addresses, telephone numbers, email addresses and emergency contact details, social media and other online identifiers;
• identification information such as photographs, passport and/or driving licence details, etc.;
• pay and financial information such as salary, benefits (including pensions), bank account details, card details, timesheets, National Insurance numbers, etc.;
• recruitment and professional information such as application forms, CVs, academic and training-related information, records/results of any pre-employment checks (including credit and fraud checks), references, etc.;
• employment and management records such as disciplinary and grievance records, flexible working requests, performance records, appraisals and training records, holiday and attendance records, terms and conditions of employment, etc.;
• right to work documentation such as proof of eligibility to work in the UK and obtaining and maintenance of any necessary professional consents or licences;
• information relating to access to our premises and/or use of our management and IT systems such as system ID, passwords, use of websites, emails sent or received, telephone calls, entry/exit records etc; and
• recordings of phone conversations.

We also handle the following special categories of sensitive personal information:

• information collected for equal opportunities monitoring such as gender, race, ethnic origin etc.;
• any trade union memberships you hold, religious beliefs, sexual orientation and political opinions,
• information about physical and mental health, including any medical conditions, biometric records, sickness absence records, occupational health records, medical reports, pre-employment medical screening tests, insurance claims, etc.; and
• information about criminal convictions and offences.

How and why will we use your personal information

In most cases, we will use your personal information to perform your contract, to comply with our legal obligations as your employer or where we need to in order to further the Priory’s legitimate business interests. We obtain information either directly from you or sometimes from third parties such as employment agencies, your former employers, immigration consultants, the Disclosure and Barring Service and other background check agencies. In rare cases, we may need to use your personal information to protect your (or someone else’s) best interest or if it is in the public interest for us to do so. The situations in which we will use your personal information include:

• recruitment and selection;
• salary, pensions, insurance and benefits administration (including pensions);
• HR, business management and planning purposes;
• carrying out appraisals, handling disciplinary and grievance matters, performance management, career planning, training, promotion, secondments, etc.;
• managing disability, sickness or other types of leave, e.g. maternity leave;
• to facilitate settling of expenses staff have incurred in the course of the business in accordance with their employment contracts;
• to facilitate communications between employees and members within the business;
• internal record keeping purposes to enable us to maintain an audit trail in respect of approvals of decisions, voting and any internal surveys; 
• managing and safeguarding our management, IT and communications systems;
• security reasons;
• health and safety reasons;
• performing workforce analysis, project management and planning;
• training and quality purposes;
• legal reasons, e.g. complying with employment and health and safety obligations, ensuring you are legally entitled to work in the UK, establishing or defending legal claims, for record keeping purposes (including, without limitation to keep pension records or records for tax purposes), to defend our legal rights etc.
• to test our computer systems to improve our services to you i.e. when there are changes to the National Minimum Wage or Living Wage. If you do not wish for your information to be used for these purposes, you can let us know.

Some of the above grounds may overlap and there may be several grounds that justify our use of your information.

We process sensitive personal information for the following purposes:

• managing sickness absence, providing reasonable adjustments in the workplace and administering benefits; and
• for legal reasons, e.g. to comply with employment and health and safety obligations.
• 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.
• We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law 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.

With whom might we share your information?

We may share personal data about you with other entities and their representatives in the Priory.

We may also from time to time appoint a third party to process personal data on our behalf for the purposes outlined above.  Currently we share personal data about with the following third parties:

• other group entities and their employees, representatives, strategic investor, their respective advisors;
• our group’s service providers such as our advisers, pensions and benefits providers, payroll provider, as well as those who provide and support our management, data storage, intranet, and other IT systems;
• occupational health/other benefits provider;
• HM Revenue & Customs and any other regulatory bodies which have authority over the Priory or its group
• our professional advisers, such as lawyers, auditors, immigration advisers etc.;
• such third parties as we reasonably consider necessary in order to prevent crime.

When we use third parties to process information on our behalf, we require them to commit to compliance with relevant data protection legislation.

We may also share your personal data with other third parties where and to the extent that we are under a legal obligation to do so, e.g. HMRC, because of a Court Order, etc.

When might we transfer your information overseas?

Generally, your personal data will be kept within the UK and will never be transferred out of the European Economic Area (EEA). However, at times personal data stored on Priory servers may be temporarily transferred outside the UK into the EEA.