Privacy Policy - Relative Matters

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Privacy Notice

BACKGROUND:

Relative Matters understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

  1. Information About Us

Relative Matters Limited registered in England under company number 07455183.

Registered address: 14 Hamilton Court, Drake Avenue, Worthing, West Sussex, BN14 7DU. 

Data Protection Officer: Chris Moon-Willems.

Email address: chris@relativematters.org.

Telephone number: 0800 088 6184.

We are regulated by the HCPC – Health Care Professions Council. Consultants are also registered with their professional bodies, such as BASW (British Association of Social Workers) and The Royal College of Occupational Therapists.

  1. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

  1. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

  1. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

        1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact me to find out more or to ask any questions using the details in Part 11.
        2. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
        3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
        4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
        5. The right to restrict (i.e. prevent) the processing of your personal data.
        6. The right to object to us using your personal data for a particular purpose or purposes.
        7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
        8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

  1. What Personal Data Do You Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):

  • Name;
  • Date of birth;
  • Gender;
  • Address;
  • Email address;
  • Telephone number;
  • Business name;
  • Job title;
  • Profession;
  • Payment information;
  • Information about your preferences and interests;
  • Some health related information.

Your personal data may be obtained from the following third party parties:

  • Your, or a, solicitor you have consulted;
  • A relative or family friend
  • A financial adviser.
  1. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for or may be used for one of the following purposes:

  • Supplying our services to you.
  • Your personal details are required in order for us to enter into a contract with you or someone you have asked us to liaise with in your best interests, such as a relative, family friend, solicitor or financial advisor.
  • Personalising and tailoring our services for you or in your best interests.
  • Communicating with you. This may include responding to emails or calls from you.
  • Supplying you with information by email and or post.
  • Providing our services to your Attorney or Deputy in your best interest.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone AND/OR text message AND/OR post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

  1. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

  • Information may be retained for a longer period of time where there are continuing circumstances related to health or legal matters where the information may be required for the performance of services or to act in the recipient of care’s best interests.

Documents

Retention

Exceptions

General Correspondence – Electronic Data

3 Years

Where linked to Certificate Providing, Lasting Powers of Attorney or other continuous matters information may be retained for a longer period of time.

General Correspondence – Hard Copy

3 Years

Where linked to Certificate Providing, Lasting Powers of Attorney or other continuous matters information may be retained for a longer period of time.

Lasting Powers of Attorney

For the life of the Donor

Related material disposed of in accordance with General Correspondence following the death of the donor.

Certificate Providing Notes

For the life of the Donor and for 1 year following.

Letter of Wishes

For the life of the Donor

Related material disposed of in accordance with General Correspondence following the death of the donor.

Accounting Records

For up to 7 Years

Client Reports, Reviews, Consultations

3 Years

Where linked to Certificate Providing, Lasting Powers of Attorney or other continuous matters information may be retained for a longer period of time.

Timesheets

1 Year

Consultant’s References

6 months after the cessation of the consulting relationship

Health Related Information

3 Years

Where linked to Certificate Providing, Lasting Powers of Attorney or other continuous matters information may be retained for a longer period of time.

Name and Email Address for Marketing Information

3 Years

Where the information is displayed within the public domain and it is current and correct.  Where a client has purchased or enquired about our services.

  1. How and Where Do You Store or Transfer My Personal Data?

We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.]

AND/OR

We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.]

AND/OR

Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.]]

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
  1. Do You Share My Personal Data?

We may sometimes contract with the following third parties to supply services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

  • Xero.
  • Microsoft 365.
  • Liz Tremlett, Independent Occupational Therapist for the purpose of providing Occupational Therapy Services
  • Richenda Solomon independent office administrator for the purposes of invoicing, administration and office management.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

  1. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything I need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

Wewill respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

  1. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Chris Moon-Willems:

Email address: chris@relativematters.org.

Telephone number: 0800 088 6184.

Postal Address: 14 Hamilton Court, Drake Avenue, Worthing, West Sussex, BN12 6ER.

  1. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on request or by downloading the latest copy of our Privacy Notice from our website.