Introduction
1. Purpose of this privacy notice
This notice sets out the basis on which we will process any personal data we collect from you, or that you provide to us. 'Processing' for the purposes of this notice covers a very broad range of activities, including using, transferring, storing and even deleting data.
We process personal data in order to provide a Reablement App with the purpose of supporting Organisations to meet their service users to progress and meet their Reablement goals.
In registering, or using, or supplying data or information through the App you acknowledge that you are aware of the collection, use and transfer of the relevant data and your personal data under the terms of this privacy notice.
Newton respects your privacy. We think that it is important to be transparent about how we collect and use your personal data and are committed to protecting the privacy and security of the information we hold about you. This privacy notice provides more information about how we do this and provides you with certain information that must be provided under the retained EU law version of the General Data Protection Regulation (UK GDPR).
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
The app will be hosted on infrastructure owned by Xantura, a Newton company.
2. Contact
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below:
Full name of legal entity: Newton Consulting Limited
Email address: sarah.dasilva@newtonimpact.com
Postal address: 2 Kingston Business Park, Kingston Bagpuize, Abingdon, Oxfordshire, OX13 5FE
3. Data Protection Principles
We will comply with data protection law and principles, which means that your data will be:
- used lawfully, fairly and in a transparent way;
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- relevant to the purposes we have told you about and limited only to those purposes;
- accurate and kept up to date;
- kept only as long as necessary for the purposes we have told you about; and
- kept securely.
4. The data we collect about you
Personal data, or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- User Identity Data: workforce data covering names, email addresses and roles to control the worker's access to the application and to audit workers accessing and/or changing service user data.
- Contact Data includes address, email address and telephone numbers.
- Usage Data includes information about how you use our app.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
5. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests
In this context, "legitimate interest" means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data. If we expressly tell you that we are relying on consent as a legal basis for processing your personal data, you can withdraw consent at any time by contacting us: sarah.dasilva@newtonimpact.com
6. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|
To manage our relationship with you which may include: (a) To administer the login and access to app accounts (b) Notifying you about changes to our terms or privacy policy |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our services) |
|
To administer and protect the app (including data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical (d) usage |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
7. Third-party marketing
We won't share your personal data with any third party for their marketing purposes.
8. Change of purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us: sarah.dasilva@newtonimpact.com
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
9. Who has access to your personal data?
In the course of working with you, we will collect information from, or share it with your employer.
10. International transfers
We use strict procedures and security features designed to prevent any unauthorised or unlawful access to the personal data which we control.
Personal data which we hold in relation to you will be stored securely within secure data centres located within the United Kingdom.
11. How do we protect your personal data?
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
We have also put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
12. For how long do we keep your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. After this period, we will securely destroy your personal data in accordance with applicable laws. For the purposes of the app, it is anticipated that your data will be held in line with the contractual terms for how long the app is in use by your employer.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
13. What are your rights?
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below);
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes;
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it; and
- Request the transfer of your personal data to another party.
If you wish to exercise any of the rights set out above, please contact us at sarah.dasilva@newtonimpact.com
If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
14. No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
15. Time limit to respond
We try to respond to all legitimate requests within one month.
16. Changes to the privacy notice or to your personal data
We keep our privacy policy under regular review and may update this privacy notice at any time. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.