Athena Care Homes (UK) Ltd Website Privacy Notice
Athena Care Homes (UK) Ltd, also known as Athena Care Homes, together with their subsidiary companies are committed to protecting your privacy when you use our services.
The Privacy Notice below explains how we use information about you and how we protect your privacy.
We have a Data Protection Officer who makes sure we respect your rights and follow the law. If you have any concerns or questions about how we look after your personal information, please contact the Data Protection Officer, at Enquiries@athencarehomes.co.uk
Who Are We?
This privacy notice (the “Privacy Notice”) applies to all personal information processing activities carried out by Athena Care Homes (UK) Ltd.
Our principal address is Unit 5, Russel House, Russel Square, Hornsby Way, Southfields Business Park, Laindon, Essex, SS15 6TF but you can search for your local care home here: https://www.athenacarehomes.co.uk/our-care-homes/
We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with our business.
We may update our Privacy Notice from time to time. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.
Supplementary notice – COVID-19
This supplementary notice is to make it easier to understand and provide you with more information about how we may process your personal information in relation to the unprecedented challenges we are all facing during the coronavirus pandemic (COVID-19).
At this time, we may seek to share your personal data limited to contact information only with the necessary Government bodies in support of the track and trace scheme, to ensure the safety and well-being of all our customers and employees.Such information will be limited to what is proportionate and necessary, considering the latest guidance issued by the Government and health professionals, to manage and contain the virus.
Any information which is shared will only be shared on a need to know basis, with appropriate individuals. Only the minimum information for the purpose will be shared.
The legal basis for processing the data for this purpose is that it is necessary in order to protect the vital interests of individuals in monitoring and dealing with the COVID-19 pandemic.
How to contact us
If you need to contact us in connection with our processing of your personal data you can contact us in the following ways:
Via your local care home team.
Via letter to Data Controller, Unit 5, Russel House, Russel Square, Hornsby Way, Southfields Business Park, Laindon, Essex, SS15 6TF. Alternatively, you can email Enquiries@athencarehomes.co.uk.
Why we collect your Personal Information
What is personal information?
Personal information can be anything that identifies and relates to a living person. This can include information that when put together with other information can then identify a person.
Information we may collect about you may include (but is not limited to):
Name
Address
Telephone numbers
Email addresses
Data of birth
Gender
Occupation
Ethnicity
Bank details
Employment Status (only if applying for concessionary memberships)
Health data
CCTV images
Computer IP address
Dependent Details (only where applicable)
Did you know that some of your personal information might be classified as ‘special’?
Some information is ‘special’ and needs more protection due to its sensitivity. It’s often information you would not want widely known and is very personal to you. This is likely to include anything that can reveal information relating to your:
Sexuality and sexual health
Religious or philosophical beliefs
Physical or mental health
Trade union membership
Political opinion
Genetic/biometric data
We will only collect this type of information if it is necessary to your contract so that we can provide the right services to you.
We may at times need to share this information. We will only do this if we have your consent or if there are legal requirements for us to do so. We may receive information about you from other data controllers, such as the police who might tell us about a crime they are investigating where this impacts on your contract with us. If you give us this information about yourself when communicating with us, you do so because you consider it forms part of a legitimate interest for us to hold this information on our records.
If we ask for any sensitive personal data about you, we will always tell you why we need it and ask for your consent to hold it.
Why do we need your personal information?
We may need to use some information about you to:
deliver services and support to you;
to carry out our obligations arising from any contracts entered into between you and us;
manage those services we provide to you;
service improvement
prevention/detection of crime/fraud
help investigate any complaints you have about our services;
check the quality of our services;
How the law allows us to use your personal information
There are a number of legal reasons why we need to collect and use your personal information.
Generally we collect and use personal information for the purposes of where:
you are entering or have entered into a contract with us
you, or your legal representative, have given consent
it is necessary to protect someone in an emergency
it is required by law
you have made your information publicly available
it is necessary for legal cases
it is necessary for archiving, research, or statistical purposes
How we communicate with you
At Athena Care Homes (UK) Ltd we believe in putting our customers in the driving seat when communicating. When we communicate with you we will do so either because it forms part of your contract with us, we have your consent or where we have a legitimate interest to communicate with you.
We have outlined our primary communication activities below which tells you how we may communicate with you and how you can update your preferences.
Customer service communications
We may contact you or send communications to tell you about a service enhancement such as improvements to your local care home or to keep you informed about your home and it’s status. We won’t need your consent to communicate with you this way because we have assessed that it forms part of our agreement with you. We will contact you through email for these service communications.
Customer communications may also include customer surveys as we feel understanding your experiences to help us improve the service we provide you forms an integral part of our relationship. We do not ask for your consent to contact you for these surveys as we have assessed that it is in our legitimate interest to contact you in this case. You can tell us to stop at any time – all our customer surveys will always contain an easy opt-out link.
Customer service communications via SMS/text messaging and calls
If you supply us with your telephone contact details, we may use them to call or send you text messages.
Examples of text messages include:
Confirming an appointment, that you have requested
Emergency updates from your local care home
Asking you to contact a named person or department
Prospective customer communications
We would like to send you occasional messages and to keep you informed about products or service information when you make an enquiry with us. We will keep your contact information for six months after which time we will delete your data from our systems if you/your relative not become a resident or have not been communicating back with us. We will always give you an opt-out route when communicating with you. To make sure you keep receiving our latest offers beyond this time, email our central enquiries@athenacarehomes.co.uk inbox confirming your opt in.
We may also contact you to follow-up on any failed online enquiries where we feel we can offer assistance to you.
We do not ask for your consent to contact you for these product or service messages as we have assessed that it is in our legitimate interest to keep you informed for a limited period. You can tell us to stop at any time – all our communications will always contain an easy opt-out link. We will also contact you where we believe you may require support for abandoned online purchases.
Past customer communications
If you are a past resident or customer and have not opted out to marketing we would love to stay in touch. We will send you occasional messages and keep you informed about products or service information. We will continue to share these updates with you for six months, after which time we will stop this communication.
We will always give you an opt-out route when communicating with you. To make sure you keep receiving our latest offers beyond this time, email our central enquiries@athenacarehomes.co.uk inbox confirming your opt-in.
We do not ask for your consent to contact you for these product or service messages as we have assessed that it is in our legitimate interest to keep you informed. You can tell us to stop at any time – all our communications will always contain an easy opt-out link.
Prospective and past resident and customer communications via SMS/text messaging
If you supply us with your telephone contact details as part of your original enquiry or during your past contact with us and have not opted out to marketing, we may use this information to send you a updates on products and services that we believe are of interest to you. We understand that not everyone wants to receive marketing through SMS, so if you wish to opt out to these messages please use the opt-out link in the SMS message or contact us at enquiries@athenacarehomes.co.uk, requesting to opt-out.
Consent and your preferences
To support our ongoing relationship, we would like to send you information on other products and services we offer, and which we think will be of interest to you. We will rely on consent for the majority of our direct marketing. We will ask for your consent to communicate this type of information to you. You can remove your consent and ask us to stop at any time. At Athena Care Homes you can easily opt out of communications by contacting your local care home.
If you want to update your preferences or remove your consent, please contact enquiries@athenacarehomes.co.uk and we can process your request. Alternatively, you can speak to the reception team at your local Athena Care Home.
We only use what we need!
Where we can, we’ll only collect and use personal information if we need it to deliver a service or meet a requirement.
If we don’t need personal information we’ll either keep you anonymous if we already have it for something else or we won’t ask you for it. For example, in a survey we may not need your contact details so we’ll only collect your survey responses.
If we use your personal information for research and analysis, we’ll keep you anonymous or use a different name unless you’ve agreed that your personal information can be used for that research.
We won’t sell your personal information to anyone else.
We will always provide an option for updating your marketing preferences on our communications with you.
What you can do with your information
The law gives you a number of rights to control what personal information is used by us and how it is used by us.
You can ask for access to the information we hold on you.
You have the right to ask for the information we have about you. When we receive a request from you in writing, we must give you access to what personal information we’ve recorded about you.
However, we can’t let you see any parts of a record which contain:
Confidential information about other people; or
May be held in preparation to defend legal claims
This applies to personal information that is in both paper and electronic records. If you ask us, we’ll also let others see your record (except if one of the points above applies).
A request for personal information can be made via email or in writing. This is known as a subject access request. In order to make a subject access request you will need to provide the following information:
your name
your address
enough information to identify your records
If we have doubts about your identity or we are finding it difficult to locate your personal information we may ask you to provide us with proof of identity.
What types of documents could I submit as proof of ID?
Copy passport with signature (please remove your passport number)
Copy driving license picture with signature (please remove your driver number)
Copy of signed tenancy or contract with us
You can write to us at the following address:
Data Protection
Officer Unit 5,
Russel House,
Russel Square,
Hornsby Way,
Southfields Business Park,
Laindon,
Essex,
SS15 6TF
If you have any difficulties or are unable to make a request in writing, please contact us on 0208 536 6690
We will not start your subject access request until we are satisfied that you have provided us with enough information for us to identify you.
Once you have made a request you will receive an acknowledgement and your request should be answered within one month. In certain circumstances, we are allowed to take longer but we will tell you if we feel we may need longer without undue delay from when we receive your request.
You can ask to change information you think is inaccurate
You should let us know if you disagree with something we may have recorded about you.
We may not always be able to change or remove that information but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.
Please contact enquiries@athenacarehomes.co.uk and we can deal with your request. Alternatively, you can speak to the reception team at your local Athena Care Home.
You can ask to delete information (right to erasure)
In some circumstances you can ask for your personal information to be deleted, for example:
Where your personal information is no longer needed for the reason why it was collected in the first place
Where you have removed your consent for us to use your information (where there is no other legal reason us to use it)
Where there is no legal reason for the use of your information
Where deleting the information is a legal requirement
Where your personal information has been shared with others, we’ll do what we can to make sure those using your personal information comply with your request for erasure.
Please note that we can’t delete your information where:
we’re required to have it by law
it is for historical research, or statistical purposes where it would make information unusable
it is necessary for legal claims
You can ask to limit what we use your personal data for
You have the right to ask us to restrict what we use your personal information for where:
you have identified inaccurate personal information, and have told us of it
where we have no legal reason to use that information but you want us to restrict what we use it for rather than erase the information altogether
We will assess whether you have a right to a restriction and where restriction of use has been granted, we’ll inform you before we carry on using your personal information.
Where possible we’ll seek to comply with your request, but we may need to hold or use information because we are required to by law or we have a legal basis to do so, such as a contract.
You can ask to have your information moved to another provider (data portability)
You have the right to ask for your personal information to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.
However, this only applies if we’re using your personal information with consent (not where we are processing your personal information for contractual, legitimate interests, legal obligations or vital interests as a legal basis) and if decisions were made by a computer and not a human being.
It’s likely that data portability won’t apply to most of the services you receive from Athena Care Homes (UK) Ltd.
Right to understand automated decisions made about you
You can ask to have any computer made decisions explained to you, and details of how we may have ‘risk profiled’ you.
You have the right to question decisions made about you by a computer, unless it’s required for any contract you have entered into, required by law, or you’ve consented to it.
You also have the right to object if you are being ‘profiled’. Profiling is where decisions are made about you based on certain things in your personal information.
If and when your personal information is used to profile you, in order to deliver the most appropriate service to you, you will be informed.
If you have concerns regarding automated decision making, or profiling, please contact the Data Protection Officer at enquiries@athenacarehomes.co.uk who will be able to advise you about how we are using your information.
Keeping your information secure
We store personal information both electronically and in paper form.
We implement security policies, processes and technical security solutions to protect the personal information we hold from:
Unauthorised access
Improper use or disclosure
Unauthorised modification
Unlawful destruction or accidental loss
When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors) act on your behalf we will take steps to ensure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.
Employees and third parties who have access to, or are associated with the processing of, your personal information are obliged to make reasonable efforts to safeguard it.
How we use your telephone number
Text messages and contact via telephone provide a direct way to contact and share information with you about the services we can deliver to you. It can also help you to receive important messages about your residency, important home updates e.g. temporary closures and other services that we provide you.
If you provide your telephone number we may keep in contact with you by text.
Sharing your telephone number with third parties
We may pass your telephone number to third parties so that we can meet our contractual obligations with you. We may also share your telephone numbers if we are required to by law.
We may supply the details to our approved third party contractors who are delivering or performing services on our behalf, and these companies must not use your information for any other purpose. We never share or sell your telephone numbers to telesales/marketing companies.
Who do we share your information with?
We use a range of organisations to either store personal information or help deliver our services to you. Where we have these arrangements there is always an agreement in place to make sure that the organisation complies with data protection law.
We may enter into partnerships with other organisations such as local authorities and the NHS. In order to protect your information, we will enter into a legally binding data sharing agreement with partner organisations before any sharing takes place. It is not always possible for us to tell you that personal information is being shared, for example when we are working with the police or other agencies to help the investigation or detection of a crime as to do so may prejudice that investigation.
We are likely to share your personal information with the following:
Local Authorities
We will share your personal information with local authorities usually for the purposes of providing services processed by that local authority e.g. placement into beds in our homes funded by the local authority.
NHS
Trusted Care
Police
We may share your personal information with the police for the purposes of preventing or detecting a crime or fraud.
Safeguarding, Support Agencies and Charities
We may share your personal information with these organisations where we suspect there may be safeguarding or welfare concerns. We will usually try to gain your consent in advance, but we may make a safeguarding referral without consent in situations where we feel there is a significant risk.
Debt Recovery Agents
We may share your personal information with debt recovery agents for the purposes of recovering any outstanding charges owed to us.
Legal Services and Partners
We may share your personal information with our legal services or solicitors if we are preparing or defending a legal claim.
Business Asset Transactions
If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
Although this is not an exhaustive list the following third parties process data on Athena Care Homes (UK) Ltd’s behalf which may include your personal data for the specific purposes identified. Athena Care Homes (UK) Ltd has appropriate contracts in place to ensure third party data processors comply with necessary regulations:
Trusted Care (Search Care Limited) – Telephone answering services
Mailchimp (The Rocket Science Group LLC) – Marketing services
Where there is a high risk to your personal information we will complete a privacy assessment before we share personal information to make sure we protect privacy and comply with the law.
Sometimes we have a legal duty to provide personal information to other organisations, this is often because we need to give that data to the police, courts, local authorities or government bodies.
We may also share your personal information when we feel there’s a good reason that’s more important than protecting your privacy. This doesn’t happen often, but we may share your information:
in order to detect and prevent a crime and fraud; or
if there are serious risks to the public, our staff or to other professionals;
safeguarding of vulnerable individuals
If we’re worried about your physical safety or feel we need to take action to protect you from being harmed in other ways, we’ll discuss this with you and, if possible, get your permission to tell others about your situation before doing so.
For all of these reasons the risk must be serious before we can override your right to privacy.
We may still share your information if we believe the risk to others is serious enough to do so.
There may also be rare occasions when the risk to others is so great that we need to share information straight away.
If this is the case, we’ll make sure that we record what information we share and our reasons for doing so. We’ll let you know what we’ve done and why if we think it is safe to do so and will not cause harm, distress or further risks to you, our staff, other professionals and/or the public.
How do we protect your information?
We’ll do what we can to make sure we hold records about you (on paper and electronically) in a secure way, and we’ll only make them available to those who have a right to see them. Examples of our security include:
Encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password). This is done with a secret code or what’s called a ‘cypher’. The hidden information is said to then be ‘encrypted’
Pseudonymisation, meaning that we’ll use a different name so we can hide parts of your personal information from view. This means that someone outside of the Athena Care Homes Group could work on your information for us without ever knowing it was yours
Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it
Training for our staff allows us to make them aware of how to handle information and how and when to report when something goes wrong
Regular testing of our technology and ways of working including keeping up to date on the latest security updates (commonly called patches)
Where in the world is your information?
The majority of personal information is stored on systems in the UK. But there may be some occasions as our technology services progress where your information may leave the UK either in order to get to another organisation or if it’s stored in a system outside of the UK or EU.
We will always have additional protections on your information if it leaves the UK ranging from secure ways of transferring data to ensuring we have a robust contract in place with that third party.
We’ll take all practical steps to make sure your personal information is not sent to a country that is not seen as ‘safe’ either by the UK or EU Governments.
How long do we keep your personal information?
There’s often a legal or a contractual reason for keeping your personal information for a set period of time. We will keep your information for the duration of providing a service or product to you under the terms of a contract, such as your residency contract. When your contract has ended we will keep your personal data for a set time for auditing and reporting purposes and for legitimate interest purposes, after that time we will either anonymise or destroy your information.
You can ask us for a copy of our retention periods by contacting us at:
Data Protection Officer
Athena Care Homes (UK) Limited
Unit 5, Russel House, Russel Square
Hornsby Way, Southfields Business Park
Laindon, Essex, SS15 6TF
How to tell us of a data breach
Athena Care Homes (UK) Limited takes responsibility to protect the personal information we hold about those with whom we work seriously. We are accountable for our processing and take necessary technical and operational steps to maintain information security protections.
If you suspect your personal information or that of others may have been at risk of a data protection breach, please tell us by emailing enquiries@athenacarehomes.co.uk.
The above email address has been made available to everyone with whom we deal with so that customers, employees and supply chain processors can tell us without undue delay of a potential or actual breach.
Where can I get advice?
If you have any worries or questions about how your personal information is handled please contact our Data Protection Officer at: enquiries@athenacarehomes.co.uk
For independent advice about data protection, privacy and data sharing issues, you can contact the Information Commissioner’s Office (ICO) at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
Alternatively, visit ico.org.uk or email casework@ico.org.uk.
