PRIVACY NOTICE for RESIDENTS
Introduction
Isobel Fraser Home is committed to protecting your privacy, upholding your right to confidentiality and keeping any personal information that you share with us safe and secure. Isobel Fraser Home operates under the General Data Protection Regulation 2018 which regulates the collection of your personal information.
This Privacy Notice sets out how we will protect your right to privacy, why we collect your information and how we keep your personal information safe and secure. Where we work with other organisations we will tell you who we work with and why.
Who are we?
Isobel Fraser Home is a charity, regulated by the Scottish Charity Regulator, registered charity number: SC047168. We are an independent residential care home for the elderly in Inverness.
We are also registered with the Information Commissioner’s Office (ICO). Our registration number is ZA222185. You can use this number to search the ICO’s Register.
What information do we collect about you?
The types of information that we may collect or hold on you includes name, address, date of birth, telephone number, your next of kin and family information and your doctor’s contact details. We will also collect your financial details in order to assess your ability to pay for the care that we provide. We also collect sensitive information relating to your physical and mental health and religious beliefs.
Where do we get your information?
Your information may be sourced directly from you, a family member, legal attorney / guardian or other representative. Information about you concerning your health may also be sourced from your doctor, health professional, social worker or from NHS Highland.
Why do we collect and process your information?
Information is collected and processed to provide healthcare services to you and to comply with any reporting requirements, for example, from the Care Inspectorate. Information may also be processed to comply with other legal obligations.
Do we share your information with anyone?
We may share your personal information with NHS Highland (the Health Board”), your doctor, other medical professionals and The Highland Council Social Work Service to ensure that you receive appropriate health care. The Health Board may share that personal data with other regulators or relevant public bodies (including NHS Highland’s and Provider's external auditors, H.M. Revenue and Customs and law enforcement agencies, the Care Inspectorate, the Mental Welfare Commission and the Scottish Human Rights Commission). The personal data may be checked with other Health Boards or Councils for accuracy, to prevent or detect fraud or maximise the Health Board’s revenues. It may be shared where the Health Board considers it appropriate to do so with other public bodies for the same purposes.
How long do we keep your information?
Isabel Fraser Home has a Data Retention Policy, which is available from the address below. There are statutory periods for the retention of medical records. In general, we will keep your personal information for 6 years starting from the date that the provision of care has ended.
What if you visit our website?
Cookies are small pieces of data which are stored on your computer by your web browser when you visit a website. The Isobel Fraser Home website uses cookies for the following purposes:
• to collect anonymised visitor statistics; and
• if you are an administrator, to keep you logged in.
Isobel Fraser Home does not use cookies to gather contact information about you and we do not share, sell or swap your personal information with any other third party.
Lawful Basis
Under the General Data Protection Regulation 2018, Isobel Fraser Home must have a valid lawful basis for processing information. Isobel Fraser Home will only process personal information where we believe we have a lawful basis to do so.
The following information summarises the basis on which we process your personal information.
• You have given clear consent to the Isobel Fraser Home to process your personal data for a specific purpose (Article 6 (1) (a) of the GDPR 2018).
• The processing is necessary for a contract you have with Isobel Fraser Home (Article 6 (1) (b) of the GDPR 2018).
• Processing is necessary for Isobel Fraser Home to comply with its legal obligations (Article 6 (1) (c) of the GDPR 2018).
• Processing may be necessary to protect an individual’s life (Article 6 (1) (d) of the GDPR 2018).
• Processing is necessary for Isobel Fraser Home to meet its legitimate interest in running a care home for the elderly Article 6 (1) (f) of the GDPR 2018).
Additional Condition
Special category data is personal data which the GDPR says is more sensitive, and so needs more protection. Special category data includes data that Isobel Fraser Home processes in relation to health and religion. Under the GDPR an additional condition for processing Special Category Data is required. Isobel Fraser Home considers that it processes Special Category data on the following basis:
• The data subject has given explicit consent to the processing of those personal data for one or more specified purposes (Article 9 (2) (a) of the GDPR 2018).
• Processing is necessary for the provision of health or social care or treatment (Article 9 (2) (h) of the GDPR 2018.
How do we protect your personal information?
Isobel Fraser Home takes information security seriously. We have a suite of policies which describe how we safeguard personal information. These are available from the Manager at the address below. The measures include lockable storage, clean desk policy, password protection policy, data encryption and up-to-date security software to guard against unauthorised access, accidental loss, damage or destruction of personal information. Other measures include secure door access, access monitoring and restricted access to sensitive information.
What are your rights?
If at any point you wish to access your personal information or believe the information we process on you is incorrect you can request to see this information and have it corrected or deleted. You also have the right to restrict the processing of personal information and, in certain circumstances, you can object to the processing of your personal information. This is generally known as a Subject Access Request. We advise that you use the Isobel Fraser Home Subject Access Request Form but this is not essential.
If you wish to raise a complaint on how we have handled your personal information, you can contact us to have the matter investigated. Please contact us as follows:
The Manager
Isobel Fraser Home
4A Mayfield Road
Inverness
IV2 4AE
Tel 01463 230149
email: manager@isobelfraserhome.co.uk
If you are not satisfied with our response or believe we are processing your personal information not in accordance with the law you can complain to the Information Commissioner’s Office at www.ico.org.uk.