Data we hold about you will be processed fairly and lawfully. It will be used only for the purposes set out below:
- to provide you with updates relating to your enquiry with us or application through us
- to provide you with occasional information about other services which we offer that may be useful to you
- to invite you to any occasional events we may host
- in the event that you have retained us, to provide you with information relating to matters we are handling for you, or otherwise communicate with you about our business arrangements
We will not pass data about you to any third party other than as set out below, and we will only process it in the United Kingdom.
Usually, we will have data about you because you have made an enquiry about our services or because someone has made an enquiry about our services on your behalf.
You may wish us to amend or delete data we hold, or to stop using it for one or more of the purposes set out. In this event, or if you have any other enquiry relating to your data, please send an e-mail to firstname.lastname@example.org with the subject “Data Protection Request” stating your full name and your request. Alternatively you can telephone our Data Protection Officer (01384 241292) or write to our Principal Office:
Unit 3, 1 Castle Court,
West Midlands, DY1 4RD
If you have supplied us with information via a contact form on our web site, you can view, edit, or remove it using the contact details provided above.
Gordon Moody Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data as our client and when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice covers the following:
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Gordon Moody collects and processes your personal data, including any data you may provide to us in your dealings with us whether through this website, signing up to our services or purchasing a product or service through us.
This website is not intended for children and we do not knowingly collect data relating to children, save as stated below.
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 (including our Terms of Business where we are providing you with a service) 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. This privacy notice supplements the other notices and is not intended to override them.
Gordon Moody Limited is a Charity and Limited Company registered in England. Gordon Moody is the controller and responsible for your personal data (collectively referred to as “Gordon Moody”, “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Controller in writing using the details set out below.
The Data Controller
Unit 3, 1 Castle Court,
West Midlands, DY1 4RD
Telephone: 01384 241292
You have the right to make a complaint at any time 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.
Changes to the privacy notice and your duty to inform us of changes
This privacy notice sets out most of your data protection rights under new laws introduced in 2018. 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.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, 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 follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title and date of birth.
- Contact Data includes billing address, email addresses and telephone numbers.
- Financial Data includes bank account and payment card details, financial data obtained from third party organisations such as credit reference agencies.
- Transaction Data includes details about payments to and from you and other details of products or services you have purchased from us.
- Technical Data includes for use of our website, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do collect 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) for purposes of treatment (such as when you apply for a residential place with us).
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with appropriate treatment and/or support). In this case, we may have to cancel a service we provide to you but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- meet with our representatives;
- apply to receive our services and/or support;
- complete an enquiry form on our website;
- subscribe to our service or publications;
- request marketing material to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EEA;
- advertising networks based inside the EEA; and
- search information providers based inside the EEA.
- Contact, Financial and Transaction Data from other professionals with whom we work on your financial matters, providers of technical, payment and delivery services based inside the EEA.
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EEA.
4. HOW WE USE YOUR PERSONAL DATA
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 updates to your care and/or treatment plans or changes to our terms, conditions and policies. Because this information is important to your interaction with Priory, 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.
We may use your personal information to test our computer systems such as the software we use to store your health, social, care and education records to improve our services. If you do not wish for your information to be used for these purposes, you can let us know.
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.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA) unless this is because you are located outside of the EEA and we need to communicate with you.
7. DATA SECURITY
We have 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.
8. DATA RETENTION
How long will you use my personal data for?
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.
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.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) normally for six years after they cease being clients for statutory purposes. Where we hold deeds or document on your behalf, we have to keep records for such time as we hold those deeds or documents.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the details provided above.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
- Service providers acting as processors based EEA who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including financial advisers, lawyers, bankers, auditors and insurers based in EEA who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, National Crime Agency, Serious Fraud Office, regulators and other authorities in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
- 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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Unit 3, 1 Castle Court,
West Midlands, DY1 4RD
Telephone: 01384 241292