Crossways Care services Privacy policy.
Where we use the term “residents” in this Privacy Notice, we refer to residents in our residential care homes.

We recognise the privacy and security of personal information is of great importance to our residents, their families
and friends, our workers, and others such as GPs and all those involved in looking after the welfare of our residents.

We have provided this Privacy Notice to set out why we need to collect personal information relating to our residents,
families, friends, and representatives, how we use it and how we protect it.

We have appointed a Data Protection Officer who is responsible for overseeing questions relating to this Privacy
Notice. If you have any questions, please refer to the “How to Contact Us” section below.

Our privacy policy is governed by the principle of only collecting and using personal details when they help us provide
a better service to our residents and to meet our legitimate interests including to protect our residents and workers.

The personal information we refer to in this Privacy Notice includes information that can be used to identify you. Your
name and address are the main examples.

Set out below is the personal information we collect and the reasons why we need it.

 

Topics

How do we collect information from you
What types of information do we collect from you
What information do we get from other sources
Lawful basis for processing
How we use the information about you?
How we store, process, and protect your data
How long will we hold your personal data
Market research and feedback
Marketing
Access to your information and correction
Request Restriction of Processing
Automated Decision Making

How do we collect information from you?
We collect information about you when you enquire about our care services, use our website, and become a resident
in one of our care homes. We also collect information when you voluntarily complete customer surveys or provide
feedback about our services.

What types of information do we collect from you?
Personal data or personal information can be any information about an individual from which that person can be
identified. We may collect, use, store and transfer different types of personal data about you which we have grouped
together as follows:

When you enquire about our care services
 Personal information including your name, address, telephone numbers and email address.

When you use the Crossways website
 Any personal details you knowingly provide us with through forms or email, such as your name, address, telephone
numbers and email address. We use the information that you provide so we can respond to your requests and
communicate with you.

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 Your preferences and use of email updates, recorded by emails we send you (if you select to receive email updates)

 Your IP Address: this is a string of numbers unique to your computer that is recorded by our web server when you request
any page or component on the website. This information is used to measure your usage of the website.

Where you are resident in one of our residential care homes
 Personal details including your title, full name, maiden name, marital status, date of birth, gender, contact details including
address (billing address or correspondence address), telephone numbers, email addresses, contact details for next of kin,
your GP and other allied health professionals.

 Financial information including bank account information to enable payment of services.

 Transaction data including details of payments from you for the services we have provided.

 Information about your life, including social history, health and wellbeing, treatment, and care. This may also include
information about your marital status, ethnicity and sexual orientation and details of medical treatments.

 Notes and reports about your health and care provision including case assessments and medication provided.

 Compliments, complaints, accidents, and incidents information.

 Contributions to resident questionnaires and surveys.

Where you are the relative, next of kin, attorney, or deputy to one of our residents
 Personal details including title, full name, relationship to the resident, contact details including address, telephone numbers,
email addresses.

When you visit one of our Crossways care home
 Name of the visitor, purpose of their visit and car registration details if car parking was used.

 Information relating to the prevention and detection of crime and the safety of residents and workers.

What information do we get from other sources?
 We work closely with NHS Clinical Commissioning Groups (CCGs), local and health authorities, medical
professionals, and regulators to deliver our care services. We will receive information from them regarding your
health and care including admission details, care records and medical records.

 We also work with other companies who provide professional services, advertising, and marketing services.

Lawful basis for processing
We use the following lawful basis condition for processing your data as a resident in our care home:

 Article 6(1)(b) “…processing is necessary for the performance of a contract to which the data subject is party or
in order to take steps at the request of the data subject prior to entering into a contract…”

 Article 6(1)(e) “…processing is necessary for the performance of a task carried out in the public interest or in
the exercise of official authority vested in the controller….”

 Article 9(2)(h) “…processing is necessary for the purposes of preventive or occupational medicine, for the
assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care
or treatment or the management of health or social care systems and services on the basis of Union or Member
State law or pursuant to contract with a health professional and subject to the conditions and safeguards
referred to in paragraph 3…”

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How we use the information about you?
How we store, process, and protect your data

 We process your personal data to manage the services we provide you, to carry out our obligations arising from
any contracts entered into between us and you, to provide you with information or services you have requested
and to process payments and refunds.

 Your care record will contain detailed information about your health and well-being including illnesses, medical
appointments, and treatments. It will also contain details of your attorney, deputies, your close family and next
of kin. We will share these with medical and allied health professionals who have a legal and legitimate need to
use the information to support the care provided to you.

 We share information within the Crossways to provide necessary administrative and managerial support.

 We use either personal or anonymised data to review the performance of our care services as part of our
continuing work to improve our services and meet the needs of our residents.

 We may use your details to contact you about any changes to our care services.

 We may use your personal data to send you marketing information describing services that you may be
interested in where you have consented to receive this beforehand. You may opt out of receiving this
information at any time.

 We share information with NHS Clinical Commissioning Groups (CCGs), local and health authorities, medical
professionals and regulators regarding resident’s health and care including admission details, care records and
medical records.

 We use cookies on our website to collect information to enable us to better present and improve our services.
The “Cookies” section below provides further information.
We are required from time to time to provide specific information about you without you or your representative’s
consent. This may include:

 Reporting health or safety issues including infectious diseases
 Where there is a legal or statutory requirement, court order or public authority instructs us to do so
 Supporting police investigations, professional conduct hearings and safeguarding investigations in the public
interest.

In exceptional circumstances, we may be required to share information without your or your representative’s consent.
Circumstances may include:

 Where a serious crime or fraud has been committed.
 If there is a serious risk to the public, resident, or employees.
 Where there is a need to protect children or vulnerable adults who are not able to decide if their personal data
should be shared

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How we store, process, and protect your data

 We take the privacy and security of your personal data very seriously. We ensure we handle your data with the
highest level of care by having clear internal policies and procedures, physical security to our premises and IT
security technologies to prevent the unauthorised access, damage, and loss of your data.

 The personal data that we collect from you is only stored inside the European Economic Area (EEA), therefore
ensuring we achieve the maximum privacy and security in line with UK Data Protection Laws.

 Credit card payments are processed securely via our third-party payment processing partner, who we have
vetted and who has agreed to provide a level of data protection no less than ours.

How long will we hold your personal data?
 We will only keep your information for as long as necessary to fulfil the purposes we collected it for, including
satisfying any legal, contractual, or reporting requirements. How long we keep the data for is determined by law
and is largely determined by necessity. Once your information is no longer required it will be securely
destroyed.

 You can ask us to delete your data where retaining it is no longer necessary.

 Whilst at all times compliant with legislation and acting reasonably, we reserve the right to judge what
information we must continue to hold to be able to fulfil our legal and contractual obligations to you.

 We may anonymise your personal data (so that you can no longer be identified) for research and analysis
purposes in which case we may use this information indefinitely without further notice to you.

 Where we process data based solely on your consent, you have the right to withdraw that consent at any time.

Market research and feedback
 We are committed to protecting the privacy of all persons’ personal information we collect for research
purposes. This covers all research participant data housed within Crossways and made available to market
research partner organisations. Any third party that receives personal information is obliged to follow all of the
same privacy protection regulations as Crossways.

 All responses to our research are completely confidential. We collect data in our studies for research purposes
only, and our use of that information will be limited to that purpose. Research participant answers will not be
used by any entity as an aid for sales or marketing activities unless permission has been expressly granted by
research participants.

 Research participation is voluntary, and participants always can decline involvement or to "opt out" of the
research after agreeing to participate. We do not collect personal information without research participant
consent.

 At their request, we give research participants access to the personal information we have collected about
them. We correct any information that is inaccurate or incomplete, change their consent status, or have their
personal information deleted.

Marketing
 We would like to send you information about the services we provide which may be of interest to you.

 You have a right at any time to request that we stop contacting you for marketing purposes or sharing your
information.

 If you have recently contacted us regarding our services or are an existing customer or resident, we may
contact you to ask for your consent to continue sending you marketing information. If you no longer wish to be
contacted for marketing purposes, please contact us at sandra@crosswaystheboulevard.co.uk.

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Access to your information and correction
 You have the right to request a copy of the information that we hold about you. If you would like a copy of some
or all your personal information, please email or write to us at the address set out in the “How to Contact Us”
section below.

 We try to respond to all legitimate requests within one month. It may take us longer if your request is
particularly complex or you have made several requests. In which case, we will notify you and keep you
updated.

 You will not have to pay a fee to access your personal data and you are entitled to receive a copy of your
personal data within one calendar month of receipt of your request and once we have verified your identity.

 We want to make sure that your personal information is accurate and up to date. You may ask us to correct or
remove information you think is inaccurate.

 We may ask for proof of identity before we share your personal data with you or your representative.

Request restriction of processing
You have the right to request us to suspend the processing of your personal data where:

 you want us to establish the data’s accuracy,
 where our use might be unlawful, but you do not want us to erase it,
 you need us to hold the data even if we no longer require it as you need it returned to establish and exercise
any legal claims or.
 you have objected to our use of your data, but you need to verify whether we can lawfully use it.

If possible, we will inform any third parties to whom your data has been disclosed of your requirement.

Automated decision making
 You have the right not to be subject to decisions made solely on automated data processing if the decisions
have legal impact or significantly affects you.

 Several our care assessment systems employ a scoring system to provide an indication of the care delivery
that may be required. However, in all cases, human intervention is required when deciding on the care to be
provided.