Current as of: 9 May 2025

Who We Are

Down Hall, part of Down Hall Care Ltd, (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

Down Hall Care Ltd registered office is at AMP House, Dingwall Rd, Croydon CR0 2LX and we are a company registered in England and Wales under company number 11535163. Down Hall is the ‘data controller’ and its staff ‘data processors’. Our designated Data Protection Officer/Appointed Person is our Home Manager who can be contacted at Down Hall Residential Home, Down Hall, Down Hall Rd, Bradwell-on-Sea, CM0 7QP.

Information That We Collect

Down Hall processes personal information to meet our legal, statutory and contractual obligations and to provide a service. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice. ‘Personal’ and special categories of personal data’ is collected to ensure we have the required information to carry out our service.

The personal data that we collect includes:

• Name
• Date of Birth
• Home Address
• Personal Email
• Business Email
• Home Telephone Number
• Mobile Telephone Number
• National Insurance Number
• Passport Number
• Driver’s License Number
• Special Category Data (i.e. health/medical information, details about religion, sexuality etc)

We collect information in the following ways:

• In person
• Residential & employment Contracts/Care Plans
• Employment CV’s
• Via ECC/Social Services

How We Use Your Personal Data

Down Hall takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with newsletters/email updates, you are free to withdraw this consent at any time.

We collect and use your personal data for the following purposes:

• We collect your personal data in the performance of a contract and to provide a service
• We collect and store your personal data as part of our legal obligation for business accounting and tax purposes
• We will occasionally send you promotional information where we have assessed that it is beneficial to you as a resident/relative/staff member and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests

Your Rights

You have the right to access any personal information that Down Hall processes about you and to request information about:

• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to correct it as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us; to exercise your data portability rights, and to be informed about any automated decision-making we may use.

Down Hall do not carry out any automated decision-making.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure. Please contact our Manager if you wish to ‘opt-out’:

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. Down Hall uses third-parties to provide the below services; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

Smooth Group Limited

To help improve our customer experience and manage enquiries effectively, we may share the information you provide (by phone or email) with our trusted partner, Smooth Group Limited. When appointed to do so, Smooth Group may support us by: Monitoring and improving enquiry follow-up; Carrying out quality checks and mystery shopping; Gathering feedback from recent enquiries; Assisting with enquiry handling and communication. Calls may also be recorded for training and monitoring purposes. Smooth Group acts as a data processor and will only process your information in accordance with our instructions, solely for the above purposes. They will securely delete your data when it is no longer required.

Dengie Medical Partnership

Provide

Templemans – Opticians

Community Dental Services (CDS)

Safeguarding Measures

Down Hall takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:

• Locked & Restricted access
• IT authentication
• Firewalls
• Anti-virus/malware

Consequences of Not Providing Your Data

You are not obligated to provide your personal information to Down Hall, however, as this information is required for us to provide you with our services, we will not be able to offer some/all our services without it or in the case of employment, enable us to employ you.

How Long We Keep Your Data

Down Hall only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. Client records are retained for 6 years after ceasing to be a client; staff records, 6 years after ceasing to be a member of staff; Unsuccessful staff application forms, 6 months after vacancy closing date; Volunteer records, 6 years after ceasing to be a volunteer; Timesheets and other financial documents, 7 years.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Consent for Personal & Special Categories Data

Owing to the services that we provide, Down Hall sometimes needs to process sensitive personal information (known as special category data) about you, to health professionals and organisations. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.

Where we rely on your consent for processing special category data, we will obtain your explicit consent through a signature. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.

Consent for Photographs

Occasionally, we may take photographs of residents/staff/visitors at Down Hall. We use these images as part of our displays and sometimes in our printed publications and newsletters. We may also wish to use them on our website. If we use photographs of individuals, it may be relevant/desired to use the name (first name only) of that individual in the accompanying text or photo.

From time to time, our home may be visited by the media who will take photographs or film footage of an event. Individuals may appear in these images, which will sometimes be published in local or national newspapers, or on approved websites.

To comply with the GDPR regulations, we need your permission before we can photograph or make any recordings of you or your relative. You have the right to modify or withdraw your consent at any time by contacting our Manager directly. Consent is applicable with the following conditions of use:

• The consent form is valid indefinitely from the date signed
• Historic photographs will remain on our website, unless we are contacted and asked to remove them (of which you have the right to do so)
• We will not use the personal details or full names (which means first name and surname) of the individual in a photographic image or video, on our website, in our brochure or in any of our other printed publications
• We will only use images of individuals who are suitably dressed, to reduce the risk of such images being used inappropriately
• Websites and social media platforms can be viewed throughout the world and not just in the United Kingdom & Europe where EU law applies

Lodging A Complaint

Down Hall only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however, you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with our management or the supervisory authority.

Down Hall Residential Home

ICO

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