We value your trust and respect your privacy. That’s why we’re committed to total transparency in relation to the data we collect from you when you sign up to and use ElderFlourish, and how we store and use this data.
Who we are?
ElderFlourish is a subscription-only online resource providing activity content and materials for use in care homes. ElderFlourish is the sole Data Controller. ElderFlourish’s appointed Data Control Officer is Sarah Fardy, who can be contacted via firstname.lastname@example.org, or by writing to us at 8 The Driftway, Shipston-On-Stour, Warwickshire, CV36 4QH.
What information do we collect?
Personal data, or personal information, means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymised data).
Personal information we collect may include but is not limited to the names of individuals, corporations and premises, head office and premises addresses and telephone numbers, email addresses of individuals and departments within those corporations and premises, email communications, user names, passwords and account activity data.
Some of this data is collected when you provide the same during sign-up to our Free Two-Week Trial to our Premium Content Package through the ElderFlourish website; this and additional data is submitted by yourselves when you subscribe through our administrative team to our Basic or Premium Packages.
We will not require you to transmit any financial, personal or sensitive data to us; nor will we store any such data.
We may use your IP address to gather broad demographic information. Our site may log IP addresses and browser types for systems administration purposes and these logs will be analysed to constantly improve the value of the materials available on the site.
Your requirement to provide personal information
We will require certain information in order to set up your account. Failure to provide the same may result in delays in the set-up of your account. Should there be any change to your personal details in the future (i.e. change of email address) you are asked to notify us promptly. This will ensure we maintain accurate personal details and remain able to provide continuity of service. Failure to do so may result in the ElderFlourish website becoming temporarily inaccessible to you.
How do we use personal information?
We will only use your information for the following purposes:
- the set-up and administration of your ElderFlourish account;
- to personalise your user experience and deliver bespoke content;
- communications regarding content drops and other ElderFlourish events;
- seeking customer satisfaction feedback (through polls, surveys, etc…) to further develop and improve our service;
- to respond to your comments, questions and feedback;
- to notify you of changes in service or maintenance to the website;
- to advise you of unauthorised logins to your account.
What legal basis do we have for processing your personal data?
We only collect and store data with your consent. If you decide that you no longer wish for ElderFlourish to be in possession of such data, please do contact Sarah Fardy via email@example.com or by writing to 8 The Driftway, Shipston-On-Stour, Warwickshire, CV36 4QH, and all your data will be immediately removed from our systems. You will of course retain the right to register at a future time with a new account.
When do we share personal data?
ElderFlourish treats all personal data confidentially and we would never disclose or share it without your express permission.
It is possible that we might contact you to request permission to feature stories, images, audio and/or video featuring your service users, staff and/or premises; in the event that you agree, we would ensure that all appropriate media consents are obtained beforehand, and would only share details with your explicit permission.
How do we secure personal data?
ElderFlourish will take all steps reasonably necessary including policies, procedures and security features, to ensure that your data is treated securely and protected from unauthorised and unlawful access and/or use, and in accordance with this notice. These include:
- not sharing your data with any third parties;
- only storing such data as is necessary to set up and service your account;
- restricting access to personal information through the use of secure passwords and protections;
- conducting privacy impact assessments in accordance with GDPR and the UK DPA, and in line with ElderFlourish business policies;
- training all staff on data security.
Unfortunately, the transmission of information via the internet is not completely secure and, although we will do our best to protect your personal data transmitted to us via the internet, we cannot guarantee the security of your data transmitted to our website from your device. Any transmission is at your own risk.
How long do we keep your personal data for?
We will only retain your personal information 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. Data will be deleted securely and permanently.
Your rights in relation to personal data
Data protection laws grant you, as a Data Subject, certain ‘information rights’, which are summarised below:
Right of access – You have the right to obtain a copy of information we hold about you.
Right of rectification or erasure – If you feel that any data that we hold about you is inaccurate, you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where you can demonstrate that the data we hold is no longer needed by us, or if you withdraw the consent upon which our processing is based, or if you feel that we are unlawfully processing your data. Please note that we may be entitled to retain your personal data despite your request, for example if we are under a separate legal obligation to retain it. Your right of rectification and erasure extends to anyone we have disclosed your personal information to and we will take all reasonable steps to inform those with whom we have shared their data about your request for erasure.
Right to restriction of processing – You have a right to request that we refrain from processing your data where you contest its accuracy, or the processing is unlawful and you have opposed its erasure, or where we do not need to hold your data any longer but you need us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal data.
Right to Portability – You have a right to receive any personal data that you have provided to us in order to transfer it onto another data controller where the processing is based on consent and is carried out by automated means. This is called a data portability request.
Right to Object – You have a right to object to our processing your personal data where the basis of the processing is our legitimate interests including but not limited to direct marketing and profiling.
Right to Withdraw Consent – You have the right to withdraw your consent for the processing of your personal data where the processing is based on consent.
Right of Complaint – You also have the right to lodge a complaint about any aspect of how we are handling your data with the UK Information Commissioner’s Office, which can be contacted at http://www.ico.org.uk.
Marketing Communications – To stop receiving marketing (such as email, postal or telemarketing), then please contact us using the contact us details below.
How to contact us?
Should you have questions or concerns about our privacy practices or your personal information, or if they wish to update your information or file a complaint, please contact Sarah Fardy via firstname.lastname@example.org, or by writing to us at 8 The Driftway, Shipston-On-Stour, Warwickshire, CV36 4QH.
We may collect information about your computer including, where available, your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive.
If you have consented to receiving them, our system will issue cookies when you log on to the Site.
Linking to other websites/third party content
The site contains links to other websites. The Group is not responsible for the privacy practices or the content of such websites.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.