PRIVACY NOTICE

BACKGROUND

1.1 Ashill Lodge Care Limited(”Ashill”) with its registered office at The Limes, 2 Hyde lane, Danbury, Chelmsford CM3 4QX, and company registration number 10436264 collect and use certain Personal Data. Ashill is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.

1.2 At Ashill we respect the privacy of individuals and we are committed to keeping all your Personal Data secure. This Privacy Notice (“notice”) applies if you visit or are using a website operated by Ashill and governs the handling of Personal Data by Ashill in the course of carrying on commercial activities.

1.3 We use the following definitions in this Privacy Notice: “Ashill”, “we or “us” means Ashill Lodge Care Limited “Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Ashill (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Ashill or any other person in respect of an individual.

2. THE  SERVICES WE PROVIDE

2.1 This Privacy Notice concerns the following categories of information that we collect about you when providing the following  services (together, the “services”):

(A) Information we receive through our website ("Ashill Websites");

(B) Information we receive through our Service provision ("Ashill Services");

(C) Information we receive through our affiliated partners ("Ashill Partners").

(D) Information we receive through the regulators ad other advisory bodies (such as CQC, Norfolk Council)

3. THE TYPES OF PERSONAL DATA WE COLLECT

3.1 Many of the services offered by Ashill require us to obtain Personal Data about you in order to perform the services we have been engaged to provide. In relation to each of the services described at section 2.1 above, we will collect and process the following Personal Data about you:

• Information that you provide to Ashill. This includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):

           - basic Personal Data (such as first name; family name; job title; company name; company email address; business phone number; business address; city; postcode; country).

           - special category Personal Data(Such as about health; race or ethnic origins, or religion ) • Information that we collect or generate about you.                  This includes (by way of non-exhaustive list): - a file with your users records and contact history to be used for service provision purposes so that we may ensure that you are satisfied with the services which we have provided to you; and - contact information (such as email address, name, address, phone number).

• Information we obtain from other sources. 


Cookies - Ashill Website does not use cookies. Cookies are essentially a small amount of data which is transferred to and sometimes updated on your computer or other devices by our web servers.

4. HOW WE USE YOUR INFORMATION

4.1 Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

• for ongoing review and improvement of the information provided on Ashill Website to ensure they are user friendly and to prevent any potential disruptions or cyber-attacks;

• to understand your needs and interests;

• for the management and administration of our business; • to allow you to use and access the functionality provided by the Ashill Services;

• to assess your application for Ashill Services or employment, where applicable;

• to set up customers to use Ashill Services;

• to understand feedback on Ashill Services and to help provide more information on the use of those services quickly and easily;

• to communicate with you in order to provide you with services or information about Ashill services;

• in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or

• for the administration and maintenance of databases storing Personal Data. 


4.2 However we use Personal Data we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include:

• we need to do so in order to perform our contractual obligations;

• we have obtained your consent;

• we have legal and regulatory obligations that we have to discharge;

• we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;

• the use of your Personal Data as described is necessary for our legitimate business interests, such as:

 - allowing us to effectively and efficiently manage and administer the operation of our business;

    - maintaining compliance with internal policies and procedures;

    - monitoring the use of our copyrighted materials;

    - enabling quick and easy access to information on Ashill Products;

    - offering optimal, up-to-date security solutions for mobile devices and IT systems; and

    - obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.


4.3 We will take steps to ensure that the Personal Data is accessed only by employees of Ashill that have a need to do so for the purposes described in this Privacy Notice.


5. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

5.1 We may share your Personal Data within the Ashill for the purposes described above

5.2 We may also share your Personal Data outside of the Ashill Group for the following purposes:

• with other trusted businesses or persons for the purpose of processing personal data on our behalf for the above stated purposes;

• with our business partners. For example, this could include our partners from whom you or your company or your organisation purchased the Ashill service(s). Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;

• with third-party agents and contractors for the purposes of providing services to us (for example, Ashill’s temporary agency staff, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Notice;

• to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;

• if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and

• if we are acquired by a third-party, in which case the Personal Data held by us about you will be disclosed to the third-party buyer.


6. INTERNATIONAL TRANSFERS OF PERSONAL DATA

6.1 Ashill does not transfer your information outside the EEA;

6.2 If we do transfer your Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:

• the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data (Israel is an approved country);

• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;

• where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or

• in other circumstances the law may permit us to otherwise transfer your Personal Data outside Europe.


6.3 You can obtain more details of the protection given to your Personal Data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described in section 10 below.


7. HOW WE SAFEGUARD YOUR INFORMATION

7.1 We have extensive controls in place to maintain the security of our information and information systems. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees or approved persons.

7.2 As a condition of employment, Ashill employees are required to follow all applicable laws and regulations, including in relation to data protection law. Unauthorised use or disclosure of confidential client information by a Ashill employee is prohibited and may result in disciplinary measures.


8. HOW LONG WE KEEP YOUR PERSONAL DATA

8.1 How long we will hold your Personal Data for will vary and will be determined by the following criteria:

• the purpose for which we are using it – Ashill will need to keep the data for as long as is necessary for that purpose; and

• legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.


9. YOUR RIGHTS

9.1 In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;

• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;

• in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third-party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Ashill;

• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;

• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;

• the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and

• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us. 9.2 You can exercise your rights by contacting us using the details listed in section 10 below.


10. QUESTIONS AND CONCERNS

10.1 If you have any questions or concerns about Ashill’s handling of your Personal Data, or about this notice, please contact us using the following contact information:

Address: Ashill Lodge, The Lodge Care Home, Watton Road, IP25 7AQ

Email Address: manager@ashill-lodge.co.uk


We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulations