Surrey Choices Ltd Privacy Statement

This Privacy Statement explains what personal data and other information is collected by us, Surrey Choices Ltd (“Surrey Choices”, “we”, “our”, “us”), as part of our activities, and how we use or process that information.

We are committed to complying with the latest Data Protection Act and the EU General Data Protection Regulation (EU) 2016/679. These are referred to in this Privacy Statement as the “data protection legislation”.

The data protection legislation give you various rights regarding the way in which we store and use your information. These are set out below in section 1.1 Your rights under the data protection legislation.

For the purpose of the data protection legislation, the data controller is:

Surrey Choices Limited

Fernleigh Activity Centre,
Fernleigh Close,
Walton-On-Thames,
Surrey, England.
KT12 1RD

ICO Registration Number: ZA066209

Our Data Protection Officer can be contacted on dpo@surreychoices.com or 07885 367851.

This Statement may change at any time so please review it from time to time.

Surrey Choices, April 2018

To make it easier for you to review those parts of the Privacy Statement which apply to you, we have divided up the document into sections.

Section 1: General

Section 2: For our customers

Section 3: For our employees, Board members and other associates

Section 4: For job applicants

Section 1: General

Laws apply to Surrey Choices’ use of anyone’s personal information and everyone has rights regarding how their personal information is handled. We have published this Statement to tell you:

  • What information we may collect about you
  • How we store your personal information
  • What we use your personal information for
  • Who (if anyone) we may pass it on to and how they use it, and
  • Your rights as an individual

In this Privacy Statement, when we use the following words or abbreviations they will have the following meanings:

Word or abbreviation Meaning
Board member or members Member/s of the Surrey Choices Board of Directors
Customer An individual who is a recipient of Surrey Choices services
Employee or employees Any or all people employed whether full time or part time, permanent, temporary or fixed term contract. This Statement also applies to
Intranet The internal Surrey Choices system
Member or members Member/s of any group member boards, committees or panels (e.g. Care Quality Forum) and includes (but is not limited to) other people that may from time to time be involved with the operation of the organisation such as consultants, volunteers, people on work placements, interns etc.
Personal data or personal information Information from which the identity of a living individual may be determined. Examples of Personal Data include (but are not limited to) first and last name, home or other physical address, email address, phone number, work history and other contact information.
Sensitive or special category personal data or information This is defined as personal data consisting of information about one or more of:

  • Racial or ethnic origin
  • Political opinion
  • Religious or philosophical beliefs
  • Trade union membership
  • Genetic or biometric data
  • Physical or mental health or condition
  • Sex life or sexual orientation
  • Criminal convictions and offences as well as alleged offences
Visitor An individual visiting our website
Website www.surreychoices.com
  1. Your rights under data protection legislation

Surrey Choices will ensure that the rights of people about whom information is held can be fully exercised under data protection legislation. These rights are:

  • The right to information – under this right we must provide information to you and demonstrate that we collect and process your personal data fairly. We do this mainly through the Surrey Choices Privacy Statement.
  • Right to access – you have the right to obtain confirmation that your data is being processed; access to your personal data; and other supplementary information
  • The right to rectification – you have the right to have information about you corrected and / or to challenge us about the accuracy of the information we hold
  • Right to erasure – the right to erasure (also known as the right to be forgotten) states that the you can have personal data erased under a number of specific circumstances
  • Right to restrict processing – you are allowed, under certain specific circumstances, to prevent us from conducting specific processing of your data
  • Right to data portability – you can request a copy of the information you have provided to us in a useful electronic format that another organisation could use
  • Right to object – you can object to us processing your data if we cannot demonstrate legitimate grounds for that processing
  • Right to withdraw consent – you have the right in certain circumstances to withdraw your consent for us to process your personal information
  • Right to appropriate decision making – you have the right not to be subject to a decision based solely on automated processing; Surrey Choices do not use this form of automated processing
  • Right to notification; it is our duty to notify any third parties that may process our data if you exercise your rights to rectify, restrict or erase your data
  • Right to make a complaint to the Information Commissioner’s Office (ICO)

Should you wish to exercise any of your rights, please contact us using the details above.

    1. Retention of information

We retain your information only as long as we need it. We base our record keeping on the Surrey Choices Retention Schedule. If you have a specific query regarding how long we retain your information please contact us using the details above.

    1. Consent

Where we have requested your specific consent for processing your information (for marketing for example), you have the right to withdraw that consent at any time by contacting us using the details above. You may unsubscribe from marketing emails by following the instructions given at the bottom of the email.

    1. Complaints

If you are dissatisfied with the way we have handled your personal data you should contact us using the details above so that we can investigate in the first instance. Following our response to you, if you are still dissatisfied then you have the right to complain to the Information commissioner’s Office (ICO).

Section 2: For our customers

2.1 Information we may collect from you 

We may collect the following personal information about you:

When you first come to see us 

  • Your name and contact details for use across Surrey Choices and by our suppliers and partners
  • Detailed personal information (including sensitive personal information) such as age, sex, date of birth, ethnicity, particular needs or preferences so that we can understand our customers and their needs better

Information we may collect from you 

We may collect the following personal information about you in person, online, in writing or over the phone:

When you first come to see us or otherwise contact us

  • Your name and contact details for use across Surrey Choices and by our suppliers and partners
  • Detailed personal information (including sensitive personal information) such as age, sex, date of birth, ethnicity, particular needs or preferences so that we can understand you and your needs better
  • Your care needs, so we can ensure our services suit you
  • Where relevant, bank details and direct debit information to make payments such as service charges (we only exchange details with the account holder and the third party who manages our Direct Debits)

NB If you pay us using your payment card we do not store the details, for your added security (and we only exchange the details with the person we believe to be the card holder or permitted third parties)

  • Benefit information to verify your circumstances
  • Income and earning information related to employment services we provide
  • Information that you provide during the referral process
  • Information that you provide to other members of staff
  • Feedback from our contractors, about their appointments with you
  • Voice and video recordings for safety, crime reduction and quality management

To enhance your experience with Surrey Choices 

  • You can give us details of your friends, relatives or neighbours who you trust to contact us on your behalf e.g. to arrange one of our services for you
  • You can give our details to anyone to whom you have given a Power of Attorney so they can contact us on your behalf
  • With your consent, we can use your name, photo, video or story for marketing materials, advertising or press releases or use by the media
  • We will use any complaints about our service or other individuals, or accidents or incidents, to improve Surrey Choices services
  • We will use your comments about services, from us or our suppliers, to improve Surrey Choices services

If you ask for additional services

  • If you ask us for other care and support requirements we will hold detailed information about your needs and your family’s needs
  • We will hold records of payments for the services
  • If you use any of our training and/or employment projects we will ask about your employment and learning history
  • If you access any of our other involvement and support projects we will ask you for personal information relevant to those projects

In addition 

  • We may hold information about your history. For example, regarding offences, if we need it to look after our colleagues, business or anyone else

The legal basis’ we rely on for using personal information in these ways are as follows:

  • Processing is necessary for the performance of a contract;
  • Processing is necessary for the compliance with a legal obligation;
  • Processing is necessary for our legitimate interests; or
  • Consent has been obtained

We will receive information from your service provider and we will exchange the information we need in order to provide a service to you on their behalf

We may receive management information about the accounts we manage

We may get the information, or related information, from you or our partner organisations (see below), other people, our colleagues or public information sources including the Disclosure and Barring Service (formerly the Criminal Records Bureau).

We may also record factual information whenever you contact us or use our services, and of other actions

2.2 Where we store your personal information 

We are committed to holding your personal information securely. This means only those of our colleagues and contractors that need to see it have access.

If we can store your personal information solely on computers we will, however there will be cases where we have paper copies instead, or as well.

Our computer system is at our offices but we do use mobile devices outside our offices if they are secure and under our control.

Sometimes we also use computers which are owned or managed by our suppliers, if the computers are secure and comply with our security requirements and all relevant information management legislation.

Occasionally our processors or sub-processors may process information outside the European Economic Area (EEA). Where this happens we will ensure that the processor is compliant with the data protection legislation including transfer agreements that incorporate approved model clauses.

2.3 What we use your personal information for 

  • As above, and generally for providing our services for you
  • Keeping in touch with our customers, understanding your needs and preferences, inviting you to events, offering and booking appointments with you and seeking your opinion on our services.
  • Telling you about changes to Surrey Choices and its services
  • Meeting your service needs and requirements including (but not limited to) ensuring you have access to the right equipment while accessing our services, that we can manage any medication requirements and fulfilling any dietary requirements.
  • Managing payments from you to your or on your account, and for accounting purposes
  • Providing additional services, where available, at your request including skills training, adaptations and every day support services
  • Prevention, detection and prosecution of crime
  • Quality management
  • Informing our staff, contractors or others (as appropriate) about past incidents (for example, anti-social behaviour), for their protection, in line with our policies
  • Meeting our legal obligations including our funders or regulators
  • Us or your other suppliers exercising legal rights, including under contract with you
  • Other purposes. We may anonymise your information so that it cannot be linked to you. In that case we may use the data for any purpose

2.4 Who else we may pass on your information to 

Normally, only Surrey Choices will be able to access your personal information. However there may be times when we disclose your details to others, and we will comply with data protection legislation when disclosing this information. Where it is required or necessary we may share information with:

  • Commissioners and commissioning organisations who are purchasing services from us on your behalf
  • Our suppliers who enable us to provide our services to you, or who provide services on our behalf including (but not limited to)
  • Contractors. For example IT providers who own or manage the computers, phones or systems we use
  • Banks. For example to carry out payments through a secure system
  • Companies that assist us in printing and mailing out our letters, leaflets and newsletters
  • Additional staff resources, such as consultants or agency staff
  • Our professional advisors and providers of financial services
  • Our partner organisations whose purposes dovetail with ours including (but not limited to)
  • Training providers or learning institutions
  • Other care providers
  • External assistance where you have agreed to the referral, for example to do with money problems or domestic abuse
  • Local authorities and government departments who provide relevant services for you, including benefits
  • The police, fire services, health authorities or medical staff who provide services for you
  • Others who may request information from us for their own purposes
  • For crime prevention or detection, risk assessment, resolution of complaints or other issues
  • Local authorities, safeguarding boards, regulators, government departments and other public authorities
  • The police, fire service, health authorities or medical practitioners

We may sometimes be obliged to disclose your personal data by law such as by a regulator with appropriate power (for example the Care Quality Commission) or court order. Information held by public bodies can be subject to Freedom of Information legislation.

We do not give anyone else access to your information, in return for payment, for their marketing or commercial purposes.

We will not share your personal information with anyone who claims to represent you unless we are satisfied that you have appointed them or they act in some recognised official capacity. There may be a delay to us dealing with requests whilst we confirm the person’s identity, or check that we have your approval to deal with them.

2.5 Social media 

We may get your information from social media, whether on our own accounts or elsewhere. Where you use our own website or social media you grant us an irrevocable, royalty-free, non-exclusive licence, and give us your consent, to copy, use and reproduce any of your contributions for any purpose.

Where you make a contribution to any social media (whether on our own accounts or elsewhere) we may use that information for any of the purposes stated in this Privacy Statement.

Where a contribution to any social media (whether on our own accounts or elsewhere) constitutes a breach of Surrey Choices terms and conditions, agreements, or laws that apply, we may take the following actions:

  • Start legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.
  • Take further legal action against you (including, but not limited to, proceedings for a breach of any contract you may have with us).
  • Report you and disclose such information to law enforcement authorities in any jurisdiction as we reasonably feel is necessary.
  • Report you and disclose such information to any local government or statutory body in the United Kingdom as we reasonably feel is necessary.
  • Report you and disclose such information as we reasonably feel is necessary to the account administrator and/or take action against you through the account administrator’s procedures to enforce the policies and terms and conditions that apply between you and the account administrator and/or between you and us.

The responses described in this Privacy Statement are not limited, and we may take any other action we reasonably deem appropriate and we are not obliged to take any action.

Section 3: For our employees, Board members and other associates

3.1 Information we may collect from you

We may collect the following personal information about you:

When you first come into contact with us

  • Your name and contact details for use across Surrey Choices and by our partners
  • Sensitive personal information such as age, sex, date of birth, ethnicity, particular needs or preferences so that we can meet your needs and those of employment legislation

For employment and/or board/committee/panel membership purposes

  • Attendance, equality and diversity, disciplinary, pension, benefits, references, employee services, training, welfare and sickness absence and any other information necessary to fulfil obligations of both employer and employee (or board/committee/panel member) as given by law and/or contract of employment and/or contract of engagement
  • Next of kin information so that we have contact details in case of emergency
  • Bank details to make salary and any other payments to you
  • National Insurance (NI) details to fulfil obligations relating to tax and NI payments and deductions
  • Information that you provide through the application process
  • Information that you provide to other employees of Surrey Choices group of companies
  • Coaching and roadmap information
  • Photographs, voice and/or video recordings, written stories etc. to be used for example in ID cards, for company promotion and publicity, and for safety, crime reduction and quality management

If you ask for additional Surrey Choices services

  • If you ask us for care and support requirements we will hold detailed information about your needs and your family’s needs (where appropriate)
  • We will hold records of any payments for services where a charge may be made, for example a cycle to work scheme

In addition

  • We may hold information about your history such as credit or offences, if we need it to look after our colleagues, organisation or anyone else

We may obtain the information, or related information, from you or our partner organisations (see below), our colleagues or public information sources including credit reference agencies or the Disclosure and Barring Service (formerly the Criminal Records Bureau).

We may also record factual information from time to time, and any action we take, so we have a record of what happened.

The legal basis’ we rely on for using personal information in these ways are as follows:

  • Processing is necessary for the performance of a contract;
  • Processing is necessary for the compliance with a legal obligation;
  • Processing is necessary for our legitimate interests; or
  • Consent has been obtained

Failure to provide the personal information requested may result in us being unable to fulfil our obligations to you. For example, if you failed to provide your bank details we would be unable to pay you.

3.2 Where we store your personal information

We are committed to holding your personal information securely. This means only those of our colleagues and partners that need to see it have access.

If we can store your personal information solely on computers we will, however there will be cases where we have paper copies instead, or as well.

Occasionally our processors or sub-processors may process information outside the European Economic Area (EEA). Where this happens we will ensure that the processor is compliant with the data protection legislation including transfer agreements that incorporate approved model clauses.

3.3 What we use your personal information for

  • As above, and generally for providing our services for you
  • Data sharing between departments within Surrey Choices
  • Keeping in touch with our employees, understanding your needs and preferences, inviting you to events and offering and booking appointments with you
  • Telling you about changes to Surrey Choices and its services
  • Meeting your employment needs and requirements
  • Managing payments to you and for accounting purposes
  • Providing additional services, where available, at your request including skills training, adaptations and every day support services
  • Prevention, detection and prosecution of crime
  • Quality management
  • Meeting our legal obligations including those of Her Majesty’s Revenue and Customs (HMRC) and other regulators
  • Other purposes – we may anonymise your information so that it cannot be linked to you. In this case we may use the data for any purpose

3.4 Who else we may pass on your information to

Normally only Surrey Choices will be able to access your personal information, however there may be times when we disclose your details to others, and we will comply with data protection legislation when disclosing this information. Where it is required or necessary we may share information with:

  • Organisations that are within the Surrey Choices group of companies
  • Our suppliers who enable us to provide our services to you, or who provide services on our behalf:
  • Banks, for example to carry out payments through a secure system
  • Companies that assist us in mailing out our letters, leaflets and newsletters
  • Driver management service providers
  • Health service providers
  • Lone worker protection service providers
  • Vehicle tracking service providers
  • IT providers who own or manage the computers, phones or systems we use
  • Lease car providers
  • Our professional advisors and providers of financial services
  • Payroll service providers
  • Pension service providers
  • Shopping discount providers
  • Our partner organisations whose purposes dovetail with ours:
  • Training providers or learning institutions
  • Local authorities and government departments who provide relevant services
  • The police, fire services, health authorities or medical staff who provide services
  • Others who may request information from us for their own purposes:
  • Utility companies
  • Debt collection agencies acting for others
  • For crime prevention or detection, risk assessment, resolution of complaints or other issues
  • Local authorities, safeguarding boards, regulators, government departments and other public authorities, such as for preventing payment errors or fraud
  • The police, fire service, health authorities or medical practitioners.

We may sometimes be obliged to disclose your personal data by law such as by a regulator with appropriate power (such as the Care Quality Commission), or by court order. Information held by public bodies can be subject to Freedom of Information legislation.

We do not sell your information to others for marketing or commercial purposes.

We will not share your personal information with anyone who claims to represent you unless we are satisfied that you have appointed them or they act in some recognised official capacity. There may be a delay with us dealing with such requests whilst we confirm identity or check that we have your approval to deal with them.

3.5 Social media

We may obtain your information from social media, whether on our own accounts or elsewhere. Where you use our own website or social media you grant us an irrevocable, royalty-free, non-exclusive licence, and give us your consent, to copy, use and reproduce any of your contributions for any purpose.

Where you make a contribution to any social media (whether on our own accounts or elsewhere) that relates in any way to any of the Surrey Choices group of companies, your past or current employment here, or to the field of housing, we may use that information for any of the purposes stated in this Privacy Statement.

Where a contribution to any social media (whether on our own accounts or elsewhere) constitutes a breach of Surrey Choices Code of Conduct, policy, contract, terms and conditions or laws that apply, we may take the following actions:

  • Issue you with a warning
  • Start legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach
  • Take further legal action against you (including, but not limited to, proceedings for a breach of your contract of employment or other contract you may have with us)
  • Report you and disclose such information to law enforcement authorities in any jurisdiction as we reasonably feel is necessary
  • Report you and disclose such information to any local government or statutory body in the United Kingdom as we reasonably feel is necessary
  • Report you and disclose such information as we reasonably feel is necessary to the site administrator and/or take action against you through the site administrator’s procedures to enforce the policies and terms and conditions that apply between you and the site administrator and/or between you and us

The responses described in this Privacy Statement are not limited, and we may take any other action we reasonably deem appropriate and we are not obliged to take any action.

Section 4: For job applicants

4.1 Information we may collect from you

We may collect the following personal information about you:

When you first come into contact with us

  • Your name and contact details for use across Surrey Choices and by our partners
  • Sensitive personal information such as age, sex, date of birth, ethnicity, particular needs or preferences so that we can meet your needs and those of employment legislation
  • Your application details in order to process your application for employment

If you ask for additional Surrey Choices services

  • If you ask us for care and support requirements we will hold detailed information about your needs (where appropriate)

In addition

  • If you make a complaint we will keep the details separate from our other information about you

We may obtain the information, or related information, from you or our partner organisations (see below), our colleagues or public information sources including the Disclosure and Barring Service (formerly the Criminal Records Bureau).

We may also record factual information, interview details and interview responses so we have a record of what happened.

The legal basis’ we rely on for using personal information in these ways are as follows:

  • Processing is necessary for the performance of a contract;
  • Processing is necessary for the compliance with a legal obligation;
  • Processing is necessary for our legitimate interests; or
  • Consent has been obtained

4.2 Where we store your personal information

We are committed to holding your personal information securely. This means only those of our colleagues and partners that need to see it have access.

If we can store your personal information solely on computers we will, however there will be cases where we have paper copies instead, or as well.

Our computer system is at our offices but we do use mobile devices outside our offices if they are secure and under our control.

Sometimes we also use computers which are owned or managed by our suppliers, if the computers are secure and comply with our security requirements and all relevant information management legislation.

Occasionally our processors or sub-processors may process information outside the European Economic Area (EEA). Where this happens we will ensure that the processor is compliant with the data protection legislation including transfer agreements that incorporate approved model clauses.

4.3 What we use your personal information for

  • As above, and generally for providing our services for you
  • Data sharing between organisations that are within the Surrey Choices group of companies
  • Keeping in touch with our applicants, understanding your needs and preferences and inviting you to interview
  • Providing additional services, where available, at your request including adaptations and interview support services
  • Prevention, detection and prosecution of crime
  • Quality management
  • Meeting our legal obligations including those of Her Majesty’s Revenue and Customs (HMRC) and other regulators
  • Other purposes – we may anonymise your information so that it cannot be linked to you. In this case we may use the data for any purpose

4.4 Who else we may pass on your information to

Normally only Surrey Choices will be able to access your personal information, however there may be times when we disclose your details to others, and we will comply with data protection legislation when disclosing this information. Where it is required or necessary we may share information with:

  • Organisations that are within the Surrey Choices group of companies
  • Our suppliers who enable us to provide our services to you, or who provide services on our behalf:
  • Companies that assist us in recruitment
  • Driver management service providers
  • Health service providers
  • Our professional advisors
  • For crime prevention or detection, risk assessment, resolution of complaints or other issues
  • Local authorities, safeguarding boards, regulators, government departments and other public authorities, such as for preventing payment errors or fraud
  • The police, fire service, health authorities or medical practitioners.

We may sometimes be obliged to disclose your personal data by law such as by a regulator with appropriate power (such as the Homes and Community Agency), or by court order.

We do not sell your information to others for marketing or commercial purposes.

We will not share your personal information with anyone who claims to represent you unless we are satisfied that you have appointed them or they act in some recognised official capacity. There may be a delay with us dealing with such requests whilst we confirm identity or check that we have your approval to deal with them.