Data Protection Privacy Notice
Who We Are
The ExtraCare Charitable Trust was established in 1988. We develop and run retirement villages and smaller housing developments. Our registered office is:
7 Harry Weston Road
Binley Business Park
Coventry CV3 2SN
Company Number: 02205136
Charity Number: 327816
The ExtraCare Charitable Trust (“we” or “the Charity”) promises to respect the confidentiality of any personal data you share with us, or that we get from other organisations, to keep it safe, and we will always take every effort to protect your privacy.
Transparency is one of the values of our Charity. We will be open, transparent and honest in our dealings with our residents, staff, volunteers and customers and be clear how, when and why we collect and process your information.
Developing a better understanding of our residents and supporters of the Charity is crucial, and your personal data allows us to make better decisions, provide services more efficiently, and ultimately, help us achieve our mission of providing “better lives for older people”.
Data Protection Officer
The Charity’s Data Protection Officer is:
The ExtraCare Charitable Trust
Tel: 02476 509023
The legal basis for processing your personal data
Under relevant Data Protection legislation, the main grounds that we rely upon in order to process personal information are the following:
(a) Contract necessity or contract performance – in order for us to perform obligations that we undertake in providing a service to you and in order to take steps at your request to enter into a contract with us or to respond to any queries you raise, it will be necessary for us to process your personal data;
(b) Compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data;
(c) Legitimate interest - either we, or a third party, will need to process your personal data for the purposes of our (or a third party's) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include, but are not limited to, responding to requests and enquiries from you or a third party, providing awareness of relevant legislation or regulations, preventing theft and unauthorised access, optimising our website and customer experience, and ensuring that our operations are conducted in an appropriate and efficient manner;
(d) Consent – in some circumstances, we may ask for your consent to process your personal data in a particular way.
(e) Vital Interest – in some circumstances, it may be necessary for us to process your data in order to protect the vital interests of you or of another natural person.
Reasons for Collecting Your Data
How much personal information we need to hold depends on our relationship with you. For example, if you are donating to us we will need to hold fewer details on you than if you are a resident or a resident in receipt of care, where we will need to know more about your personal circumstances.
Regardless, we will only ever capture the minimum amount of information we require and we promise to keep information secure and only share with other organisations or individuals who need to know.
If you are a resident at one of the villages or schemes, which we own or manage on behalf of another housing provider, we will usually collect:
Where appropriate, we may ask for additional information. We mainly use your data to:
In order that we are able to provide you with the services you require, for example to assist you with a housing enquiry, or seeking access to care or wellbeing services, we will need additional ‘sensitive’ information from you. This may come directly from you, or from a third party on your behalf, for example from a family member or GP. Examples of this sensitive information includes any medical conditions you may have or your racial or ethnic origin.
We will normally only hold, use and share this ‘sensitive’ information with your explicit permission, although there may be reasons when we are required to do so by law, or to protect your vital interests. In such circumstances we may process your information without your knowledge or consent, but this would be extremely rare, but possible.
If you volunteer we will usually collect:
Where it is appropriate, we may ask for additional information. We mainly use your data to:
If you support us, for example you make a donation or buy something from our shops, we will usually collect:
Where it is appropriate, we may ask for additional information. We mainly use your data to:
We will collect all personal information required to comply with employment legislation, including where necessary sensitive information. This may include medical information and where additionally appropriate we will perform a criminal record search. To prevent discrimination and ensure diversity, we will request information from the employee or volunteer on religion, sexuality and ethnicity.
In order to prevent, investigate and detect, crime, misconduct, breaches of relevant regulations, and to ensure the safety of our residents, staff and volunteers, we operate CCTV systems in our various locations. These cameras record footage in real-time and are operated and controlled by our own staff. Captured images will be deleted after 30 days in accordance with our CCTV policy unless required for evidentiary purposes.
Residents are provided with limited access to CCTV Footage from their apartments. In order to share personal data under relevant data protection legislation we are required to have a legitimate basis to do so. The Charity is satisfied that it has a legitimate interest to permit this to ensure that our residents feel safe in their own homes and in order for them to be able to prevent and detect unauthorised access and/ or crime. This is particularly important given that locations do not have 24hr security and the location reception is generally closed and un-manned during out-of-office hours and at weekends.
Details of our CCTV policy are available on request.
Sharing Your Data
We ensure there are appropriate physical and technical controls in place to protect your personal details. For example, paper records are locked away and our IT network is protected and routinely monitored.
We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors. We do on occasions use external companies to collect or process personal data on our behalf. We do comprehensive checks on these companies before we work with them and put in place a contractual arrangement that sets out our expectations and requirements, especially regarding how they manage personal data we provide to them or have access to. We will only ever allow your data to be used for as long as is necessary by suppliers working on our behalf. As outlined above under the legal basis for processing your data, we may share your data with a third party where we have a legitimate basis to do so, in association with: the performance of a contract, where we have a legal obligation to do so, we have a legitimate interest, in order to protect the vital interest of you or another natural person or where you have consented for us to do so.
How long we keep your data for
We will only keep your information for as long as long as is necessary. There are some statutory timescales on how long we should keep your information, for example, gift aid transaction must be retained indefinitely, and employment records for 6 years after an employee leaves. We will retain your information in accordance with our Records Management Policy which takes into account statutory limits and guidance issued by the Information Commissioners Office and other bodies.
We will ensure as much as possible that your information is accurate, and where necessary up-to-date. We would appreciate it if you let us know if your contact details change.
Under new data protection legislation you have the following Individual Rights:
If you would like to make a request to The ExtraCare Charitable Trust in relation to any of these Individual Rights please email firstname.lastname@example.org together with proof of identification. We will review your request and respond to you in line with relevant data protection legislation.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and/ or transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Like most websites, when you visit our sites we place cookies on your computer or other device. For the most part, these cookies are used to enable the websites' functionality, improve the user experience or help us to optimise our websites, measure traffic and other internal management purposes.
If you are unhappy with how we have processed your information, we would like you to contact us in the first instance so we can put it right.
Write to us at:
The ExtraCare Charitable Trust, 7 Harry Weston Road, Binley Business Park, Binley, Coventry, CV3 2SN.
Telephone us on:
Email us at:
You also have a right to lodge a complaint with the Office of the Information Commissioner at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Helpline 0303 123 1113 (local rate) or 01625 545 745.
Changes to this policy