BACKGROUND

Thrive Care Solutions Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our website www.thrivecaresolutions.co.uk (“the Website”) or provides data to us through other means.  This may include information given by health and social care professionals, or by you in meetings with our employees or through the completion of forms or other documentation.  We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it.

If you are viewing this Privacy Policy on the Website, your acceptance of it is deemed to occur upon your first use of the Website. If you do not accept and agree with this Privacy Policy, you must stop using the Website immediately.

If you have been provided with a hard copy of this Privacy Policy or one has been emailed to you, please read it before providing us with any data.  If you do not consent to our processing data in accordance with this Privacy Policy, please let us know straightaway.  This may mean, however, that we are unable to provide some or any services to you.

1. Information About Us

We are Thrive Care Solutions Ltd, a company registered in England under company number 14836784. The address of our registered office is: 20 Pumphouse Way, Basingstoke, Hampshire, RG24 9GY. We are registered with the Information Commissioner’s Office under reference ZB546588.

2. What Does This Policy Cover?

This Privacy Policy applies to your use of the Website and to any data that you provide us with or is provided to us by a third party.

The Website may contain links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for what they do including how they process your data. When you leave our website, we encourage you to read the privacy policy of every website you visit.

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. It does not include anonymised data.

4. What Are My Rights?

Under the GDPR, you have the following rights:

1. The right to be informed about the collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can also contact us if you have any questions using the details in section 11.
2. The right to access the personal data we hold about you. Section 10 will tell you how to do this.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in section 11 to find out more.
4. The right of erasure. You may ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in section 11 to find out more.
5. The right to restrict the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to data portability. This means that, if you have provided personal data to us directly, weare using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in section 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office the UK supervisory authority for data protection issues or your local Citizens Advice Bureau.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office.  We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

5. What Data Do You Collect?

Depending upon how you use the Website and whether you are a client of ours, the types of personal and non-personal data that we collect are listed in the Schedule.

6. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one or more of the following purposes:

•  Supplying services to you. Your personal details are required in order for us to enter into a contract with you.
•  Personalising and tailoring our services for you. This may involve sharing your data with the relevant Integrated Care Boards, Local Authority, 3rd party agencies where you have given us permission to do so.
•  Communicating with you. This may include responding to emails or calls from you.
•  Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by clicking on the ‘Unsubscribe’ link at the foot of the email).

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and post with information and news about our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

7. How Long Will You Keep My Personal Data?

We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for. These purposes may include satisfying any legal, accounting, or reporting requirements.

When deciding what is the correct time to retain your personal data, we consider its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, and whether these can be achieved by other means and legal requirements.  Some personal data may be retained for up to 8 years to enable us to comply with various regulatory requirements.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

9. Can I Withhold Information?

You may access the Website without providing any personal data. However, to use all features and functions available on the Website (e.g., the contact form) you may be required to submit or allow for the collection of certain data.

If you are a client, then you are free not to provide personal data.  However, this may mean that we are unable to provide some or any services to you.

10. How Can I Access My Personal Data?

If you want to know what personal data we hold about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in section 11.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please contact Ed Kemp (Director) at info@thrivecaresolutions.co.uk

12. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any revised Privacy Policy will be posted on our Website and you will be deemed to have accepted the terms of it on your first use of the Website following the alterations. We recommend that you check this page regularly to keep up to date.

SCHEDULE

Data that may be collected through using the Website

Contact Us Form

First Name
Surname
Email address
Reasons for contacting the company 

Personal Health Budget Review Form

First Name
Surname
Email address
ICB / Location 
Personal Health Type
Reason for Personal Health Budget
Personal Health Budget Managed Account Holder
Personal Heath Budget Support Plan 
No. of carers employed by Personal Health Budget

Information that you provide on the contact form not listed above.

IP address
Web browser type and version
Operating system