Privacy Policy
1. Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).
2. Who are we?
The Dignus Group is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes.
3. How do we process your personal data?
The Company complies with its obligations under the “GDPR” by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We use your personal data for the following purposes:
People We Support
- To enable us to provide you with care and support in the location/service where you live or receive support.
- To administer medical records applying to the time you have spent with us and your medical history charts.
- Contact details about your next of kin, to enable us to maintain contact with them.
- We also keep some financial details, to enable us to provide you with the required service.
- Your GP, Social Services, CCG details to enable us to maintain contact with them.
- We keep records required by care home regulations, like risk assessments, information on resuscitation and records of accidents and incidents.
- We also keep records about likes, dislikes, support needs and life history in your care plan.
- We may also need to use relevant information about you to:
- Provide information to other agencies who may contribute to your care, like hospitals.
- Keep your GP fully informed.
- Provide some information to people with Power of Attorney, Deputyship or people acting on your behalf if they request it or when it is in your best interest.
- Share with agencies who will continue your care: for example, if you chose to move to another care facility.
- To inform you of news, events, and activities running at the company’s locations.
- Access to GP Connect to support your direct care. GP Connect makes patient information available to all appropriate clinicians when and where they need it, to support direct patient care which leads to improvements in both care and outcomes. GP Connect is not used for any purpose other than direct care.
Employees
- To manage our employees and volunteers, which includes the processing of your employment history and DBS checks.
- To maintain our own accounts and records including the processing of Payroll and Pensions.
- To provide information to third parties when legally required to do so, i.e. HMRC.
- To inform you of news, events, activities and opportunities within the group.
- To manage the entire employee lifecycle, prior to, during and after the employment has ended.
4. CCTV Monitoring
We operate closed-circuit television (CCTV) systems across our business premises to ensure a safe environment for our employees, contractors, and visitors.
Locations: Cameras are positioned prominently at the external boundaries of our premises, and at some locations within internal entrance and reception/lobby areas. CCTV cameras are not deployed in private residential areas (such as bedrooms or bathrooms). This is to ensure the dignity, privacy, and wellbeing of our residents are fully respected.
Purpose and Lawful Basis: We process the visual data in pursuit of our legitimate business interests, including:
- Ensuring the safety and security of our residents, staff, and visitors;
- Preventing, detecting, and investigating crime (such as vandalism or trespassing);
- Securing our buildings, protecting company assets and preventing unauthorised access.
Audio recording: The system records high-definition video images, surveillance is strictly limited to visual data. No audio monitoring or sound recording takes place at any time.
Performance monitoring: CCTV is installed strictly for security and safety purposes. We do not use CCTV to monitor day-to-day employee productivity or attendance. However, if footage inadvertently captures evidence of potential criminal activity or gross misconduct, it may be used in formal disciplinary investigations. Images captured by CCTV may be monitored and recorded in accordance with applicable data protection laws and retained only for as long as necessary for the purposes outlined above.
Retention and Security: Footage is recorded securely, access is restricted to authorised management, and data is automatically overwritten after 31 days, unless required for an ongoing investigation.
Your Rights: Under data protection law, all individuals captured by our CCTV system, including people we support, employees, family members, and visitors, have the following rights:
- The Right of Access: You have the right to request a copy of any CCTV footage in which you are clearly identifiable.
- The Right to Restriction: You can request that we temporarily “freeze” and preserve specific footage (preventing it from being automatically overwritten) if it is required for a legal dispute or an ongoing safeguarding investigation.
- The Right to Object: You have the right to object to our use of CCTV if you believe it disproportionately impacts your privacy. We will review your objection, balancing it against our statutory safeguarding duties and workplace security requirements.
- The Right to Erasure: You may request the early deletion of footage featuring you, though we may decline this request if the data is lawfully required for security, safety, or legal claims.
How to Exercise Your Rights
- Submitting a Request: To request access to or restriction of CCTV footage, you must submit a Subject Access Request (SAR) to our data protection office at [email protected].
- Required Information: To help us locate the relevant data, you must provide the exact date, time, and specific camera location(s) of the footage you are requesting, along with a recent photograph of yourself so we can verify your identity.
- Acting on Behalf of a Person We Support: Due to strict privacy laws, family members or advocates requesting footage on behalf of a resident must provide formal legal proof of authorisation, such as a registered Health and Welfare Power of Attorney (LPA) or court order.
- Response Time: We will respond to valid requests within one calendar month, in accordance with regulatory requirements.
- Complaints: If you remain unsatisfied with how we handle your CCTV data or your rights request, you have the right to lodge a formal complaint with the Information Commissioner’s Office (ICO).
5. What is the legal basis for processing your personal data?
- Explicit consent of the data subject so that we can keep you informed about news, events, activities and opportunities across the group. (Consent)
- Processing is necessary for carrying out obligations under employment, social security or social protection law. (Performance of a contract) (Legal Obligation)
- Provision of care and support services to maintain your health and wellbeing. (Vital Interests) (Performance of a contract) (Consent) (Legitimate Interests)
- Employee personal data, for the entire employment lifecycle. (Performance of contract) (Legal Obligation) (Legitimate Interests)
6. Sharing your personal data
Your personal data will be treated as strictly confidential and will only be shared with other members of the organisation to carry out or to perform a function as requested or required. We will only share your data with third parties outside of the organisation with your consent.
7. How long do we keep your personal data?
We keep data in accordance with the guidance set out in Retaining personal data (Principle 5) from the ICO (Information Commissioner’s Office). Dependent upon the nature of the data and the status of the data subject, this will have a bearing upon the time for which data is retained, to ensure compliance with the relevant and governing law.
Specifically, we retain paperwork for up to 6 years after the calendar year to which it relates for people we support over 18, up to 75 years for under 18’s, and 6 years for staff employment data.
8. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of your personal data which the Dignus Group holds about you (SARs) Subject Access Requests.
- The right to request that the Dignus Group corrects any personal data if it is found to be inaccurate or out of date.
- The right to request your personal data is erased where it is no longer necessary for the Dignus Group to retain such data.
- The right to withdraw your consent to the processing at any time.
- The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability), where applicable. [Only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means.]
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
- The right to object to the processing of personal data, where applicable. [Only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics.]
- The right to lodge a complaint with the Information Commissioner’s Office.
9. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
10. Contact Details
To exercise all relevant rights, queries or complaints please in the first instance contact the Data Controller for the Dignus Group in any of the following ways:
Post: Data Controller, Dignus Group, 10 Hatherton Road, Walsall WS1 1XS
Email: [email protected]
Phone: 0121 357 5049
You can contact the Information Commissioner’s Office by phone on 0303 123 1113, via email at https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office located at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
