ASPIRE CLINICAL EDUCATION PRIVACY POLICY
ASPIRE CLINICAL EDUCATION LTD
Customer Privacy Notice
This privacy notice tells you what to expect us to do with your personal information.
· What information we collect, use, and why
· Lawful bases and data protection rights
· Where we get personal information from
· How long we keep information
· Who we share information with
Contact details
Telephone: 07733972145
Email: training@aspireclinicaleducation.co.uk
What information we collect, use, and why
We collect or use the following personal information to comply with legal requirements:
· Name
· Contact information
· Health and safety information
· Financial information
· Any other personal information required to comply with legal obligations
· Insurance details
· Safeguarding information
We also collect the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:
· Health information
We collect or use the following personal information for information updates, marketing or market research purposes:
· Names and contact details
· Addresses
· Marketing preferences
· Website and app user journey information
· IP addresses
· Records of consent, where appropriate
We collect or use the following personal information for dealing with queries, complaints or claims:
· Names and contact details
· Addresses
· Payment details
· Purchase or service history
· Witness statements and contact details
· Relevant information from previous investigations
· Customer or client accounts and records
· Financial transaction information
· Correspondence
· Relevant training, competency, care planning, risk assessment or clinical information where necessary to investigate or respond to a complaint or claim.
We also collect the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:
· Health information
We collect or use the following personal information To provide clinical education, training, competency support and consultancy services, including client-centred training, care plan and risk assessment development or review, and associated administration.:
· Name, address and contact details
· Gender
· Pronoun preferences
· Date of birth
· NHS/HSC/CHI number
· Hospital number
· Next of Kin details
· Emergency contact details
· Photographs
· Health information (including medical conditions, allergies, medical requirements and medical history)
· Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions)
· Records of meetings and decisions
· Administration information (including treatment schedules and admission and discharge information)
· Records of consent, where appropriate
· Care plans, risk assessments, medication information, clinical procedures and instructions, equipment information, competency-related information, and other relevant documentation needed to tailor training or consultancy to the individual.
We also collect the following special category information to provide clinical education, training, competency support and consultancy services, including client-centred training, care plan and risk assessment development or review, and associated administration. This information is subject to additional protection due to its sensitive nature:
· Health information
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
· Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
· Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to comply with legal requirements are:
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for information updates, marketing or market research purposes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· To promote Aspire Clinical Education’s relevant training, consultancy and related services to existing and prospective business contacts who may reasonably have an interest in those services, while respecting their privacy and providing a clear way to opt out of marketing communications.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· To respond to and manage queries, investigate and resolve complaints, handle disputes or claims, protect Aspire Clinical Education’s legal and business interests, and maintain appropriate records of communications and decisions.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information to provide clinical education, training, competency support and consultancy services, including client-centred training, care plan and risk assessment development or review, and associated administration. are:
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· Aspire Clinical Education has a legitimate interest in using relevant personal information where this is necessary to provide clinical education, competency support and consultancy services safely and effectively, particularly where services are commissioned by an organisation rather than directly by the individual whose information is being used. This may include reviewing care plans, risk assessments, health information and other relevant documentation so that training or consultancy can be accurately tailored to the individual’s needs. The processing benefits the individual and the commissioning organisation by helping ensure that the service provided is relevant, informed and appropriate. Only information that is necessary for the specific service is used, access is restricted, and information is retained only for as long as needed. These safeguards reduce the potential impact on individuals and help ensure that Aspire Clinical Education’s interests do not override their rights and freedoms.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
· Directly from you
· Regulatory authorities
· Family members or carers
· Other health and care providers
· Social services
· Schools, colleges, universities or other education organisations
· Councils and other public sector organisations
· Relevant regulatory authorities
· Suppliers and service providers
· Third parties:
· Commissioning organisations, care providers, case managers, responsible healthcare professionals, and other organisations or professionals involved in arranging, funding or supporting the relevant training, competency or consultancy service.
· Commissioning organisations, care providers, case managers and other professionals involved in arranging or supporting the relevant service.
How long we keep information
Aspire Clinical Education retains personal information only for as long as it is necessary for the purpose for which it was collected and in line with legal, regulatory and business requirements.
Special category health information used for client-centred training, care planning, risk assessment or competency support is normally retained for up to 6 months after it is no longer required for the relevant service, unless there is a legal, safeguarding, complaint, insurance or other justified reason to retain it for longer.
When information reaches the end of its retention period, it is securely deleted, destroyed or anonymised. Retention periods are reviewed where necessary to ensure personal information is not kept for longer than required.
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Who we share information with
Data processors
Cloud storage and email service provider - Microsoft.
This data processor does the following activities for us: Cloud storage and email service provider - Store business emails, documents and records and provide email and cloud-based file storage.
Accounting software - FreeAgent.
This data processor does the following activities for us: Store and process invoicing, payment and business accounting information.
Web hosting - Squarespace
This data processor does the following activities for us: Hosts and operates the Aspire Clinical Education website and processes website enquiry and usage information.
Email marketing and marketing automation provider – Mailchimp
This data processor does the following activities for us: stores and processes contact details, marketing preferences and related information to manage mailing lists and send marketing communications on behalf of Aspire Clinical Education.
Others we share personal information with
· Care providers
· Organisations we need to share information with for safeguarding reasons
· Local authorities or councils
· Organisations we’re legally obliged to share personal information with
· Other relevant third parties:
· Commissioning organisations, case managers, responsible healthcare professionals and other organisations or professionals involved.
Duty of confidentiality
We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:
· you have provided appropriate consent for the disclosure or use of the information, where consent is required;
· swe have a legal requirement (including court orders) to collect, share or use the data;
· on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
· If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
· If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.
How to complain
If you have any concerns about our use of your personal information, you can make a data protection complaint to us:
Email: training@aspireclinicaleducation.co.uk
Telephone: 07733972145
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint