Privacy statement - Comms and Marketing
1. Purpose of our privacy statement
1.1 Under the Data Protection Act 1998 and the General Data Protection Regulation, we are required to explain to you why we are asking for this information about you, how we intend to use the information you provide and whether we will share this with anyone else.
2. Who are we?
2.1 We are Sanctuary Supported Living Limited, a trading name of Sanctuary Housing Association, Sanctuary Affordable Housing Limited and Sanctuary Home Care Limited; and Sanctuary 365, a trading name of Sanctuary Home Care. Both Sanctuary Supported Living and Sanctuary 365 are parts of Sanctuary Group (“Sanctuary”) one of the UK's leading providers of housing, care and commercial services. Our address is Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ.
3. Our data protection officer
3.1 Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
3.2 If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to:The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ
or emailing email@example.com.
4. Why are we collecting your information?
4.1 When you make a general enquiry using our website’s enquiry form or by telephone, we use this to appropriately and fully respond to your enquiries.
4.2 When you provide us with your information at other times, we use this in order:
- to provide improved customer service to you;
- to keep you and other people updated with news about our services and events;
- to celebrate successes across our services; and
- to publicise Sanctuary through the methods outlined in section 5
4.2.1 The information that we use for these purposes is the information collected:
- by telephone;
- by social media;
- by email;
- in your other electronic and written communications with us; and
- in the course of face-to-face contact with you.
4.2.2 This information is completely voluntary and is not required by us in order to provide you with our core housing and personalised care and support planning services.
5. What information are we collecting?
5.1 When you make an enquiry on our website, we will collect the following information:
- the location, name or type of service you are enquiring about;
- your name and personal contact details or the name and contact details of the person on whose behalf you are enquiring;
- the details of your enquiry to us; and
- your communication and language preferences
5.2 When you provide us with your information at other times, we collect the following information which you provide to us with your consent:
- your name, date of birth and personal contact details;
- your communication and language preferences;
- relevant details of your personal life, care and support requirements and experiences of using our services, for the purpose of producing casestudies, publicity materials (both online and printed) or organising events;
- images or videos of you, for the purpose of producing case-studies, publicity materials (both online and printed) or organising events;
6. What we are going to do with your information?
6.1 Your information will be stored and used by us in accordance with this privacy statement and also in accordance with your rights under the Data Protection Act 1998 and the General Data Protection Regulation.
6.2 The information you provide to us will be used for the following purposes:
6.2.1 to respond to your enquiries;
6.2.2 it will be collected and used by us fairly and openly for the purposes of:
- providing news and updates about our events, products and services and how these could meet your needs;
- for organising events;
- for producing publicity materials to promote our services;
6.2.3 it will be used to improve our news, updates and marketing offer to you; and
6.2.4 it will allow us to make contact with you in the most appropriate way. For example, we can provide literature in large print if you have difficulty reading smaller print; or provide documents in an alternative language if English is not your first language.
7. What is the legal basis for using your information?
7.1 In accordance with the data protection laws, we need a "legal basis" for collecting and using information about you. There are a variety of different legal bases for processing personal data which are set out in the data protection laws.
7.2 The lawful bases on which we rely in order to use the information which we collect about you for the purposes set out in this notice will be:
7.2.1 you have provided explicit consent to our use of your information. We will inform you prior to collecting or processing your information based on consent and keep a record of your consent;
7.2.2 using your information is necessary for us to comply with a legal obligation to which we are subject; and
8. Sharing your information
Members of Sanctuary Group
8.1 Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary in order to best provide the services to you in accordance with the contract between us.
8.2 Your information will only be accessed by other companies in the Group where it is necessary to do so in order to provide services to you in accordance with our contract. The obligations which are set out in this notice shall apply to the other members of the Group to the same extent that they apply to us.
8.3 For more information on which companies make up Sanctuary Group, please go to www.sanctuary-group.co.uk/about-us.
Contractors and sub-contractors
8.4 We may share your information with contractors and sub-contractors for the purpose of producing publicity materials, such as printers, designers, publishers and photographers. The contractors and sub-contractors shall be contractually required to ensure that they adhere to the security requirements imposed by the Data Protection Act 1998 and / or the General Data Protection Regulation (as applicable).
8.5 Our contractors and sub-contractors will not share your information with any other parties and will only be able to use the information when completing work on behalf of us.
8.6 We may from time to time share your information with other organisations, such as:
8.6.1 voluntary and statutory organisations who provide us with referrals to our services;
8.6.2 the police for the purpose of detection and prevention of crime; and
8.6.3 social services regarding safeguarding concerns we may have.
9. Transferring your information abroad
9.1 We intend to transfer the information which you provide to us to the United States of America. We are transferring that information to the USA because our e-marketing software provider is located in that country.
9.2 We are transferring your information to Campaign Monitor for the purpose of sending e-marketing and communication emails to you.
9.3 The European Commission has made an adequacy decision in relation to the USA. This means that the Commission has determined that the data protection laws of the USA adequately protect your personal information. As a result, we are not required to obtain specific authorisation to transfer your information to the USA. You can find details of the adequacy decision on the Commission's website: https://ec.europa.eu/info/law/law-topic/data-protection_en
10. Security of your information
10.1 The information that you provide will be uploaded and stored securely on our systems and the form that you complete will be shredded. Our security measures and procedures reflect the seriousness with which we approach security and the value we attach to your information.
10.2 Only relevant members of staff will access the information you provide to us.
11. Can we use your information for any other purpose?
11.1 In limited circumstances we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.
12. Storing your information and deleting it
12.1 We will store the information that you provide to us in the course of your enquiries to us, or in relation to our publication of updates and news about our services for a maximum period of three years. After three years from the point of collection, we will delete and safely dispose of your information.
13. Your rights
13.1 In relation to the information which we hold about you, you are entitled to:
13.1.1 ask us for access to the information;
13.1.2 ask us to rectify the information where it is inaccurate or is incomplete;
13.1.3 ask us to erase the information provided on the basis of your consent and take steps to ask others who we have shared your information with to also erase it;
13.1.4 ask us to limit what we do with your information;
13.1.5 object to our use of your information and ask us to stop that use;
13.1.6 instruct us to provide you with the information we hold about you in a structured and commonly used format or transmit that information directly to another organisation (for example, if you want the information to be sent to another housing provider).
13.2 Our obligations to comply with the above rights are subject to certain exemptions.
13.3 Where we are using your information because you have provided your consent to that use, you are entitled to withdraw your consent at any time. The lawfulness of our use of your information before consent was withdrawn is not affected.
13.4 To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing firstname.lastname@example.org.
13.5 You also have the right to complain to the Information Commissioner's Office (the "ICO") if you are not satisfied with the way we use your information. You can contact the ICO by writing to:Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.