We are Worcester Garden Ltd,  Our company number is 04487255 and our Business address is  

Fieldside

 Crowle 

Scunthorpe

 Lincolnshire

 DN17 4HL 

 Worcester Garden Ltd are committed to ensuring that your privacy is protected. We comply with the UK General Data Protection Regulation (“UK GDPR”) unless and until the UK GDPR is no longer directly applicable in the UK. We also follow all national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, and any successor legislation to the UK GDPR and the DPA (together “Data Protection Legislation”). We are the data controller of data you pass to us pursuant to this policy. Our Data Protection Officer can be contacted at greenacresccare@btconnect.com. This Privacy Policy [together with our website terms and conditions and cookie policy] sets out how we collect personal information from you and how the personal information you provide will be processed by us. By visiting the website at greenacrescare.co.uk (the “Website”) you are accepting and consenting to the practices described in this Privacy Policy. If you do not consent, please do not submit any personal data to us. What information does Worcester Garden Ltd hold and how will we use it? Information you give Worcester Garden Ltd: You may give us information about you by completing enquiry forms on the website or by requesting via the website that we send you marketing information, The information you give us may include your name, email address, address/location and phone. We will retain this information while we are corresponding with you or providing services to you or to a Service User you represent.   Information Worcester Garden Ltd collects about you: Worcester Garden Ltd may collect the following information from you when you visit the website:  

Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from the website (including date and time), products you viewed or searched for, page response times, website errors, length of visits to certain pages, page interaction information, methods used to browse away from the page and any phone number used to call our helpline   Information we receive from other sources: This includes information we receive about you when you use other websites operated by us or other services we provide. This information may include your name, email address, postal address and phone number  Cookies   The Website uses cookies to distinguish you from other users of the website. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy   Use Made of the Information  We may use the information we receive and/or collect about you to:   Fulfil our obligations under any contract that we have entered into with you or with a Service User that you represent, and to provide you or the relevant Service User with information or services that you or the Service User has requested  Send you newsletters and marketing information if you have consented to us doing so  Notify you of products and services that we feel may interest you, or permit third parties to do so if you have provided the appropriate consent  Monitor website usage and provide statistics to third parties for the purposes of improving and developing the website and the services we provide via the website  Worcester Garden Ltd processes personal information for certain legitimate business purposes, which include some or all the following:   Where the processing enables Worcester Garden Ltd to enhance, modify, personalise or otherwise improve the website, its services or communications  To identify and prevent fraud  To enhance the security of the network and information systems of Worcester Garden Ltd  To better understand how people interact with the websites of Worcester Garden Ltd  To administer the website and carry out data analysis, troubleshooting and testing; and  To determine the effectiveness of promotional campaigns and advertising  If we obtain consent from you to do so, we may provide your personal details to third parties so that they can contact you directly in respect of services in which you may be interested. Where we are processing personal data that we have obtained via the website on the basis of having obtained consent from you, you have the right to withdraw your consent to the processing of your personal data at any time. If you would like to withdraw your consent or prefer not to receive any of the above-mentioned information (or if you only want to receive certain information from us) please let us know by contacting us via our email address. Please bear in mind that if you object, this may affect our ability to carry out the tasks above for your benefit. If you wish to have your information removed from our database or if you do not want us to contact you for marketing purposes, please let us know by clicking the "Unsubscribe" option in any email we send to you and providing the details requested and we will take steps to ensure that this information is deleted as soon as reasonably practicable. We will not share, sell or distribute any of the information you provide to us (other than as set out in this policy) without your prior consent, unless required to do so by law. Third Party Sites  Our website may contain links to third party websites, including websites via which you are able to purchase products and services. They are provided for your convenience only and we do not check, endorse, approve or   agree with such third-party websites nor the products and/or services offered and sold on them. We have no responsibility for the content, product and/or services of the linked websites. Please ensure that you review all terms and conditions of website use and the Privacy Policy of any such third-party websites before use and before you submit any personal data to those websites.  How Safe is your Information?  Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.  Protecting your security and privacy is important to us and we make every effort to secure your information and maintain your confidentiality in accordance with the terms of the Data Protection Legislation. The website is protected by various levels of security technology, which are designed to protect your information from any unauthorised or unlawful access, processing, accidental loss, destruction and damage. We will do our best to protect your personal data but the transmission of information via the Internet is not completely secure. Any such transmission is therefore at your own risk. Disclosure of your Information  We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006. We may share your information with selected third parties including:   Business partners, suppliers and sub-contractors for the performance of any contract we enter with them or you  Third parties who may wish to contact you in respect of services or products they offer or sell which may be of interest to you, provided we receive your consent to such disclosure; and/or advertisers and advertising networks that require the data to select and serve relevant adverts to you and analytics and search engine providers that assist us in the improvement and optimisation of the website  Please note, we may need to disclose your personal information where we:   Sell any or all of our business or assets or we buy another business or assets in which case we may disclose your personal data to the prospective buyer or seller  Are under a legal duty to comply with any legal obligation or to enforce or apply our terms and conditions; or  Need to disclose it to protect our rights, property or the safety of our customers or others, including the exchange of information with other companies, organisations and/or governmental bodies for the purposes of fraud protection and credit risk reduction  Where we Store your Personal Data Although we have left the EU, UK GDPR still requires the following:  Your Rights in Respect of your Data   If any of the information you provide to us via the website changes, please let us know as soon as possible so that we can make the necessary changes to the information we hold for you on our database. If you wish to make any changes to your information, please contact us via the following greemacrescare@btconnect.com.  If you wish to access or rectify the information we hold about you, or request that such information be transmitted directly to another data controller, please contact us via the following greenacrescare@btconnect.com. We shall process your request to access your information within one month of receipt, or we will let you know within that timeframe if we need more information from you. We will process your request free of charge.  To request that your information is deleted or if you wish to restrict or object to the processing of your information, please contact us via the following greenacrescare@btconnect.com.  If you have any complaints about our use of your personal data, please contact us. You also have the right to complain to the relevant supervisory authority in your jurisdiction. In the UK, the supervisory authority is the Information Commissioner's Office. Contact details for the ICO can be found at https://ico.org.uk/.  If you have any further queries or comments on our Privacy Policy, please contact us via the following greenacrescare@btconect.com]. We also welcome your views about our website and our Privacy Policy.  

1.1 To help reduce the fear of crime for staff, Service Users and visitors, (particularly those who are entering and leaving Worcester Garden Ltd during the hours of darkness) and to protect Worcester Garden Ltd from criminal activity.

1.2 To set the acceptable parameters for the use of hidden Cameras by Worcester Garden Ltd and ensure that any CCTV system is not abused or misused.

1.3 This policy dovetails with the Home Office Surveillance Camera Code of Practice and The Information Commissioners Office (ICO) CCTV Code of Practice.

1.5 To meet the legal requirements of the regulated activities that {Worcester Garden Ltd} is registered to provide:

1.5.1 Regulation of Investigatory Powers Act 2000 (RIPA)

1.5.2 The Telecommunications (Lawful Business Practice) (interpretation of Communications) Regulations 2000

1.5.3 The Care Act 2014

1.5.4 Freedom of Information Act 2000

1.5.5 The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014

1.5.6 Human Rights Act 1998

1.5.7 Mental Capacity Act 2005

1.5.8 Mental Capacity Act Code of Practice

1.5.9 Protection of Freedoms Act 2012 (links to) The Protection of Freedoms Act 2012 (Disclosure and Barring Service Transfer of Functions) Order 2012

1.5.10 General Data Protection Regulation 2016

1.5.11 Data Protection Act 2018

2.1 The following roles may be affected by this policy:

l All staff

2.2 The following Service Users may be affected by this policy:

l Service Users

2.3 The following stakeholders may be affected by this policy:

l Family

l Advocates

l Representatives

l Commissioners

l External health professionals

l Local Authority

3.1 CCTV systems are operated lawfully and only for the defined purposes set out within this

policy. Worcester Garden Ltd is clear that the rationale for the use of CCTV is to detect, prevent and reduce the incidence of crime on the property of Worcester Garden Ltd.

4.1 Worcester Garden Ltd has due regard for the privacy of all Service Users, staff and visitors at all times and staff and Service Users understand their rights regarding the use of hidden surveillance within Worcester Garden Ltd.

• Worcester Garden Ltd recognises and endorses people's rights to privacy and dignity whilst balancing protection from avoidable harm. Worcester Garden Ltd will consult with Service Users and gain their consent before using any surveillance equipment. For those Service Users who lack capacity, Worcester Garden Ltd will consult with their legal representatives and best interests will be determined under the Mental Capacity Act (2005).

• Worcester Garden Ltd will have a designated Registered Manager who will take legal responsibility for the operation and compliance of the CCTV system and resulting data. At Worcester Garden Ltd this is Claire Johnson. Worcester Garden Ltd will adhere fully to the 12 guiding principles of the ICO Surveillance Camera Code of Practice.

• The storage and disclosure of information from surveillance systems will be controlled and consistent with the purpose(s) for which the system was established and in line with data protection principles.

• The use of surveillance will never substitute suitably skilled, knowledgeable staff in relation to the numbers required to support Service Users. Where poor care is identified through the use of surveillance, relevant policies will be followed. Where criminal activity is discovered or suspected, Worcester Garden Ltd will notify the relevant authorities and bodies.

Worcester Garden Ltd will conduct a privacy impact assessment in line with its GDPR policy on privacy impact assessments before considering implementing any CCTV system or modifying an existing system. The Privacy Impact Assessment must be written and stored for future reference.

Authorisation must be sought from Worcester Garden Ltd before introducing a new CCTV system or modifying an existing one. The ICO should be notified prior to the installation of any CCTV system. The ICO will expect to be told what the data being recorded will be used for.

It is essential that the location of the equipment is carefully considered, as the way images are captured must comply with the Data Protection Regulations.

Cameras will be located in prominent positions within Service User, public, and staff view and will not infringe on living and circulating areas (corridors etc.).

CCTV surveillance will be automatically recorded and any breach of the Codes of Practice (i.e. The Home office Surveillance Camera Code of Practice and The Information Commissioners Office (ICO) CCTV Code of Practice) will be detected via controlled access to the system and auditing of the system.

Signs must be placed at entrance points to the premises of Worcester Garden Ltd and throughout the site to ensure that staff and visitors are aware that they are entering an area that is covered by CCTV surveillance equipment. The signs must include details of the purpose of the CCTV as well as

the organisation and contact details of the person responsible for the CCTV.

The use of covert CCTV (directed) surveillance, should be considered only after consultation with the Police, whose advice and requirements must be met.

Siting a camera within a Service User's place of care provision must be carried out in consultation with the Service Users and their family. Privacy concerns that are identified during the consultation with the Service User must be given due consideration.

CCTV surveillance systems will not be used to record conversations between Service Users, visitors or staff.

Images produced by the equipment should be clear in order that they are effective for the purpose(s) for which they are intended. For example, if a system has been installed to prevent and detect crime, then it is essential that the images are adequate for that purpose.

Camera installations and service contracts should be undertaken by NSI approved security companies where the equipment is placed in or on the site of the premises of Worcester Garden Ltd. Upon installation, all equipment is tested to ensure that only the designated areas are monitored and that high-quality pictures are available in live and playback mode. All CCTV equipment should be serviced and maintained on an annual basis by an NSI approved company. The Data Controller should have access to the manufacturer's guidelines for the system in use.

The system can consist of cameras recording to digital recorders. These recorders must be located in secure locations, with access control at two levels:

l Access to the location must be available only to authorised persons

l Access to images must be password protected and limited to persons authorised to view them

Images, which are not required for the purpose(s) for which the equipment is being used, should not be retained for longer than is necessary. While images are retained, it is essential that their integrity is maintained, whether it is to ensure their evidential value or to protect the rights of people whose images may have been recorded.

All images that are digitally recorded in or on site at the premises of Worcester Garden Ltd must be stored securely within the system’s hard drive for up to 30 days after which they must then be automatically erased. Located within the premises of Worcester Garden Ltd, there may be sub-monitors which display images of public areas. However, these must be located within enclosed areas and only accessible to the Registered Manager or a designated other at Worcester Garden Ltd.

Where the images are required for evidential purposes in legal or disciplinary proceedings, a DVD disc recording is made and placed in a sealed envelope, signed and dated and held by Alison Hunt-Siwy until completion of the investigation. The viewing of images must be controlled by the Registered Manager or a person nominated to act on their behalf. Only persons trained in the use of the equipment and authorised