Our privacy promise
Last updated: December 2021
This is the standard data protection privacy policy for Country Cousins Homecare Agencies Limited (under which Country Cousins is a trading name). This includes the privacy information applicable to our self-employed carers.
- Introduction
- How we use your information
- Fraud prevention and credit checks
- Lawful bases for using your information
- Keeping you informed about our products and services
- Sharing your information
- Information sent outside the European Economic Area – EEA
- Amendment and retention of information
- Your rights
- Updates to our privacy policy and your comments
- Carer data protection
Country Cousins Homecare Agencies Limited, together with its subsidiaries are registered as data controllers with the Information Commissioner’s Office (ICO).
Companies within Country Cousins Homecare Agencies Limited use a variety of well-known brand and trading names including, but not limited to, Country Cousins and Patricia White’s.
Country Cousins Homecare Agencies Limited (“we”,”us”) are committed to protecting your privacy. We comply with the principles of the General Data Protection Regulation (GDPR) and associated data protection legislation. We aim to maintain best-practice standards in our processing of personal and/or special category personal data (this is also referred to as sensitive personal data).
We use the information we receive from you, together with information we have obtained from our dealings with you (including in relation to goods and/or services we provide to you and/or your use of those goods and/or services), to provide goods and/or services that you request, to communicate with you, and to personalise information sent to you.
We do not sell, trade, or rent your personal information to others.
We store all the information you provide to us, including information provided via forms you complete on our website, and information which we may collect from your browsing. Our server, in common with nearly all web servers, logs each page that is downloaded from the site. If you contact us electronically we may collect your electronic identifier, e.g. Internet protocol (IP) address or phone number supplied by your service provider. This is to identify the number of visits to our websites, fraudulent behaviour or mystery shoppers using our websites.
We ask for your home, mobile phone number, and email address to enable us to contact you in relation to an enquiry you have made, to contact you if there is a problem with your order, notifying you about important functionality changes to the website, or if there is another genuine reason for doing so. For example, when you enter a contest or other promotional features, we use these details to administer the contest and notify winners.
Sometimes we may need to collect information that the law defines as special category data (also called sensitive personal data). This includes, but is not limited to, information about racial or ethnic origin, sexual orientation, health data, and criminal records. We will not collect or use these types of data without your consent, unless the law allows us to do so. If we do, it will only be when it is necessary as determined by the law and the ICO.
Any new information you provide to us may be used to update an existing record we hold for you. If you provide a work email address we will not be responsible for third parties having access to any communications we send.
We collect credit or debit card details from you in order to pay for a service or product. We will keep such details secure and ensure that the details are only used further with your consent and/or for the purposes of any appropriate refunds.
In the event of phone calls from you, we also reserve the right to ask security questions (which we in our sole discretion deem appropriate) in order to satisfy ourselves that you are who you say you are.
To help us prevent fraud and money laundering, your details may be submitted to fraud prevention agencies and other organisations where your records may be searched.
In order to assess financial and insurance risk, we will make full and open checks on the electoral roll registers and public data provided to us by credit reference bureaus and other third parties.
Our own security procedures mean that we may occasionally have to request proof of identity or check your presence on the electoral roll.
Before you provide any data to us we will endeavour to make it clear why we need it. Sometimes we may need special category (sensitive) personal data. When this is required, we will obtain your consent first, unless the information is necessary to provide the service requested by you. Without this information, we may not be able to fulfil the product or service you have requested.
A customer may properly give their partner’s consent over the phone or via the website providing the customer confirms they have permission to do so. If the consent is written, the spouse must independently endorse such consent via counter signature.
We use the information you provide to us, either orally or in writing and the information we obtain from you through the use of our website, and as a result of our dealings with you (including any data we obtain from third parties) to provide the service requested by you. It may also be used for market research and statistical purposes.
We recognise that we have a legitimate interest in processing the personal data we collect about you for a number of reasons, including, but not limited to: marketing purposes, to enables us to enhance, modify, personalise, or otherwise improve our services, identify and prevent fraud, enhance and protect the security of our network and systems, and market research (e.g. determining the effectiveness of campaigns and the products / services we offer). “Legitimate interests” means the interests of our company in conducting and managing our business to enable us to give you the best service and most secure experience.
When we use your information for our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. Where applicable, legitimate interest assessments are conducted to ensure that these rights are protected.
When you contact us, either online or via one of our contact centres, we may ask for your permission to contact you about the products and services we offer. Where we have obtained your permission to do so we will contact you by post, telephone, email or other means to tell you about offers, products and services that may be of interest to you.
We also recognise that it is in our legitimate interests to send communications about our products and services, latest offers and rewards, so we may process your information to send you communications that are tailored to your interests.
At any time, you can opt out of receiving such information, revise the products you would like to hear about or change the method we use to communicate with you. You can update these preferences by contacting us in the normal ways.
We also use your personal information to make decisions about what products, services and offers we think you may be interested in. This is called profiling for marketing purposes. You can contact us at any time and ask us to stop using your personal information this way. If you allow it, we may show or send you marketing material online (on our own and other websites including social media), or by email, phone or post.
We make outbound phone calls for a number of reasons relating to our services. We are fully committed to the regulations set out by Ofcom and follow strict processes to ensure we comply with them.
We may use personal data, collected in respect of one product to market another product that we may deem appropriate and relevant to you based on the information we have collected.
As previously mentioned, we do not sell, trade or rent your information, and will never disclose information about you (including information obtained from our dealings with you) to third parties, except:
a) where we have a legal interest in a company.
b) to fulfil your specific orders for a product or service or information in the event that third parties deliver the relevant product or service or information. In these instances, while the information you provide will be disclosed to them, it will only be used for the administration of the service provided, including (but not limited to), verification of any quote given to you, pricing purposes as appropriate, testing, and to maintain management information for business analysis.
c) where third parties administer part or all of the product or service. We may of course be obliged by law to pass on your information to the police or any other statutory or regulatory authority and in some cases, exemptions may apply under relevant data protection legislation, whereby we can legitimately release personal data e.g. to prevent or detect crime or in connection with legal proceedings.
d) data such as your existing information is shared within the Country Cousins Homecare Agencies / Corinium Care Limited / Trinity Homecare Group / Berkeley Home Health Limited / Fitzrovia Personal Homecare Limited / Genuine Care Homecare Services Limited group of companies in order that the services we provide to you can continue across the group. You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. You have the right to ask us to erase your personal information in certain circumstances.
Subsequent to your purchase of a product or service, we may enter into an arrangement for that service to be provided by a new third party. If this happens, the terms and conditions of your contract with us will provide that you consent to the transfer and processing of personal and/or special category personal data to the new provider, subject to the requirements of the GDPR and associated legislation.
If we provide information to a third party (either a provider of a product or service, or an external data processing agency such as a mailing house) or a company we have a legal interest in, we will exercise the strictest control over them contractually, requiring it and any of its agents and/or suppliers to:
a) Maintain the security and confidentiality of the information and restrict access to those of its own employees use the data for the agreed purpose only and prevent it being used for any other purpose by any other party refrain from communicating with you other than concerning the product in question.
b) Return the data to us at the conclusion of any contract term, and destroy or delete any copies made of all or any part of the information unless copies are needed to be kept to comply with regulations.
Automated decision making enables us to make efficient and fair decisions, providing a better service for our customers. Whilst you have the right to object to us using your information in this way, this could have an impact on the products or services we may be able to offer you. We use automated decision making in the following areas:
Country Cousins Homecare Agencies Limited, trading as Patricia White’s and Country Cousins, are the data controller in respect of your personal data. Under the Data Protection Act 2018 we are required to provide you with certain information about how we collect, store, share and retain your personal data.
The purposes for which we will process your personal data (whether provided by you or third parties) are as follows:
