Brio Retirement Living (Holdings) Ltd (England) and Brio Retirement Living (Chapelton) Ltd (Scotland) is committed to protecting your privacy when you use our services.
The privacy notice below explains how we use information about you and how we protect your privacy.
Who are we?
This privacy notice (the “Privacy Notice”) applies to all personal information processing activities carried out by Brio Retirement Living (Holdings) Ltd (England) and Brio Retirement Living (Chapelton) Ltd (Scotland).
Brio Retirement Living is a data controller in respect of personal information that we process in connection with our business (including the products and services that we provide).
Our principal address is 305 Gray’s Inn Road, London, WC1X 8QR.
Brio Retirement Living is part of Places for People Group. More information about the Places for People Group can be found at https://www.placesforpeople.co.uk/about-us/about-the-group/.
We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this privacy notice is to explain how we collect and use personal information in connection with our business.
We may update our privacy notice from time to time. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.
Why we collect your personal information
Do you know what personal information is?
Personal information can be anything that identifies and relates to a living person. This can include information that when put together with other information can then identify a person.
Information we may collect about you may include (but is not limited to):
- Name
- Address
- Telephone numbers
- Email addresses
- Data of birth
- Bank details
- Employment details – if applicable
- Communication formats
- Identification documents
- Care and support service needs and preferences
- Photographs
We may also collect personal information from others with whom you live or receive service from us – this may include:
- Family and household members
- Friends and visitors
- Members of public
- Representatives
- Enquirers
Did you know that some of your personal information might be classified as ‘special’?
Some information is ‘special’ and needs more protection due to its sensitivity. It’s often information you would not want widely known and is very personal to you. This is likely to include anything that can reveal information relating to your:
- Sexuality and sexual health
- Religious or philosophical beliefs
- Ethnicity
- Physical or mental health
- Trade union membership
- Political opinion
- Genetic/biometric data
- Financial
- Dietary requirements
This information is collected as part of your care and support assessments. We will only collect this type of information if it is necessary to your contract so that we can provide the right services to you.
We may at times need to share this information we will only do this if we have your consent or if there are legal requirements for us to do so.
If we ask for any sensitive personal data about you, we will always tell you why we need it and ask for your consent to hold it.
Why do we need your personal information?
We may need to use some information about you to:
- Deliver services and support to you
- Manage those services we provide to you
- Service improvement
- Prevention/detection of crime/fraud
- Help investigate any complaints you have about your services
- Check the quality of services
- To help with research and planning of new services
How the law allows us to use your personal information
There are a number of legal reasons why we need to collect and use your personal information.
Generally we collect and use personal information for the purposes of where:
- You are entering or have entered into a contract with us
- You, or your legal representative, have given consent
- It is required by law
Consent & your preferences
We may contact you or send communications to tell you about a service enhancement such as improvements to our online services or to keep you informed on how we are performing. We won’t need your consent to communicate with you this way because we have assessed that it forms part of our agreement with you and it is in our legitimate interest or of mutual interest for us to keep you informed and is relevant to your contract with us.
We will provide an unsubscribe option on communications where you have a choice to object. You can also update your communications preferences at any time by contacting us at marketing@brioretirement.co.uk.
We only use what we need
Where we can, we’ll only collect and use personal information if we need it to deliver a service or meet a requirement.
If we don’t need personal information we’ll either keep you anonymous if we already have it for something else or we won’t ask you for it. For example in a survey we may not need your contact details so we’ll only collect your survey responses.
If we use your personal information for research and analysis, we’ll keep you anonymous or use a different name unless you’ve agreed that your personal information can be used for that research.
We won’t sell your personal information to anyone else.
We may share your information with other companies within our group, we will always ask for your consent to do this and you can ask us to stop at any time.
We will always provide an option for updating your marketing preferences on our communications with you.
Visiting our websites
When you visit one of our websites, we collect standard internet log information for statistical purposes.
- We use cookies to collect information in an anonymous way, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
- We do not make any attempt to identify visitors to our websites. We do not associate information gathered from our sites with personally identifying information from any source.
- When we collect personal information, for example via an online form, we will explain what we intend to do with it.
Our websites contain links to various third party websites. We are not responsible for the content or privacy practices of any external websites that are linked from our sites.
How we use your telephone number & email address
Text messages and contact via telephone or email provide a direct way to contact and share information with you about the services we can deliver to you. It can also help you receive important messages about your home/community or which may interest or a help to you such as new online services.
If you provide your telephone number or email address we may keep in contact with you by these methods.
Operational SMS/text/email messaging & calls
If you supply us with your telephone or email contact details, we may use them to call or send you operational information. Examples of operational messages include:
- Confirming a repair and/or a time and date for a repairs contractor to visit
- Confirming a home visit
- Sending a reminder about an appointment
- Satisfaction surveys
- Checking that we have the correct contact details for you
Sharing your telephone number with third parties
We may pass your telephone number to third parties so that we can meet our contractual obligations with you. We may also share your telephone numbers if we are required to by law.
We may supply the details to our approved third party contractors who are delivering or performing services on our behalf, and these companies must not use your information for any other purpose. We never share or sell your telephone numbers to telesales/marketing companies.
Communicating with you
We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes of improving our service to you.
Who do we share your information with?
We use a range of organisations to either store personal information or help deliver our services to you. Where we have these arrangements there is always an agreement in in place to make sure that the organisation complies with data protection law.
We are likely to share your personal information with the following:
- CCTV
We use CCTV systems in some locations. CCTV is installed for the purpose of preventing and detecting crime. - Mailing companies
We may share your name and address with external mail out companies who we have appointed to assist us with mail distribution. - Utility companies
We may need to share your personal information with utility companies [gas, electric, water] and local authorities for the purpose of ensuring utility services and council tax to the property are correctly charged. We may pass on your details after you have left us if there are arrears with a utility or local authority for services received. - Legal services and partners
We may share your personal information with our legal services or solicitors if we are preparing or defending a legal claim. - Places for People group companies
We may share your information with shared service functions within the Places for People group, such as for the purpose of financial transaction when making payments to us or the insurance functions if you make a claim. Places for People group shared services comply with and process personal information within the same privacy standards and procedures. - Safeguarding, Support Agencies and Charities
We may share your personal information with these organisations where we suspect there may be safeguarding or welfare concerns. We will usually try to gain your consent in advance, but we may make a safeguarding referral without consent in situations where we feel there is a significant risk.
Where there is a high risk to your personal information we will complete a privacy assessment before we share personal information to make sure we protect privacy and comply with the law.
Keeping your information secure
We store personal information both electronically and in paper form.
We implement security policies, processes and technical security solutions to protect the personal information we hold from:
- Unauthorised access
- Improper use or disclosure
- Unauthorised modification
- Unlawful destruction or accidental loss
We’ll do what we can to make sure we hold records about you (on paper and electronically) in a secure way, and we’ll only make them available to those who have a right to see them.
Examples of our security include:
- Encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password). This is done with a secret code or what’s called a ‘cypher’. The hidden information is said to then be ‘encrypted’
- Pseudonymisation, meaning that we’ll use a different name so we can hide parts of your personal information from view. This means that someone outside of the Places for People Group could work on your information for us without ever knowing it was yours
- Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it
- Training for our staff allows us to make them aware of how to handle information and how and when to report when something goes wrong
- Regular testing of our technology and ways of working including keeping up to date on the latest security updates (commonly called patches)
When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, solicitors) act on your behalf we will take steps to ensure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.
Employees and third parties who have access to, or are associated with the processing of, your personal information are obliged to make reasonable efforts to safeguard it.
Where in the world is your information?
Your personal information is stored on systems in the UK. But there may be some occasions as our technology services progress where your information may leave the UK either in order to get to another organisation or if it’s stored in a system outside of the EU.
We will always have additional protections on your information if it leaves the UK ranging from secure ways of transferring data to ensuring we have a robust contract in place with that third party.
We’ll take all practical steps to make your personal information is not sent to a country that is not seen as ‘safe’ either by the UK or EU Governments.
How long do we keep your personal information?
There’s often a legal or a contractual reason for keeping your personal information for a set period of time. We will keep your information for the duration of providing a service or product to you under the terms of a contract, such as your tenancy agreement. When your contract has ended we will keep your personal data for a set time for auditing and reporting purposes and for legitimate interest purposes, after that time we will either anonymise or destroy your information.
You can ask us for a copy of our retention periods by contacting us at enquiries@brioretirement.co.uk or by phoning 020 7429 0400
Your rights
The law gives you a number of rights to control what personal information is used by us and how it is used by us. You can contact us regarding any of the rights below by contacting us at: enquiries@brioretirement.co.uk. We will deal with your request within one month from receiving your request and if we need additional information from you to identify you we will ask for this without undue delay.
You can ask for access to the information we hold about you.
You have the right to ask for the information we have about you. When we receive a request from you in writing, we must give you access to what personal information we’ve recorded about you.
A request for personal information can be made via email or in writing. This is known as a subject access request. In order to make a subject access request you will need to provide the following information:
- Your name
- Your address
- Enough information to identify your records
If we have doubts about your identity or we are finding it difficult to locate your personal information we may ask you to provide us with proof of identity.
What types of documents could I submit as proof of ID?
- Copy passport with signature (please remove your passport number)
- Copy driving license picture with signature (please remove your driver number)
- Copy of signed contract with us
Email us at enquiries@brioretirement.co.uk (please ensure you attach enough information for us to identify your records).
Once you have made a request you will receive an acknowledgement and your request should be answered within one month. In certain circumstances, we are allowed to take longer but we will tell you if we feel we may need longer without undue delay from when we receive your request.
We can refuse to handle your request for access if it is manifestly unfounded or excessive.
You can ask to change information you think is inaccurate
You should let us know if you disagree with something we may have recorded about you.
We may not always be able to change or remove that information but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.
You can ask to delete information (right to erasure)
In some circumstances you can ask for your personal information to be deleted, for example:
- Where your personal information is no longer needed for the reason why it was collected in the first place
- Where you have removed your consent for us to use your information (where there is no other legal reason us to use it)
- Where there is no legal reason for the use of your information
- Where deleting the information is a legal requirement
- Where your personal information has been shared with others, we’ll do what we can to make sure those using your personal information comply with your request for erasure
Please note that we can’t delete your information where:
- You have an account with us such as an application or a tenancy
- We’re required to have it by law
- It is for historical research, or statistical purposes where it would make information unusable
You can ask to limit what we use your personal data for
You have the right to ask us to restrict what we use your personal information for where:
- You have identified inaccurate personal information, and have told us of it
- Where we have no legal reason to use that information but you want us to restrict what we use it for rather than erase the information altogether
We will assess whether you have a right to a restriction and where restriction of use has been granted, we’ll inform you before we carry on using your personal information.
Where possible we’ll seek to comply with your request, but we may need to hold or use information because we are required to by law or we have a legal basis to do so, such as a contract.
You can ask to have your information moved to another provider (data portability)
You have the right to ask for your personal information to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.
However this only applies if we’re using your personal information with consent (not where we are processing your personal information for contractual, legitimate interests, legal obligations or vital interests as a legal basis) and if decisions were made by a computer and not a human being.
It’s likely that data portability won’t apply to most of the services you receive from Brio Retirement Living.
Right to understand automated decisions made about you
We do not process your personal data using automated decisions
You also have the right to object if you are being ‘profiled’. Profiling is where decisions are made about you based on certain things in your personal information, e.g. your health.
If and when your personal information is used to profile you, in order to deliver the most appropriate service to you, you will be informed.
How to tell us of a data breach
Brio Retirement Living and Places for People group takes responsibility to protect the personal information we hold about those with whom we work seriously. We are accountable for our processing and take necessary technical and operational steps to information security protections.
If you suspect your personal information or that of others may have been at risk of a data protection breach please contact us.
Where can I get advice?
Places for People group have a Data Protection Officer who makes sure we respect your rights and follow the law. If you have any concerns or questions about how we look after your personal information, please contact the Group Data Protection Officer at data.protection@placesforpeople.co.uk.
For independent advice about data protection, privacy and data sharing issues, you can contact the Information Commissioner’s Office (ICO) at: https://ico.org.uk/make-a-complaint/
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Tel: 0303 123 1113 (local rate)
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