Flexible Options Limited customer privacy notice
This privacy notice tells you what to expect us to do with your personal information.
• Contact details
• 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
• How to complain
Contact details
Post
Transport House, Cardiff Road, , NEWPORT, Gwent, NP20 2EH, GB
Telephone
01633 760526
What information we collect, use, and why
We collect or use the following information to provide service user support & services:
• Name, address and contact details
• Gender
• Pronoun preferences
• Date of birth
• Next of Kin details including any support networks
• Emergency contact details
• Photographs
• Health information (including medical conditions, allergies, medical requirements and
medical history)
• Information about care needs (including disabilities, home conditions, medication and
dietary requirements and general care provisions)
• Payment details (including card or bank information for transfers and direct debits)
• Insurance policy details
• Records of meetings and decisions
We also collect the following special category information to provide service user support & services:
This information is subject to additional
protection due to its sensitive nature:
• Racial or ethnic origin
• Religious or philosophical beliefs
• Health information
We collect or use the following personal information for the prevention, detection or
investigation:
• Name, address and contact details
• Witness statements and contact details
• Relevant information from previous investigations
We collect or use the following information for safeguarding or public protection reasons:
• Name, address and contact details
• Emergency contact details
• Photographs
• Health information (including medical conditions, allergies, medical requirements and
medical history)
• Relevant information from previous investigations
• Records of meetings and decisions
We also collect the following special category information for safeguarding or public
protection reasons. This information is subject to additional protection due to its sensitive
nature:
• Racial or ethnic origin
• Religious or philosophical beliefs
• Health information
We collect or use the following personal information to comply with legal requirements:
• Name
• Contact information
• Identification documents
• Health and safety information
• Any other personal information required to comply with legal obligations
• Right to work
• Insurance details
• Tax information
• Criminal offence data
We collect or use the following personal information for recruitment purposes:
• Contact details (eg name, address, telephone number or personal email address)
• Date of birth
• National Insurance number
• Copies of passports or other photo ID
• Employment history (eg job application, employment references or secondary
employment)
• Education history (eg qualifications)
• Social media
• Right to work information
• Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI
or Disclosure Scotland checks )
We also collect the following special category information for recruitment purposes. This
information is subject to additional protection due to its sensitive nature:
• Racial or ethnic origin
• Religious or philosophical beliefs
We collect or use the following personal information for dealing with queries, complaints
or claims:
• Names and contact details
• Addresses
• Witness statements and contact details
• Relevant information from previous investigations
Customer or client accounts and records
• Information relating to health and safety (including incident investigation details and
reports and accident book records)
• Correspondence
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 provide patient care,
services, pharmaceutical products and other goods 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.
• 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.
Our lawful bases for collecting or using personal information for the prevention, detection,
investigation or prosecution of crimes 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.
• 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.
Our lawful bases for collecting or using personal information for safeguarding or public
protection reasons 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.
• 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.
Our lawful bases for collecting or using personal information to comply with legal
requirements 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.
• 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.
Our lawful bases for collecting or using personal information for recruitment 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.
• 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.
Our lawful bases for collecting or using personal information for dealing with queries,
complaints or claims 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.
• 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.
Where we get personal information from
• Directly from you
• Family members or carers
• Other health and care providers
• Social services
• Insurance companies
• Councils and other public sector organisations
• Previous employers
• Social media
How long we keep information
Client information is kept for 7 years, enquiry information is kept for 1 year
Who we share information with
Others we share personal information with
• Organisations we need to share information with for safeguarding reasons
• Local authorities or councils
• Publicly on our website, social media or other marketing and information media
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’ve provided us with your consent (we have taken it as implied to provide you
with care, or you have given it explicitly for other uses);
• we 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: contact@flexibleoptions.co.uk
Telephone: 01633 760526
Post: Transport House, Newport, NP20 2EH
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:
ICO Head Office
4th Floor, No.3 Circle Square
5 Hawkshaw Street
Manchester
M1 7BL
Helpline number: 0303 123 1113