Privacy Policy

Introduction

Glenholme is committed to protecting the privacy and security of your personal data. This Privacy Notice describes how Glenholme collects and processes personal data about you when you use our website, our services, and/or visit one of our locations.

This Privacy Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties. This Privacy Notice also describes your rights regarding the personal data that we hold about you including how you can access, correct, and request erasure of your personal data.

We will only process your personal data in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

There are separate privacy notices applicable for our staff and residents.

Collection of Personal Data

For the purposes of this Privacy Notice, personal data means any information about an identifiable individual. Personal data excludes anonymous or de-identified data that is not associated with a particular individual.

To carry out our services, we may collect, store, and process the following categories of personal data:

Personal contact details such as name, title, date of birth, addresses, telephone numbers, and personal email addresses
Gender
Marital and dependent status
Emergency contact information, for example, nominated family and friends
Bank account details
Photograph
CCTV footage
Call recordings, transcripts, and call data (see below for details)
Usage data, such as information about how you interact with and use our website and services
Marketing and communications data, such as your preferences in receiving marketing from us and our third parties and your communication preferences

We will collect the majority of the personal data that we process directly from you. In limited circumstances, third parties may provide your personal data to us, such as family members, carers and/or medical professionals.

Use of Personal Data

We only process your personal data where applicable law permits or requires it, including where the processing is necessary for the performance of our contract for services with you, for our legitimate interests or the legitimate interests of third parties, to protect your vital interests, or with your consent if applicable law requires consent.

In addition to the purposes set out above, calls made to or from telephone numbers published on our website may be recorded and transcribed by a third-party service provider acting on our behalf. This is done for the following purposes:

Staff training, coaching, and performance monitoring
Quality assurance and service improvement
Complaint handling, investigation, and dispute resolution
Compliance with our legal and regulatory obligations

The following may be collected as part of call processing:

Voice recordings of calls
Transcripts of calls (automated or manually corrected)
Call data, including caller contact details (such as full name, telephone number, email, and address), and care-related enquiry details (such as who requires care, when care is needed, type of funding, type of care, and length of stay)

Retention periods for call data:

Voice recordings: retained for a maximum of 45 days from the date of the call
Transcripts: retained for a maximum of 2 years from the date of the call
Call data (including contact and care enquiry details): retained for a maximum of 3 years from the date of the call

After these periods, call data is securely deleted or anonymised unless it is required for an ongoing complaint, dispute, investigation, or to comply with legal obligations. Access to call data is restricted to authorised personnel only. Our third-party call recording provider only processes data under our instruction and in compliance with data protection laws.

Collection and Use of Special Categories of Personal Data

We may collect and process the following special categories of personal data when you voluntarily provide them for the following legitimate business purposes. Where we have a legitimate need to process special categories of personal data for purposes not we will only do so only after providing you with notice and, if required by law, obtaining your prior, express consent.

We will always treat special categories of personal data as confidential and we will only share such data internally where there is a specific and legitimate purpose for sharing the data. As set out below, we have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure.

We will only retain special categories of personal data for as long as necessary to fulfil the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes.

Data Sharing

We will only disclose your personal data to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering our relationship with you, including third-party service providers who provide services to us or on our behalf. Third-party service providers may include, but are not limited to, healthcare professionals and local authorities, and data storage or hosting providers. These hosting providers may be located outside of the UK.

We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us as your employer. We do not permit our third-party service providers who process your personal data on our behalf to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions.

We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:

When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.
To protect the rights and property of Glenholme.
During emergencies or when necessary to protect the safety of persons
If a business transfer or change in ownership occurs, the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is necessary, and we will anonymise the data where possible.
For additional purposes with your consent, where such consent is required by law

Marketing

You will receive marketing communications from us if you have requested information from us or purchased services from us.

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at marketing@glenholme.org.uk or at 79 High Street, Eton SL4 6AF.

If you opt out of receiving marketing communications, you may still receive service-related communications that are essential for administrative or customer service purposes for example relating to a appointment reminders, updates to our terms and conditions, checking that your contact details are correct.

Cross-Border Data Transfers

We do not store and process your personal data outside the UK.

Data Security

We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means. We specify the retention periods for your personal data in our data retention policy.

Under some circumstances, we may anonymise your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. We will retain and securely destroy your personal data in accordance with our document retention policy and applicable laws and regulations.

Rights of Access, Correction, Erasure, and Objection

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

By law you may have the right to request access to, correct, and erase the personal data that we hold about you, or object to the processing of your personal data under certain circumstances. You may also have the right to request that we transfer your personal data to another party.

How to make a Subject Access Request (SAR):
If you wish to make a request to access your personal data, you must do so using the Information Commissioner’s Office (ICO) online form, available at: https://ico.org.uk/for-the-public/make-a-subject-access-request/.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes.

Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Data Protection Officer

We have appointed a Data Protection Officer to oversee compliance with this Privacy Notice.

If you have any questions about this Privacy Notice or how we handle your personal data, please contact the Data Protection Officer at: data@glenholme.org.uk or at 79 High Street, Eton SL4 6AF.

If you are unsatisfied with our response to any issues that you raise with the Data Protection Officer, you may have the right to make a complaint with the Information Commissioner’s Office.

Data Protection Registration Number: ZA194097

Changes to This Privacy Notice

We reserve the right to update this Privacy Notice at any time.

If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose.

We may process your personal data without your knowledge or consent where required by applicable law or regulation.

Contact Us

If you have any questions about our processing of your personal data, please contact the Data Protection Officer at: data@glenholme.org.uk or at 79 High Street, Eton SL4 6AF.

Effective Date: 9 July 2025