Privacy Policy
We are Solstice Care Ltd, incorporated in England
. We are committed to ensuring that your privacy is protected. We comply with the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) unless and until the GDPR is no longer directly applicable in the UK, together with any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, and any successor legislation to the 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 [insert email address for DPO. If there is no DPO, delete reference to them].
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 to be added at a later date (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 Solstice Care Ltd hold and how will we use it?
Information you give Solstice Care 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 number
We will retain this information while we are corresponding with you or providing services to you or to a Service User you represent. We will retain this information during the time of enquiries and on file stored away. If you do not wish for Solstice Care to keep records, please contact us by email, and we will discuss your wishes further.
Information Solstice Care Ltd collects about you: Solstice Care Ltd may collect the following information from you when you visit the website:
l 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
l 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:
l 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
l Send you newsletters and marketing information if you have consented to us doing so
l 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
l 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
Solstice Care Ltd processes personal information for certain legitimate business purposes, which include some or all the following:
l Where the processing enables Solstice Care Ltd to enhance, modify, personalise or otherwise improve the website, its services or communications
l To identify and prevent fraud
l To enhance the security of the network and information systems of Solstice Care Ltd
l To better understand how people interact with the websites of Solstice Care Ltd
l To administer the website and carry out data analysis, troubleshooting and testing; and
l 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 the following webpage http://solsticecare.co.uk . 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 or by contacting us via the following webpage [insert webpage link] 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.
We may carry out automated decision-making using the personal data you provide to us. We do so to [insert an explanation about the automated decision-making (including profiling) that you carry out. You should explain the logic involved and the significance and potential consequences for the Data Subject. For example, if you track their behaviour on your website to send targeted advertising, explain this process. If you do not carry out any automated decision making, you can delete this policy entry].
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:
l Business partners, suppliers and sub-contractors for the performance of any contract we enter with them or you
l 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:
l 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
l Are under a legal duty to comply with any legal obligation or to enforce or apply our terms and conditions; or
l 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
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 webpage
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 webpage [insert webpage link]. 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 webpage [insert webpage link].
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 webpage [insert webpage link] or you can contact us by emailing [insert email address]. We also welcome your views about our website and our Privacy Policy.
Note: All QCS Policies are reviewed annually, more frequently, or as necessary.
Cookie Policy
4.1 Solstice Care Ltd understands that if it operates a website, it may need to update its Privacy Policy to ensure that it is compliant with GDPR. Solstice Care Ltd will use this Privacy Policy as a template for its updated version. Solstice Care Ltd understands that this Privacy Policy only needs to be uploaded
by Solstice Care Ltd to its website if it collects personal data via its website. Solstice Care Ltd will use the template Fair Processing Notice to inform all other Data Subjects, including Service Users, about
how Solstice Care Ltd processes personal data other than personal data collected via the website.
4.2 Solstice Care Ltd understands that the form found within the forms section of the GDPR suite of policies in the QCS management system constitutes the template Privacy Policy. Solstice Care Ltd understands that terms in square brackets are optional (depending on whether they apply to Solstice Care Ltd or not) or require completion by Solstice Care Ltd. Solstice Care Ltd will review the Privacy Policy in its entirety to determine which elements are applicable to its website, and which are not relevant.
For example:
l If the template Privacy Policy refers to personal data that is not collected by Solstice Care Ltd via its website, Solstice Care Ltd will delete references to such personal data
l If the website of Solstice Care Ltd does not use cookies, Solstice Care Ltd will delete references to cookies and the Cookie Policy at Solstice Care Ltd
l If Solstice Care Ltd does not transfer personal data outside of the EEA, Solstice Care Ltd will delete the section entitled "Where we store your personal data"
l If Solstice Care Ltd is not required to appoint a Data Protection Officer, Solstice Care Ltd will delete references to the Data Protection Officer or will consider replacing references to the Data Protection Officer with references to the Privacy Officer at Solstice Care Ltd or other person nominated to have day-to-day responsibility for data protection and GDPR
If Solstice Care Ltd uses personal data collected via its website in a way that is not described in the Privacy Policy, it will consider incorporating additional sections.
This Privacy Policy directs users to a webpage with a contact form or contact details if they wish to
contact Solstice Care Ltd. Solstice Care Ltd will consider whether to provide an alternative contact method instead, such as an email address and/or phone number.
If Solstice Care Ltd has any concerns or queries in respect of the template Privacy Policy, it will seek legal advice.
4.3 GDPR has changed the way cookies should be incorporated into websites which means that Solstice Care Ltd must explain what cookies will be set and what the cookies will do to the users of its website. Solstice Care Ltd must obtain consent from individuals to store certain cookies on devices. Cookies that are not strictly necessary need consent which is GDPR compliant which means that Solstice Care Ltd can no longer rely on implied consent. Solstice Care Ltd will ensure that it uses a cookie banner on its website to obtain consent to the use of cookies in line with this policy and that if no consent is obtained, no cookies will be set.
4.4 Solstice Care Ltd must, therefore, update its processes for collecting consent for cookies. In practice, this means:
l Users must take a clear and positive action to consent to non-essential cookies
l The websites and apps of Solstice Care Ltd must tell users clearly what cookies will be set and what they do, including any third-party cookies
l Pre-ticked boxes or any equivalents, such as sliders defaulted to “on”, cannot be used for non- essential cookies
l The users at Solstice Care Ltd must have control over any non-essential cookies
l Non-essential cookies must not be set on landing pages before you gain the user’s consent Consent is not required for cookies that are defined as “strictly necessary” or that fall within the
communication exemption. “Strictly necessary” cookies are those that are essential to providing the service
requested by the user. Such cookies must be essential to fulfil their request. Those that are simply helpful or convenient, but not essential, or that are essential for the purposes of Solstice Care Ltd, will still require consent. The communication exemption is about the transmission of a communication over an electronic communications network. For the exemption to apply, the transmission of the communication must be
impossible without the use of the cookie. Simply using a cookie to assist the communication is insufficient for the exemption to apply.
Solstice Care Ltd must note, in particular, that cookies used for analytical purposes or those used for marketing and advertising will always need consent as they are considered to be non-essential. This guidance may change as the latest draft legislation is subject to some challenges on this point.
Solstice Care Ltd must read the ICO’s cookie guidance available at: https://ico.org.uk/for- organisations/guide-to-pecr/cookies-and-similar-technologies/ for further information on the types of cookie that require consent.
5.1 Solstice Care Ltd will consider whether or not it collects personal data via its website (for example, via enquiry forms, requests to be sent newsletters, requests for provision of services) and whether it needs a Privacy Policy. Solstice Care Ltd acknowledges that the use of cookies constitutes processing of personal data via the website.
5.2 Solstice Care Ltd will review the template Privacy Policy. Solstice Care Ltd will adapt the Privacy Policy before uploading it to its website to ensure that all aspects of the Privacy Policy are relevant and reflect the ways in which Solstice Care Ltd processes personal data collected via its website. Where Solstice Care Ltd has any concerns or queries in relation to its own Privacy Statement, Solstice Care Ltd will seek legal advice.
5.3 Solstice Care Ltd will use the template Fair Processing Notice to inform all other Data Subjects, including Service Users, about how Solstice Care Ltd processes personal data other than personal data collected via the website.
6.1 Data Subject
l The individual whom Solstice Care Ltd has collected personal data
6.2 Data Protection Act 2018
l The Data Protection Act 2018 is a United Kingdom Act of Parliament that updates data protection laws in the UK. It sits alongside the General Data Protection Regulation and implements the EU's Law Enforcement Directive
6.3 GDPR
l General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union. It was adopted on 14 April 2016 and after a two-year transition period became enforceable on 25 May 2018
6.4 Personal Data
l Any information about a living person including but not limited to names, email addresses, postal addresses, job roles, photographs, CCTV and special categories of data, as defined below
6.5 Process or Processing
l Doing anything with personal data, including but not limited to collecting, storing, holding, using, amending or transferring it. Solstice Care Ltd does not need to be doing anything actively with personal data - at the point Solstice Care Ltd collects it, it is processing it
6.6 Special Categories of Data
l Has an equivalent meaning to "Sensitive Personal Data" under the Data Protection Act 2018. Special categories of data include but are not limited to medical and health records (including information collected as a result of providing health care services), Care Plans and information about a person's religious beliefs, ethnic origin and race, sexual orientation and political views
6.7 Cookies
l Cookies are small files which are stored on a user's computer. They are designed to hold a modest amount of data specific to a particular client and website and can be accessed either by the web server or the client's computer
6.8 The Information Commissioner's Office (ICO)
l The ICO is the UK's independent body set up to uphold information rights
Professionals providing this service should be aware of the following:
l The Privacy Policy applies to personal data collected via the website of Solstice Care Ltd
People affected by this service should be aware of the following:
l Personal data provided to Solstice Care Ltd via its website will be processed in accordance with the Privacy Policy at Solstice Care Ltd
As well as the information in the 'underpinning knowledge' section of the review sheet we recommend that you add to your understanding in this policy area by considering the following materials: