Privacy and Cookies Notice

We are Say Opal Ltd, a [company] incorporated in [England and Wales] [Scotland].

(“Say Opal Ltd” / “we” / “our” / “us“). 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 [email protected] as well as at the office address

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/.

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 www.sayopalhealthcare.co.uk (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 do we hold and how will we use it?

Information we collect from you or about you:

We will collect and process the following types of information:

Identity and contact details you give us you may give us information about you by completing enquiry forms on the website/filing in forms on the Application. The information you give us may include your name, DOB, postal address, job title, role, nationality, email address/location, telephone, interest, information about your membership of professional bodies or the Website or by requesting via the website that we send you marketing information

Special category we collect information we need for the particular at the time, this include criminal record history (DBS), biometric data, occupation health records, religious beliefs, your sexuality, ethnic origin, mental wellbeing and genetic data

Profile and usage data if you sign up to receive marketing communication from us about products, events at Say Opal Ltd and services we offer

If you provide feedback or complete a survey

When you download or register to use the application and when you complete the sign up form through the website

Business information if you contact or correspond with us for instance by phone, email or otherwise, please note the information you or the organisations provide to us. We also recommend you check the organisations privacy policy

Technical Data see our Website Terms of Use and Cookies Policy below

We may collect the following information from you when you visit the website:

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

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

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 for [ the relevant retention period for the types of personal data listed above. Refer to the Records Management Code of Practice for Health and Social Care if required].

Your Rights

If any of the information you provide to us 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.

The law gives you a number of rights in relation to your personal data:

The right of access, this enable you to receive a copy of the personal data

 The right to have your data deleted (unless we have the legal right to retain it )

 The right to have your data rectify

 The right to transfer your data to another data controller if legal basis for processing is consent

 The right to object to certain type of processing your personal data

Though not all these rights apply in all situations sometime conclusion on the law based and best interest of the persons concerned

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. We shall process your request to access your information within one month of receipt, or we’ll let you know within that timeframe if we need more information from you.

Complaints: if you have any complaints about our use of your personal data, please contact us [email protected] If you are still not happy, 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/.

Changes to this Privacy and cookies policy

We may need to change this notice from time to time to reflect changes to the law or personal data, we reserve the right to make those changes as necessary and recommend you revisit the website from time to time, where appropriate we will notify you by email.

Continued use of the Website or the Application (as appropriate) will signify that you agree to such changes

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. We will retain this information for [the relevant retention period for the types of personal data listed above].

Are we allowed to collect this information

We only begin processing your information after you have given your consent.

We rely on one of the legal justifications which are set out in the GDPR and on ICO website.

These include processing which are Necessary

o To conduct our business and pursue our legitimate interests

o To comply with compliance, checks and the law

o To provide you with social care, medicine and assist in the management of social care arrangement

o To fulfill a contract with you or your organisation

We may ask you to show proof of your ID

Security

Say Opal maintain technical and administrative systems, processes, policies and procedures designed to keep all information you provide to us is stored on secure and safe.

Our staffs are trained on how to protect your privacy as well as a duty of confidentiality. We ensure that anyone we share your personal data with maintain appropriate level of security in respect of your personal data we process. We cannot guarantee the security of your data transmitted to the website or application and you acknowledge that any transmission is at your own risk.

Our other privacy notice are

Recruitment and Staffing Privacy Notice

Service Users Privacy Notice

Carers Family and Friends Privacy Notice

Sales and Marketing Privacy Notice

And Other Policies

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

By clicking “Accept Cookies” on the cookies consent box when you access the website and by continuing to access and browse this website you accept our use of cookies.

You can block cookies by activating the setting on your browser that allows you to refuse some cookies. To find out more about cookies plus how to see what cookies have been see and how to manage and delete them please visit www.allaboutcookies.org

Most web browser allow some control of most cookies through the browser settings and how to manage cookies on popular web browsers: Google Chrome, Safari, Mozilla Firefox, Microsoft Edge and Microsoft Internet Explorer

To opt out of being tracked by Google Analytics across all websites please visit https://tools.google.com/dlpage/gaoptout

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.

How to contact us

Please contact us to update or amend any of your personal data which you have provided to us. Better still for Feedback/Comments or Question regarding Say Opal are welcome and should be address to our Northampton office at Regus House, by post or email [email protected] Copyright ©Say Opal Ltd. ®Say Opal and the logo are registered trademarks of Say Opal Healthcare Ltd. Say Opal Ltd Trading as Say Opal Healthcare All rights reserved

Use Made of the Information

We may use the information we receive and/or collect about you to:

Fulfill 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

Send you newsletters and marketing information if you have consented to us doing so

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

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

We processes personal information for certain legitimate business purposes, which include some or all the following:

Where the processing enables us to enhance, modify, personalize or otherwise improve the website, its services or communications

To identify and prevent fraud

To enhance the security of the network and information systems

To better understand how people interact with the websites of Say Opal Ltd

To administer the website and carry out data analysis, troubleshooting and testing; and

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. 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 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. Copyright ©Say Opal Ltd. ®Say Opal and the logo are registered trademarks of Say Opal Healthcare Ltd. Say Opal Ltd Trading as Say Opal Healthcare All rights reserved

Disclosure of your Information

We have processes and systems in place to ensure that sharing only take place when is appropriate and lawful.

We may share your 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:

With the organisations that commission our services for service users for example NHS England.

With other health and social care providers, clinicians and administrators where this is necessary to help us provide our service and to protect your interest and vital interests of another individual

Business partners, suppliers and sub-contractors for the performance of any contract we enter with them or you.

With sub-contractors and service providers under contractual terms which provide appropriate safeguards for your privacy and confidentiality.

With the regulators, local authorities, government departments and agencies, law enforcement authorities, police, with the courts and expert witnesses where necessary in order to meet our legal obligations.

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:

Sell any or all 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

Are under a legal duty to comply with any legal obligation or to enforce or apply our terms and conditions; or

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

Where we Store your Personal Data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) to [insert the reasons why personal data is transferred outside the EEA, for example, because it is hosted on a server outside the EEA]. By submitting your personal data, you agree to this transfer, storing or processing. Say Opal Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. If a finding of adequacy hasn’t been made by the EC Commission in respect of the country to which the data is transferred, we will only transfer it where there are appropriate safeguards in place, including the use of EU standard contractual clauses or an intragroup agreement.

Retaining Personal Data

We only retain your personal data for as long as necessary of fulfill the purposes it was collected, such as fulfilling any legal requirements. The duration that personal data is retained is dependent on each individual case, as we take in the sensitivity, nature risk of having your data. We can make your personal data anonymous so it can no longer be associated with you, whereby we may use said information without further notice being given to you. Despite a request to delete personal data, we may still need to keep it, or keep it in a way that does not identify you. If your personal data is being processed as part of a contract and you haven‟t consented for us to use it for marketing, we will retain it for the period of the contract and an additional 12 months.