Privacy Policy

Migrated from the previous NL Group website. Please review for accuracy before public launch.

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1. Purpose

1.1 To provide a template Privacy Policy that NL Group Limited can adapt to use on their website.

1.2 By using the template Privacy Policy provided, NL Group Limited will ensure that the policy on their website is UK GDPR compliant.

1.3 To support NL Group Limited in meeting the following Key Lines of Enquiry/Quality Statements (New):

1.4 To meet the legal requirements of the regulated activities that {NL Group Limited} is registered to provide:

The Privacy and Electronic Communications (EC Directive) Regulations 2003
Data Protection Act 2018
UK GDPR

2. Scope

2.1 The following roles may be affected by this policy:

All staff

2.2 The following Service Users may be affected by this policy:

Service Users

2.3 The following stakeholders may be affected by this policy:

Family
Advocates
Representatives
Commissioners
External health professionals
Local Authority
NHS

3. Objectives

3.1 To provide assurance that NL Group Limited has a Privacy Policy in place for users of its website that is UK GDPR compliant.

3.2. To establish ways of working in terms of the use, storage, retention and security of personal data.

3.3 To ensure that all Data Subjects, including Service Users, understand the ways in which their personal data is collected and processed by NL Group Limited via their website.

4. Policy

4.1 NL Group Limited understands that if they operate a website, they need to update their Privacy Policy to ensure that it is compliant with UK GDPR. NL Group Limited will use this Privacy Policy as a template for its updated version.

NL Group Limited understands that this Privacy Policy only needs to be uploaded to their website if personal data is collected via the website.

NL Group Limited will use the Fair Processing Notice template to inform all Data Subjects, including Service Users, how their personal data is processed.

4.2 NL Group Limited understands that the Privacy Policy template can be found in the UK GDPR suite within the QCS management system.

NL Group Limited understands that terms in square brackets are optional (depending on whether or not they apply to NL Group Limited).

NL Group Limited must review the Privacy Policy in its entirety to determine which elements are applicable to its website, and which are not relevant.

For example:

If NL Group Limited does not transfer personal data outside of the EEA, they will delete the section entitled “Where we store your personal data”
If NL Group Limited is not required to appoint a Data Protection Officer, they will delete references to the Data Protection Officer
NL Group Limited may consider replacing Data Protection Officer references with ‘Privacy Officer’ instead, referencing the person nominated to have day-to-day responsibility for data protection and UK GDPR

This Privacy Policy directs users to a webpage with a contact form or contact details if they wish to contact NL Group Limited. NL Group Limited will consider whether to provide an alternative contact method instead, such as an email address and/or phone number.

If NL Group Limited has any concerns or queries in respect of the template Privacy Policy, they must seek legal advice.

4.3 UK GDPR has changed the way cookies should be incorporated into websites which means that NL Group Limited must explain what cookies will be set and what the cookies will do to the users of its website. NL Group Limited must obtain consent from individuals to store certain cookies on devices. Cookies that are not strictly necessary, need consent which is UK GDPR compliant, this means that NL Group Limited can no longer rely on implied consent.

NL Group Limited 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 NL Group Limited must, therefore, update its processes for collecting consent for cookies. In practice, this means:

Users must take a clear and positive action to consent to non-essential cookies
The websites and apps of NL Group Limited must tell users clearly what cookies will be set and what they do, including any third-party cookies
Pre-ticked boxes or any equivalents, such as sliders defaulted to “on”, cannot be used for non- essential cookies
The users at NL Group Limited must have control over any non-essential cookies
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 NL Group Limited, 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.

NL Group Limited 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.

NL Group Limited 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. Procedure

5.1 NL Group Limited 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. NL Group Limited acknowledges that the use of cookies constitutes processing of personal data via the website.

5.2 NL Group Limited 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 NL Group Limited processes personal data collected via its website.

Where NL Group Limited has any concerns or queries in relation to its own Privacy Statement, NL Group Limited will seek legal advice.

5.3 NL Group Limited will use the Fair Processing Notice template to inform all other Data Subjects, including Service Users, about how NL Group Limited processes personal data other than personal data collected via the website.

6. Definitions

6.1 The Information Commissioner’s Office (ICO)

The ICO is the UK’s independent body set up to uphold information rights

6.2 Data Subject

The individual whom NL Group Limited has collected personal data

6.3 Data Protection Act 2018

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

6.4 UK GDPR

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 became enforceable on 25 May 2018
References to GDPR include references to the UK GDPR
The UK GDPR is the retained EU law version of GDPR that forms part of English law

6.5 Personal Data

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

6.6 Process or Processing

Doing anything with personal data, including but not limited to collecting, storing, holding, using, amending or transferring it. NL Group Limited does not need to be doing anything actively with personal data – at the point NL Group Limited collects it, it is processing it

6.7 Special Categories of Data

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

6.8 Cookies

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

Key Facts – Professionals

Professionals providing this service should be aware of the following:

Key Facts – People affected by the service

People affected by this service should be aware of the following:

Outstanding Practice

To be ‘ outstanding ’ in this policy area you could provide evidence that:

The wide understanding of the policy is enabled by proactive use of the QCS App

Forms

The following forms are included as part of this policy:

Let’s talk…

Contact us today to find out more or call us on 01482 60 60 40. To join our roster of dedicated professionals, please visit our vacancies page vacancies.nlgroup.co.uk

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Privacy policy