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GDPR Privacy Notice - Service Users

  1. Principles

For us to provide care and support services to those we support we collect and use certain personal information about you.  Personal information means any information about you from which you can be identified, but it does not include information where your identity has been removed (anonymous data).

As the ‘controller’ of personal information, we are responsible for how that data is managed. The General Data Protection Regulation (GDPR), which applies in the United Kingdom and across the European Union, sets out our obligations to you and your rights in respect of how we manage your personal information.    As the ‘controller’ of your personal information, we will ensure that the personal information we hold about you is:

  • Used lawfully, fairly and in a transparent way

  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes

  • Relevant to the purposes we have told you about and limited only to those purposes

  • Accurate and kept up to date

  • Kept only as long as necessary for the purposes we have told you about

  • Kept securely

2. Please note when we refer to the following

A ‘public body‘ we mean any organisation in the United Kingdom which delivers, commissions or reviews a public service and includes (but is not limited to) the Ombudsman, local authorities, councils, unitary authorities, clinical commissioning groups, health and social care trusts, the National Health Service as well as their arm’s length bodies and regulators.

A ‘health or social care professional‘ we mean any person who provides direct services, acts as consultant or is involved in the commission of your healthcare or social care services, including (but not limited to) your general practitioner (GP), dental staff, pharmacists, nurses and health visitors, clinical psychologists, dieticians, physiotherapists, occupational therapists, hospital staff, social workers and other care and support related professionals.

The personal information we collect and use in relation to people who enquire about and use our services

3. Information collected by us

When you enquire about our care and support services through our website, phone, email, post, face to face or social media, and during the course of providing care and support services to you we collect the following personal information when you provide it to us:

  • Your name, home address, date of birth and contact details (including your telephone number, email address) and emergency contacts (i.e. name, relationship and home and telephone numbers)

  • Contact details for your GP, your allergies and any medical, physical, or mental conditions and in particular your care needs

  • Your likes, dislikes and lifestyle preferences (Including your religious beliefs or other beliefs of a similar nature, racial or ethnic origin, health and sexual orientation (so far as they relate to providing you with suitable care)

  • Credit/Debit card, direct debit details or other payment information (if you pay for some or all of our services using one of these methods)

  • Your feedback and contributions to questionnaires and surveys about the services we offer

  • Audio recordings of phone calls to and from our office teams

  • Your complaints, compliments or concerns about the service we provide

  • Any accidents and incidents or near misses you may have been involved in whilst on our premises or whilst our employees are delivering a regulated service to you – this may include details or injuries and treatment you may have received .

When using our website, we collect standard internet log information (commonly known as cookies), including:

  • Details of the pages you visit

  • IP address

  • Browser details including the type of computer or device that you are using

This is statistical information only which we collect to find out the numbers of visitors to our site and the pages they have visited. This information collected in such a way that it is not used to identify individuals. Where we do collect personal information on the website, this will be made obvious to you through the relevant pages. See our cookie policy for more information.

4. Information collected from other sources

We work closely with third parties such as social and healthcare professionals and public bodies. We therefore also obtain personal information about you from other sources such as:

  • Your allergies and any medical, physical, or mental conditions, test results and in particular your care and support needs, from any appropriate external social or health care professionals (including your GP)

  • Your name, date of birth, home address, contact details, needs assessments and financial assessments from any appropriate external social or health care professionals (including any relevant public body regardless of whether you are publicly funded)

  • Your likes, dislikes and lifestyle preferences (including your religious beliefs or other beliefs of a similar nature, racial or ethnic origin, health and sexual orientation (so far as they relate to providing you with suitable care) from your family, friends and any other person you have nominated as your representative

  • Your legal representative (for example Lasting Power of Attorney), if applicable

5. How we use your personal information

We use your personal information to:

  • Prepare, review and update a suitable care plan, describing the nature and level of care and support services which you have requested

  • To communicate with you, your representatives and any appropriate external social or health care professionals about your individual needs and personalize the service delivered to you

  • Respond, should your care needs change, to meet your individual needs and ensure the safety of you and your Care and Support Worker

  • Invoice you for the care and support services in accordance with our terms and conditions

  • Carry out quality assurance procedures, reviews our service and improve our customer experience

  • Send information about our services which we believe you may be interested in , you may unsubscribe from that at any time

  • Notify you about changes to our services which are relevant to you

  • Monitor how effective our services are and to make sure that the services we provide meets your needs

  • Improve your experience of our website and to ensure the content is presented in them most effective way

6. Who we share your personal information with

We share your medical information with appropriate external social or health care professionals (including your GP and pharmacist) and any individuals you have nominated as your representative as and when required. This data sharing enables us to establish the type of care and support you need. It also allows us to design the right care package to suit your individual needs.

We will share personal information with law enforcement or other authorities if requested or required. This includes information required by public bodies to evidence our compliance with the applicable regulatory framework. We are also required to share personal information with external social or health care professionals, including public bodies and local safeguarding groups (in some circumstances) to ensure your safety.

We will share relevant information within Invercare to provide safe and effective services to you.

We will not share, sell, or trade your personal information with any other third party without your consent.

To deliver our service to you we rely on third parties to provide specialist support to us. To provide this support they will have access to, or a duty of care over your personal information. These providers are:


  • IT and Telecoms Support companies – to ensure the safe, secure and resilient operation of our IT infrastructure including computers, servers, phones, and mobile devices

  • Software support companies- to provide specialist support and resolve issues with the software that we run, for example the systems we use to store and manage your customer records

  • Data archiving companies – responsible for the secure storage and destruction of records

These providers are under a written contract to ensure the same level of privacy and security that we promise to you.

7. Whether information must be provided by you, and if so why

The provision of your medical, physical, or mental condition is necessary to enable us to create a care plan and to provide you with suitable care and support services. Without this information, we will not be able to assess your care needs or provide any care services to you.

The provision of your name, home address and telephone number are required so that we can arrange a care support worker to attend your home to deliver service

8. How long your personal information will be kept


  • We hold the personal information kept within our electronic customer file for the length of your contract plus 3 years

  • We will hold the personal information kept within your hard copy customer files for years form the date of the last entry

  • We will hold the personal information kept within our feedback procedure for 1 year so that we can identify trends and patters in the service

  • We will hold financial information and transaction for 7 years in line with our legal requirements

9. Reasons we can collect and use your personal information

We rely on the following grounds within the GDPR:

  • Article 6(1)(a) – processing is conducted with your consent to process personal data for specified purposes

  • Article 6(1)(b) – processing is necessary for the performance of our contracts to provide individuals with care and support services

  • Article 6(1)(c) – processing is necessary for us to demonstrate compliance with our regulatory framework and the law

  • Article 6(1)(f) – to process your personal data in pursuit of legitimate interests, which include;

Corporate due diligence and financial modelling, service development and innovation – the privacy impact on you is expected to be minimal. We will process your data internally to ensure our business is stable, trusted and innovating to provide the best possible service to you

GDPR recognises that additional care is required when processing special category (sensitive) data such as your health. We process this under the following grounds within GDPR;

  • Article 9(2)(h) – processing is necessary for the provision of social care or the management of social care systems and services

10. International transfers

All your personal data is stored and processed on systems that are within the European Economic Area (EEA) and offer the same level of legal protection and rights over your data.

11. Your rights

As a data subject, you have the following rights, without charge, in relation to your personal data processed by us:

  • To be informed about how your data is handled.

  • To gain access to your personal data.

  • To have errors or inaccuracies in your data changed.

  • To have your personal data erased, in limited circumstances.

  • To object to the processing of your personal data for marketing purposes or when the processing is based on the public interest or other legitimate interests.

  • To restrict the processing of your personal data, in limited circumstances

  • To obtain a copy of some of your data in a commonly used electronic form, in limited circumstances.

For further information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of these rights, please contact us on the details below

12. How to contact us

You can contact us by:



01475 743883


Post /in person

Invercare Services , Inver House Business Centre, suite 1, 9 Ardgowan Square , Greenock , PA16 8ET


If you would like to exercise any of those rights, please contact us using the details above – making clear that you wish to exercise one of your privacy rights

  • Let us have enough information to identify you (e.g. your name and address)

  • Let us have proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill)

  • Let us know the information to which your request relates, including any account or reference numbers, if you have them

  • If you would like to unsubscribe from any news / information emails you can also click on the ‘unsubscribe’ button at the bottom of the emails. It may take up to 14 days for this to take place

13. Keeping your personal information secure

The confidentiality and security of your information is of paramount importance to us. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

14. How to complain

We hope that we can resolve any query or concern you raise about our use of your information. You can raise any concern you may have with our appointed compliance officer in respect of our data protection activities



Yvonne Watt (Director)

How to contact

01475 743883

The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at or telephone: 0303 123 1113.

15. Changes to this privacy notice

This privacy notice was last updated on 1st June 2020.

We may change this privacy policy from time to time, when changes are significant, we will draw your attention to this via our website.

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