Privacy Policy

1. Introduction

1.1 As a controller, Cromwell Care Homes Limited (Cromwell) must meet its contractual, statutory, and administrative obligations. We are committed to ensuring that visitors’ personal data is handled in accordance with the data processing principles set out in the Data Protection Act 2018 (“DPA 2018”) and the United Kingdom General Data Protection Regulation (“UK GDPR”).

1. 2 This Privacy Notice applies to people who visit our website, email, call, message, write to us or visit in person. The information we process will depend on what you are contacting us about or the reason you have visited us.

2. Contact information

2.1 We are the Controller for the information that we process unless this Notice specifically states otherwise. Questions about this Notice should be directed to the Information Governance Lead in the first instance.

3. In this Notice

3.1 This Notice covers the following areas:

How do we get your information

  • What personal data we process and why
  • Lawful basis for processing your personal data
  • How long we keep your personal data
  • Data sharing
  • Do we use any data processors
  • Your rights in relation to this processing
  • Transfers of personal data
  • Cookies
  • Mailing lists and marketing
  • Complaints
  • Changes to this Notice

4. How do we collect your information

4. 1 We get information about you from the following sources:

  • Directly from you
  • Someone acting on your behalf
  • Social Services, healthcare professionals for the purpose of support
  • Care Quality Commission
  • Emergency Services
  • From the NHS

5. What personal data we process and why

5.1 We use the following information depending on the nature of your visit:

  • Personal contact details such as your name, contact telephone numbers (landline and mobile) and personal email addresses
  • Call recordings
  • Health screening information to protect residents and colleagues
  • Vehicle registration
  • Proof of identity
  • Images on our CCTV system

5.2 The above information is held in electronic and manuscript formats and securely stored on our systems or on our premises.

5.3 The main reasons to process your personal data are:

  • Respond to enquiries and complaints
  • Training and monitoring purposes to improve the service
  • For website visitors, to process your enquiry
  • To protect residents and staff

6. Lawful basis for processing your personal data

6. 1 Lawful basis for processing. Depending on the processing activity, we rely on the following lawful basis for processing your personal data under the UK GDPR:

  • Article 6(1)(a) with your consent
  • Article 6(1)(b) for processing necessary for the performance of a contract
  • Article 6(1)(d) in order to protect your vital interests or those of another person
  • Article 6(1)(f) for the purposes of our legitimate interests

6.2 Special categories of personal data. Where the information we process is special category data, the additional bases for processing that we rely on are:

  • Article 9(2)(a) which relies on your explicit consent

7. How long we keep your personal data

7.1 We will only keep your information for as long as we have a purpose for doing so.  Further information about how long we hold your personal data is contained in our Record Retention & Disposal (RR&D) Policy and our RR&D Schedule.

8. Data Sharing

8.1 In some circumstances, such as under a court order, we are legally obliged to share information. We may also share your personal data with third parties, including government agencies, and external auditors. Examples of who we may share your information with include:

  • Independent external auditors who monitor compliance
  • Regulators
  • Those who may require personal data to protect an individual (in life and death situations for example)

9. Do we use any data processors

9.1 Data processors are external organisations who provide certain services to us. We have contracts in place with them and they cannot do anything with your personal information unless we have instructed them to do so.

10. Your rights in relation to this processing

10.1 You may exercise the rights available to you under data protection law as follows:

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • Rights in relation to automated decision making and profiling

10.2 You can read more about these rights at:

10.3 To exercise any of these rights, please contact the Information Governance Lead. We respond to all requests we receive from individuals wishing to exercise their data subject rights in accordance with applicable data protection laws

11. Transfers of personal data

11.1 We do not routinely transfer staff personal data outside of the UK but when this is necessary, we ensure that we have appropriate safeguards in place as required by the UK GDPR.

12. Our website and Cookies

12.1 This website uses cookies to better the users experience while visiting the website. As required by legislation, where applicable this website uses a cookie control system, allowing the user to give explicit permission or to deny the use of /saving of cookies on their computer / device.

12.2 What are cookies? Cookies are small files saved to the user’s computers hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.

12.3 Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors or use the cookie control system if available upon their first visit.

12.4 This website uses tracking software to monitor its visitors to better understand how they use it. The software will save a cookie to your computers hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information.

12.5 Any downloadable documents, files or media made available on this website are provided to users at their own risk. While all precautions have been undertaken to ensure only genuine downloads are available users are advised to verify their authenticity using third party anti virus software or similar applications. We accept no responsibility for third party downloads and downloads provided by external third party websites and advise users to verify their authenticity using third party anti virus software or similar applications.

13. Mailing lists and marketing messages

13.1 When downloading a brochure, you will be asked to provide your e-mail address. We will add this to our mailing list and contact you to share further information about the Care Home you are enquiring about. When you receive an e-mail, if you are unhappy to continue receiving information and updates, please do respond and request to be taken off the mailing list.

13.2 Users contacting us through this website do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is stored securely until a time it is no longer required or has no use.

13.3 Where we have clearly stated and made you aware of the fact, and where you have given your express permission, we may use your details to send you products/services information through a mailing list system. We operate an email mailing list program, used to inform subscribers about products, services and/or news we supply/publish. Users can subscribe through an online automated process where they have given their explicit permission. Subscriber personal details are collected, processed, managed and stored in accordance this Notice. Subscribers can unsubscribe at any time through an automated online service, or if not available, other means as detailed in the footer of sent marketing messages (or unsubscribe from all Mailchimp lists). The type and content of marketing messages subscribers receive, and if it may contain third party content, is clearly outlined at the point of subscription.

13.4 Email marketing messages may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data.

14. Complaints

14.1 We hope that you won’t ever need to, but if you do want to complain about our use of your personal data, please send an email with the details of your complaint to the Information Governance Lead. We will investigate and respond to any complaints we receive.

14.2 You also have the right to lodge a complaint with the UK’s data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website: ICO Make a Complaint

14.3 If you wish to contact us please write to us at:
Cromwell Care Homes Limited, registered address Helios 47 Isabella Road, Garforth, Leeds, West Yorkshire, United Kingdom, LS25 2DY

Or at email

Ph: 01947280888

15. Changes to this notice

15.1 This Notice is updated annually or as required.