Privacy Policy
BACKGROUND
Acerta24 understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, acerta24.com (“our Site”), and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is accepted when you visit or submit a form on our Site.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
| “Account” | means an account required to access and/or use certain areas and features of our Site; |
| “Cookie” | means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site; |
| “Care Data” | means personal data relating to health, care needs, or medical treatment (special category data under UK GDPR); |
| “Data Protection Legislation” | means all applicable legislation in force from time to time in the United Kingdom applicable to data protection and privacy including, but not limited to, the UK GDPR; the Data Protection Act 2018 (and regulations made thereunder); and the Privacy and Electronic Communications Regulations 2003. |
Information About Us
Our Site is owned and operated by Acerta24, a limited company registered in England under company number 08940600.
Registered address: Weatherill House Business Centre, New South Quarter, Croydon CR0 4WF
Data Protection Officer: Acerta24
Email address: homecare@acerta24.com
Telephone number: 0345 548 3300
What Does This Policy Cover?
This Privacy Policy applies only to your use of our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
This Privacy Policy applies to all visitors to our Site, including:
- Individuals seeking care services for themselves or family members
- Healthcare professionals applying for positions
- Business partners, local authorities, and NHS organisations
- General visitors browsing our services
What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
As a health and social care provider, we also process special category data (including health data), which requires additional protection under the Data Protection Legislation.
What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details below.
- The right to access the personal data we hold about you. Below will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details below to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details below to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided below.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details below.
What Data Do You Collect and How?
Depending upon your use of our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. For more information about our use of Cookies and similar technologies and our Cookie Policy visit acerta24.com/cookie-policy.
We do not collect any personal data relating to children under 13 without parental consent. Where we process data relating to vulnerable adults, we ensure appropriate safeguards are in place.
| Data Collected | How We Collect the Data |
|---|---|
| Identity information (e.g. Name, date of birth) |
– Directly from you via our online forms (e.g., “Contact” form, “Care Assessment” form, job application form). – Via email or phone communications if you provide this information directly. – From local authorities or NHS organisations when referring care services. |
| Contact information (e.g. Address, Email address, Telephone number) |
– Directly from you when you fill out forms on our website (e.g., contact form requesting address, phone number, email). – Direct communication (e.g., when you email or call us and provide contact details). – From next of kin or authorised representatives. |
| Health and care data (e.g. Medical conditions, care needs, medication) Special category data |
– Directly from you or your representative during care assessments. – From healthcare professionals (GPs, nurses, therapists) involved in your care. – From local authority social services departments. – From NHS organisations and hospital discharge teams. |
| Professional information (e.g. NMC PIN, qualifications, training) |
– Directly from healthcare professionals applying for positions. – From regulatory bodies (NMC, CQC) for verification purposes. – From previous employers (with consent) for reference checks. |
| Business information (e.g. Business name, Job title, Local authority department) |
– Provided by you in our enquiry forms, proposals, or other communications. – From publicly available sources (e.g., local authority directories, NHS websites). |
| Payment information (e.g. Bank account details, invoicing information) |
– Through our secure payment portal or invoicing system. – Directly from you when you provide payment details in writing or over the phone. – From local authority or NHS finance departments. |
| Technical information (e.g. IP address, Browser type and version, Operating system) |
– Automatically collected via cookies, server logs, or analytics tools when you visit our website. – From third-party analytics (e.g. Google Analytics) which collect device information, browser details, and IP addresses. |
| Data from third parties (e.g. Care assessments, Referral information) |
– From local authorities commissioning care services. – From NHS continuing healthcare teams. – From safeguarding teams (where legally required). – From emergency services (in crisis situations). |
How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:
| What We Do | What Data We Use | Our Lawful Basis |
|---|---|---|
| Providing care services to you | – Identity Information – Contact Information – Health and Care Data |
Performance of a contract (to provide care services) Legal obligation (under the Care Act 2014) Vital interests (in emergency situations) |
| Assessing care needs and developing care plans | – Health and Care Data – Identity Information – Contact Information |
Performance of a contract Legal obligation (safeguarding duties) Consent (where the individual has capacity) |
| Recruiting and vetting healthcare professionals | – Identity Information – Professional Information – Contact Information |
Performance of a contract (employment) Legal obligation (right to work checks, DBS requirements) Legitimate interests (verifying qualifications) |
| Managing payments for services | – Payment Information – Identity Information – Contact Information |
Performance of a contract Legal obligation (financial regulations, HMRC requirements) |
| Communicating with you about services | – Identity & Contact Information – Health and Care Data (where relevant) |
Performance of a contract Legitimate interests (service updates) Consent (for marketing communications) |
| Ensuring quality and regulatory compliance | – Health and Care Data – Identity Information |
Legal obligation (CQC requirements) Legitimate interests (quality improvement) |
| Safeguarding vulnerable adults | – Health and Care Data – Identity Information – Contact Information |
Legal obligation (Care Act 2014 safeguarding duties) Vital interests (protection from harm) |
| Administering our Site | – Technical Information – Identity Information (if logged in) |
Legitimate interests (site security, performance, and troubleshooting) Consent (for non-essential cookies) |
| Supplying you with information by email that you have opted-in to | – Identity & Contact Information | Consent (for marketing communications) Legitimate interests (to keep customers informed of relevant news) |
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose content appears on our Site may use third-party Cookies, as detailed below. For more information on controlling cookies see below. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details below.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights. This includes situations involving:
- Safeguarding concerns where there is risk of harm to a vulnerable adult
- Legal proceedings or court orders
- Public health emergencies
- Cooperation with police investigations
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
| Type of Data | How Long We Keep It |
|---|---|
| Identity Information including (e.g. name, date of birth, NHS number) | We retain identity data for the duration of our care provision plus 6 years after our last interaction, in line with UK limitation periods and CQC requirements. |
| Contact information including (e.g. address, email address, telephone number) | Contact details are kept while we are actively providing services or communicating with you. After our relationship ends, we typically retain these details for up to 6 years to manage ongoing queries, disputes, or legal obligations. |
| Health and care data including (e.g. medical conditions, care plans, medication records) | Health records are retained for the duration of care plus 6 years after death (or 6 years after the end of care if sooner), in accordance with NHS and professional standards. Some records may be kept longer for safeguarding or legal reasons. |
| Professional information including (e.g. NMC PIN, qualifications, training records) | Staff professional records are kept for 6 years after employment ends, in line with employment law requirements. DBS information is kept only as long as legally required. |
| Business information including (e.g. business name, job title, local authority department) | We keep business-related information for as long as necessary for legitimate business interests (e.g., record-keeping, audits). Typically, this is up to 6 years following the end of our working relationship. |
| Payment information including (e.g. bank account details, invoicing records) | In compliance with HMRC and other legal requirements, financial records are generally retained for at least 6 years after the end of the tax year they relate to. Card details are stored only as long as necessary for processing transactions, and thereafter securely deleted or tokenized. |
| Technical information including (e.g. IP address, browser type and version, operating system) | Technical logs and analytics data are retained for a shorter period—often 12 months—to ensure website security and to analyze site performance. Some data may be kept longer if needed for legal or security investigations. |
| Safeguarding records | Safeguarding alerts and investigation records are retained for 6 years after the case is closed, or indefinitely for serious cases involving significant harm or ongoing risk. |
How and Where Do You Store or Transfer My Personal Data?
We will store your personal data within the United Kingdom. All data is processed and stored on secure servers located in the UK.
We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the Information Commissioner’s Office.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- implementing strict password policies and multi-factor authentication for all systems containing personal data;
- encrypting all health and care data both at rest and in transit using industry-standard encryption (AES-256);
- conducting regular security training for all staff handling personal data;
- maintaining secure backup systems with encrypted off-site storage;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
- regular penetration testing and vulnerability assessments of our IT systems.
Do You Share My Personal Data?
We may share your personal data with the following categories of recipients where necessary for the provision of care services or compliance with legal obligations:
- Healthcare professionals involved in your care (GPs, district nurses, therapists)
- Local authorities commissioning care services
- NHS organisations (including continuing healthcare teams)
- Pharmacies and medication supply services
- Regulatory bodies (Care Quality Commission)
- Safeguarding teams (where there is risk of harm)
- Emergency services (in crisis situations)
- Legal representatives and attorneys (where properly authorised)
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above.
How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out above, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and/or at the point of providing your details).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Can I Withhold Information?
You may access certain areas of our Site without providing any personal data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.
Where we are providing care services, withholding certain information (particularly health and care data) may prevent us from providing safe and effective care. In such cases, we will explain the implications of withholding information so you can make an informed decision.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown below. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: homecare@acerta24.com
Telephone number: 0345 548 3300
Postal Address: Weatherill House Business Centre, New South Quarter, Croydon CR0 4WF
Data Protection Officer: Acerta24
For complaints about our use of your personal data, you may also contact:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline: 0303 123 1113
Website: www.ico.org.uk
Changes to This Privacy Policy
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
