Carer Privacy Policy

Who are we

Elder Technologies Limited (“we”, “our”, “us” or “Elder”) is committed to protecting and respecting your privacy. Elder, is a limited company (with company number 09803204) registered at 230 City Road, London, England, EC1V 2TT.

Our data protection officer for the purpose of the Data Protection Laws is Mr Pete Dowds (CEO & Co-Founder of Elder), who may be contacted at privacy@elder.org. If you have any questions or would like to discuss further, you can email us or call us on 0333 150 2350.

Our Commitment and Obligations to you

We take the collection, usage and security of our carer’s personal data seriously. We can only use your personal data under law if we have a good reason for doing so. The law provides examples of those reasons. These include:

• To perform or fulfil a contract we have with you; or
• If we have a legal duty; or
• If it is within our legitimate business interest; or
• If there is a public interest reason for doing so; or
• If you have given your consent.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

Types of Personal Data We Collect About You

• Your contact details
• Employment history
• Health information
• Criminal history / offence data (for background screening purposes)
• Demographic data (e.g. date of birth)
• Financial data (for payment)
• Technical Information (IP / Cookies)
• Location data
• User login data

What Personal Data We Collect and Where From

You may give us information about you when applying for a role or position within Elder either online, via third party sites and/or direct contact made with Elder. This information may include your employment history, resume / CV, past salary information and other contact and personal information.

Information we collect about you

With regard to each of your visits our internal and external sites we may automatically collect the following information:

• 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 our site (including date and time); products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), cookies and methods used to browse away the page and any phone number used to call our customer service number.

Information received from other sources

We may receive information from other sources, such as from third party websites (where you apply for a role via another site); from third party agencies (e.g. for purpose of background screening); from our customers (where they provide us with feedback on you); and from your past employers (where they provide us with references about you).

Automated decision making

We do not use automated decision-making processes during our relationship with you. All decisions are always reviewed manually.

What do we use your personal information for?

What we use your personal data for	What is the lawful reason	Business or commercial reason (our legitimate interest)
Background screening to ensure you are able to provide services.	We conduct these checks because we are required to do so by law. Where we carry out background criminal record checks, we only collect this information once we have your permission / consent to do so. We use this information because we have a legal obligation to carry out these searches.
Provide the customer with care services.	Perform the contract we have with our customers (or take steps needed at the customer’s request prior to entering into a contract with you). This is within our legitimate business interests to perform.	We need to do this to ensure we perform the contract we have with the customer.
Maintain customer relationships	This is within our legitimate business interests to perform.	We need to do this to ensure we perform the contract we have with the customer.

Cookies

We may obtain information about your general internet usage by using cookie files stored on your computer or device (“cookies”). Cookies are text files containing small amounts of information which are downloaded to your computer or device when you visit a website. They help us to improve our site and to deliver a better and more personalised service.

We may use both “session” cookie and “persistent” cookies on the website. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.

We will use the session cookies to: keep track of you whilst you navigate the website; keep track of your bookings; prevent fraud and increase website security; and other uses. We will use the persistent cookies to: enable our website to recognise you when you visit; keep track of your preferences in relation to your use of our website; and other uses.

We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html.

Our payment services providers may also send you cookies.

You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/. You may disable cookies by changing the settings on your browser. However, if you do so, this will affect your enjoyment of our site and we will no longer be able to offer to you a personalised service.

How we share your personal data

We take your privacy very seriously and we’ll only share your information where:

• we need to for the purposes of you performing your services and our agreement we have with you;
• we have a public or legal duty to do so e.g. to assist with detecting crime, fraud and tax evasion, economic crime prevention, regulatory reporting, litigation or defending legal rights;
• we have a legitimate reason for doing so e.g. to manage risk, or assess your suitability for providing services; or
• we have asked you for your permission to share it, and you’ve agreed.

Third Parties

We may share with third parties, including:

• business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you;
• fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity;
• background employment screening organisations who will use it to verify whether or not you have a criminal history which would prevent you from being selected to provide care services to vulnerable persons;
• analytics and search engine providers that assist us in the improvement and optimisation of the website;
• any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries for the purposes set out above;
• in the event that we buy or sell any business or assets, including the sale of an individual website owned by us, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and
• if Elder or substantially all of its assets are acquired by a third party, in which case personal data held by it about its members and customers will be one of the transferred assets.

Sharing Aggregated or Anonymised Data

Where we have made your information anonymous, we may share it this outside of Elder with partners such as research groups, universities, advertisers or connected sites. For example, we may share information publicly to show trends about the financial services market.

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”), including, in particular, the United States. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or business partners. By submitting your personal data, you agree to this transfer, storing and/or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

Security of your personal data

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the data transmitted to our site; any transmission of your data is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our site may, from time to time, contain links to and from the websites of our member and associate member organisations, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

How Long We Keep Your Information

We will retain your personal information for as long as you are instructed by Elder to provide services and for a reasonable time thereafter. After you have terminated the provision of your services to us, we will retain your personal information for up to 10 years and thereafter may store it in an aggregated and anonymised format.

Your rights

• Access to information. The Data Protection Laws give you the right to access information held about you. Your right of access can be exercised in accordance with Data Protection Laws by contacting us at privacy@elder.org.
• Consent. You may withdraw your consent to any processing of your personal data at any time by contacting privacy@elder.org.
• Rectification. You have the right to rectify any personal data held about you that is inaccurate. Your right of rectification can be exercised by contacting us at privacy@elder.org.
• Erasure. You may have the right to erasure of personal data held about you by contacting us at privacy@elder.org.
• Complaints. In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at privacy@elder.org and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the UK’s Information Commissioner’s Office.

Changes to our Privacy Notice

Any changes we may make to the Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check this page frequently to see any updates or changes to this Privacy Notice.

Contact

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to privacy@elder.org.