Privacy notice - For LivingWell customers using services provided by Alertacall

Privacy notice for Livingwell customers using services provided by Alertacall - collecting and retaining personal information.

Loretto Care (trading as Wheatley Care) is a charitable care and support provider. Glasgow Housing Association (GHA) is a Registered Social Landlord (RSL). We are members of Wheatley Group, Scotland's leading housing, care and property-management group.

Wheatley Care and GHA will be the joint 'data controllers' of the personal information you provide to us about you as a LivingWell customer using Alertacall services.

Our Data Protection Officer is Ranald Brown, who can be contacted on #wheatleydataprotectionofficer@wheatley-group.com.

About the Alertacall services

Our LivingWell service helps older tenants live independently in their homes for as long as they can. Wheatley Care provides the LivingWell service to Wheatley Group RSLs, including GHA.

LivingWell customers benefit from two services, OK Each Day and Envosense, which are operated by Alertacall.

OK Each Day

The OK Each Day service enables daily contact with LivingWell customers through a touchscreen tablet device to ensure that everything is fine in their home. Ok Each Day puts the individual in control by giving the freedom to quickly signal “everything’s OK at my property and “I’m getting on with the day” to a UK based team at Alertacall.

Where contact is not made by the customer, they will receive a reminder to press their Ok Each Day button on their touch screen tablet and if they still don’t make contact, they are guaranteed that the Alertacall team will attempt to reach them.

Where no positive contact can be established, escalation protocols are in place to raise help (or simply communicate the fact there is an alert) with LivingWell staff, families or other agencies.

Envosense

This service involves installation of environmental sensors in the customer’s home which continually monitor temperature and humidity. The data which is collected hourly shows changes in humidity and temperature, and can be indicative of dampness, poor insulation and heating failures. Envosense will help us to reduce repair bills through early detection of issues, protect against the risk of homes not being habitable and help identify and talk with you about potential issues with fuel poverty.

What we need

We collect your personal information from you when you become a tenant of GHA in a property with the LivingWell service. We collect the following information directly from you in order to provide you with the OK Each Day service:

  • your full name
  • your date of birth
  • your contact details
  • contact details for individuals that will respond in the event of an emergency
  • other information that you choose to disclose that may be useful in improving your engagement with the service.

In order to operate the Envosense service we collect temperature and humidity data through the environmental sensors in your home. This information would only be considered to be personal data in the event that it was combined with other data held by your landlord GHA in relation to your health or financial circumstances.

Why we need your personal information - contractual purposes

We need to hold personal information about you in order to deliver the Alertacall services to you in accordance with your tenancy agreement with GHA as agreed by you and/or your legal representative. We will use your personal information to provide the agreed services to you.

The purpose of the OK Each Day service is to enable daily contact with you to ensure that everything is ok in your home. Your touch screen tablet will enable you to confirm this quickly at the touch of a button, communicate with staff and receive essential messages. In the event of an emergency your personal data will be used to contact a designated individual or agency in line with the agreed escalation procedure.

Why we need your personal information – legitimate purposes

We also process your personal information in pursuit of our legitimate interests to ensure our properties are maintained and to offer you assistance if records indicate that you may be experiencing fuel poverty.

The environmental sensor in your home is designed to take heat and humidity readings on an hourly basis. This information is transmitted to Alertacall allowing for a picture of how the tenancy is used and alerting us where temperature or humidity falls out with that expected.

The purpose of this sensor is to:

  • reduce repairs and maintenance costs
  • assess for dampness
  • flag issues and allow us to offer you assistance around fuel poverty

Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes.

If you wish to object to any of the above processing, please contact us on InformationRequests@wheatley-group.com. If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit.

Why we need your personal information – vital interests

We may also process your personal information in pursuit of your vital interests in the event of an emergency or life and death situation.

Other uses of your personal information

We may ask you if we can process your personal information for additional purposes. For example, we may share your information with a language translation service if it is necessary to translate any information into, or from, a foreign language for you.

Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.

Who we share your personal information with

We share personal data with Alertacall for the purpose of providing their service (OK Each Dayday and Envosense) to you as a LivingWell customer.

As one of our contractors, Alertacall, are required to comply with the law and our own Data Processing Agreement or Data Processing Clauses within our contracts to ensure data is managed appropriately and for specified purposes.

In the event we enter into a joint venture or merge with another business entity, your information may be disclosed to our new business partners or owners. In such circumstances, we would consult with you about your personal information being shared with such a third party.

We may be required to share personal information with statutory or regulatory authorities and organisations to comply with statutory obligations. Such organisations include health and social care partnerships, homelessness services, health services or care and support organisations that we work with, local authorities, government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies. We will only share information where there is a legal basis to do so and in accordance with UK data protection legislation.

In the event we do share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure recipients shall only process the disclosed personal information in accordance with those purposes.

We may transfer information about you to other Wheatley Group companies for purposes connected with the management of your contract with GHA and with Wheatley Care’s business.

Alertacall will share information on alerts received through the Ok Each Day service in line with the agreed escalation procedure to the following:

  • Wheatley Group partners
  • family or any other person named by you
  • carers
  • other support agency specified by you.

Envosense data is transferred from the environmental sensor in your home to Alertacall on an hourly basis. This information is stored on Alertacall’s Housing Proactive system where it can be accessed and reviewed through a dashboard by Wheatley Care’s LivingWell staff and GHA’s housing and property teams.

How we will communicate with you

As a LivingWell customer we need to communicate with you. This will usually be in writing or by telephone, but is more commonly becoming electronic and paperless. We are moving many of our services online as this is usually more convenient for you and more efficient for us. You may also receive communication from us through your Ok Each Day touchscreen tablet device.

How we protect your personal information

Your personal information is stored on our paper and IT filing systems which may be copied for testing, backup, archiving and disaster recovery purposes. Access to your information is limited to those who require it to provide services to you. All data is held within the European Union (EU).

If any of your personal information is transferred out with the European Union or the European Economic Area by any of our contractors, we will ensure there are adequate safeguards in place to protect your personal information in accordance with the General Data Protection Regulations and applicable UK Data Protection Legislation.

How long we keep your personal information

Alertacall will store the following data:

  • records of daily contact with you
  • alerts raised
  • contact notes with you
  • contact notes with designated group partners, family and carers
  • changes in routines such as days you will be out property and not contactable
  • preferred contact times.

We will only keep your personal information for as long as necessary to provide you with our services and to safeguard Wheatley Care and GHA in the event of any claims, complaints, litigation, enquiries or investigations during or following the termination of the service.

Your personal data will be retained by Alertacall for a period of 6 years.

We have a data retention policy that sets out the periods for retaining and reviewing all information that we hold. This sets out different retention periods for all information we hold about your care. You can request a copy by contacting us at InformationRequests@wheatley-group.com

We review our data retention periods regularly and will only hold your personal information for as long as is necessary for the relevant activity or as required by law (we may be legally required to hold some types of information) or as set out in any relevant contracts with you or the local authority commissioning services on your behalf.

Your rights

You can exercise any of the following rights by writing to us at InformationRequests@wheatley-group.com

Your rights in relation to your personal information are:

  • you have a right to request access to the personal information we hold about you by making a Subject Access Request
  • if you believe any of your personal information is inaccurate or incomplete, you have a right to request we correct or complete your personal information
  • you have a right to request we restrict the processing of your personal information for specific purposes, and
  • if you wish us to delete your personal information, you may request that we do so.

Any requests received by Wheatley Group will be considered under applicable UK Data Protection Legislation. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner's Office at www.ico.org.uk

We seek to ensure that our information collection and processing is always proportionate. The accuracy of our information is important to us - please help us keep our records updated by informing us of any changes to your personal information.

Changes to our Privacy Notice

Our Privacy Notice is regularly kept up to date and this version was updated on 6 January 2021. The latest full version is always available from our website.