On May 25 2018 we updated our Privacy Policy in accordance with Europe’s General Data Protection Regulation, otherwise known as GDPR.
Our Privacy Commitment to you
We have set out our Privacy Policy to explain who we are, ways in which we collect, use, store and share your personal information. It sets out your rights to access your personal information and how to contact us should you wish to lodge a complaint.
Please see the section on Your rights under GDPR for more information.
Introduction
We are a small business trading under Costa Angels based on the Costa del Sol. In order that we can provide our care services to our customers we collect and use specific personal information about you.
Personal information means any information about you that identifies you, but it does not include information where your identity has been removed (anonymous data).
We work in the capacity of the ‘controller’ of your personal information and are responsible for how that data is managed. The General Data Protection Regulation (GDPR), which applies in Spain as part of the new European directive sets out our obligations to you and your rights in respect of how we manage your personal data. Our dedicated ‘controller is Madi Askew, her direct email address is madi.askew@costaangels.com.
Our remit as the ‘controller’ of your personal data means that we will certify that your personal data that we hold is;
Used legitimately, responsibly and in a transparent way.
Collected only for lawful purposes that has been explained to you fully and is not used for any other purpose than which we have that we have clearly explained to you.
Only applicable 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.
Stored securely.
If you have any questions about this privacy commitment or would like further clarification as to how your personal information is managed then please contact us on +34 952 709 933 or via email at madi.askew@costaangels.com
Terms that we use and their meaning:
A ‘public body‘ we mean any organisation in Spain or the EU which delivers, commissions or reviews a public service and includes (but is not limited to) the Ombudsman, local authorities, town halls, unitary authorities, clinical commissioning groups, health and social care trusts, the Spanish Health Service as well as their arm’s length bodies and regulators.
A ‘social or health care professional‘ we mean any person who provides direct services, acts as consultant or is involved in the commission and provision of your health or social care services.
The personal data we collect and use In this section we cover how we gather and use your Personal Information when you enquire or use
our services;
Information or Data we collect
When you make any inquiry about our care services via phone, post, email, social media or through our website and throughout the course of providing care services to you we store the following personal data that you provide to us:
Your name, residential address, date of birth, telephone numbers, email address, medical bodies contact details, next of kin details including name, residential address, contact numbers, email address and relationship status. Any third party names, contact details and email addresses pertaining to your care team including outside providers to include; your Medico, pharmacists, nurses and health visitors, clinical psychologists, dietitians and nutritionists, physiotherapists, occupational therapists, speech therapists, chiropodists, dental workers, funeral plan details,hospital staff, social workers and other care and support related professionals.
Your allergies, previous medical history, medical, physical or psychological conditions and your care requirements. Details about your lifestyle, likes and dislikes, social activities that you may engage in and share with us.
Any feedback pertaining to our services to include testimonial and complaints about the service we provide.
Any accidents that may have occurred during the period that our Carers have been providing a service to you.
When you make an inquiry where you would like us to represent you as an autonomous Carer or Nurse we hold the following personal information about you;
Your name, residential address, date of birth, telephone numbers, email address, medical bodies contact details, next of kin details including name, residential address, contact numbers, email address and relationship status. Your allergies, previous medical history and medication that you may be taking. Details about your lifestyle, likes and dislikes, social activities that you may engage in and share with us. References from previous employers and character references and details of your Criminal record background check Certificates. Any accidents that may have occurred during the period that you have been providing care and social services to a service provider.
Information collected from other sources
We may from time to time ask for your permission to collect information from third parties to improve our care service to you. These third parties may include your Medico, pharmacists, nurses and health visitors, clinical psychologists, dietitians and nutritionists, physiotherapists, occupational therapists, speech therapists, chiropodists, dental workers, funeral plan details,hospital staff, social workers and other care and support related professionals.
Your name, home address, date of birth, contact details, needs assessments and financial assessment information from any appropriate or relevant third party social or health care professional,from your family, friends and any other person you have nominated as your representative
How we use your personal information
The way in which we use your personal information to:
In order to set out, update and provide timely reviews on your care plan. This will set out the type and level of care and support that you have request us to supply.
In order to exchange information with you, your representative or external social or health workers concerning your requirements and tailor the service provided to you.
In order to make any necessary and reasonable amendments when necessary to ensure that we have the facilities to ensure your safety.
In order to Invoice you for the care and support services in accordance with our terms and conditions.
In order to facilitate quality assurance procedures, reviews of our service and improve our customer experience. Feedback may be provided anonymously.
In order to advise you of any information about our services that we feel that you could be interested in. You may unsubscribe from this at any time.
In order to notify you about changes to our services which are may affect you.
In order to ascertain how effective our services are and to ensure that the services we provide meet your needs requirements.
In order to improve your experience of our website and it’s content making sure it is presented in a comprehensive manner.
Who your personal information is shared with
Your personal about your medical information is shared with your Medico, external social and health care professionals and Farmacists along with any of your nominated representative only when required. Sharing this information enables us to tailor make a suitable care plan for you detailing the type of care and support you many require. This data sharing enables us to establish the type of care and support you need. Should you wish to change care provider this your personal medical information may be shared with them.
Your personal information will be shared when legally required to do so with any law enforcement agency or other authorities. This includes any information to public bodies to demonstrate our compliance with the relevant regulatory framework. Your personal information will be also shared with any public body, external health and social care professionals and safeguarding groups professionals, including public bodies and local safeguarding groups to ensure your safety.
We will share minimal and relevant information within Costa Angels Care Agency in order to provide safe and effective services to you.
We will not share, trade or sell your personal information with any other third party without your consent.
In the following circumstance we may call on third parties to provide support to us and in these case they will have access to your personal information. Please see below a list of third parties that could provide support to us. Please find below a list of third parties that provide specialist support to us.
Any Information Technology and Telecommunications Companies that we rely on to maintain the security and operation of our IT and Telecommunications infrastructure including Laptops, Computers, Telephones and Mobile Phones.
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 Companies providing Data archiving facilities to store and permanently delete records held.
To ensure our ongoing pledge to you these third parties are under written contract to ensure that they uphold the same level of security and privacy that we pledge to you.
When information has to be provided by you, and if so why
We require you to provide details of your physical, mental and medical condition so that we are able to create an accurate care plan and any necessary care and support services.
We require details of your name, home address so that we can introduce a care worker to attend your home to deliver the services and enabling us to invoice you for the fees.
How long will we keep your personal information
Your personal information will be kept electronically within your customer file for the length of your contract plus 3 years.
Your personal information will be kept within your hard copy customer files for 3 years from the date of the last entry.
Your personal information will be kept within our feedback procedure for 1 year so that we can identify trends in our service.
In line with legal requirements we will hold financial records and transactions for 7 years.
Reasons we can collect and use your personal information
In accordance with the Articles and directives within the GDPR:
We carry out processing of your personal data with your consent for specific purposes as set out in Article 6(1)(a).We carry out processing of your personal data when it is necessary to provide individuals with support and care services as set out in Article 6(1)(b).
We carry out processing of your personal data when needed for us to show compliance with our regulatory procedures and the law as set out in Article 6(1)(c).
As set out in Article 6(1)(f) your personal data is processed for legitimate purposes;
Marketing purposes – we do not use your personal data for marketing purposes.
We may process your data internally for corporate due diligence and financial modelling, service development and innovation purposes. The internal processing is to ensure stability, that our business is trusted and able to provide an evolving level of service to you. This will be expected to have a minimal impact 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;
We carry out processing of your personal data when necessary to provide social care or management of such services and systems as set out in Article 9(2)(h).
Transfers Internationally
Your personal data is kept and used on systems that fall within the European Economic Area, the AAE and offer the same rights and legal protection over your data.
In certain situations, we transfer your personal information to countries which are located outside the European Economic Area, EEA, This is only authorised in the event that a self employed Carer that we represent requires your name, address, phone numbers and any information pertaining to Care to provide a secure service after having been accepted by the service user.
This international transfer is under Article 49(1)(b). If the transfer is needed for the performance of a contractual agreement between the data subject and the controller.
These countries do not have the same data protection laws as Spain and EEA and any legal divulgence of your personal information will be subject to relevant safeguards that are designed to help protect your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.
If you would like further information please contact us using the options set out in the section entitled How to Contact us.
Your rights under the GDPR
Under the GDPR you have important rights free of charge. In summary, those include rights to:
Fair processing of information and transparency over how we use your use personal information.
Access to your personal information and to certain other supplementary information that this Privacy.
Promise is already designed to address.
Require us to amend any mistakes to your information that we hold.
Require the deletion of personal information about you. We may have to withdraw any care services .should you ask us to delete any of your personal information that is necessary for us to comply with any legal or contractual obligations.
You are entitled to receive your personal information that you have provided in a commonly used format and you have the right to send this information to a third party.
You have the right to oppose to the processing of your personal information for direct marketing.
You have the right to oppose to in other decisions or situations to our continued processing of your personal information.
You can limit or restrict our processing of your personal information in certain circumstances.
You have the right to claim compensation for damages caused by our breach of any data protection law.
How to contact us
You can contact us by:
Email: info@costaangels.com
Post: Buzon 113, Calle Arquimides, Coin, 29100, Malaga, Spain
Telephone: +34 952 709 933
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 NIE number, driving licence or passport and a recent utility bill).
Let us know the information to which your request relates, including any account or reference numbers, if you have them.
Securing your personal information
The confidentiality and security of your information is of utmost importance to us. We have internal and technical 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. When we process your information will do so only in an authorised way and are are held to a duty of confidentiality.
How to complain
We hope that we can rectify any concern that you raise about our use of your information. Please contact Costa Angels on +34 952 709 933 or via email to madi.askew@costaangels.com if you have any concerns.
Changes to this privacy promise
We may change this privacy promise from time to time, when changes are significant we will draw your attention to this on our website.
If you would like this privacy promise in another format (for example, in audio, large print or braille) please contact us.
