Privacy Policy for Carers

​1. Definition:

Automated Processing: any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular, to analyse or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing.

Carers: all cares  (IPAC and CBIPAC) on the Platform

Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject’s wishes by which they, by a statement or by clear positive action, signify agreement to the Processing of Personal Data relating to them.

Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Controller of all Personal Data relating to our Carers and Personal Data used in our business for our own commercial purposes.

Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.

General Data Protection Regulation (GDPR): The General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the GDPR.

Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Categories of Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour.

Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.

Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the GDPR.

Privacy Guidelines: The Company privacy and GDPR related guidelines provided to assist in interpreting and implementing this Privacy Standard and Related Policies.

Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies: separate notices setting out information that may be provided to Data Subjects when the Company collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, employee privacy notices or the website privacy policy) or they may be stand-alone, one-time privacy statements covering Processing related to a specific purpose.

Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.


2. Purpose

This Privacy Standard applies to all carers (“you”, “your”). You must read, understand and comply with this Privacy Standard when Processing Personal Data thought our Platform. This Privacy Standard sets out what we expect from you.


Your compliance with this Privacy Standard is mandatory.


3. Personal Data Protection Principles

We require that you adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to be:  

  1. Processed lawfully, fairly and in a transparent manner; 

  2. collected only for specified, explicit and legitimate purposes;  

  3. adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;  

  4. accurate and where necessary kept up to date; 

  5. not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is processed; 

  6. Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage;

  7. not transferred to another country without appropriate safeguards being in place; and  

  8. made available to Data Subjects and allow Data Subjects to exercise certain rights in relation to their Personal Data.  


4 Data Subject’s Rights and Requests

Data Subjects have rights when it comes to how you handle their Personal Data. These include rights to

  1. withdraw Consent to Processing at any time;  

  2. receive certain information about the Data Controller’s Processing activities;  

  3. request access to their Personal Data that we hold;  

  4. prevent our use of their Personal Data for direct marketing purposes;  

  5. ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data; 

  6. restrict Processing in specific circumstances;  

  7. challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;  

  8. request a copy of an agreement under which Personal Data is transferred outside of the EEA;  

  9. object to decisions based solely on Automated Processing, including profiling (ADM);  

  10. prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;  

  11. be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;  

  12. make a complaint to the supervisory authority; and  

  13. in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine-readable format.