Privacy Notice

This Privacy Notice was posted on 24 May 2018

Public Consulting Group UK Limited (“PCG UK” or “we”) operates a number of websites on behalf of local authorities.

PCG UK respects your privacy and is committed to protecting your personal data. This Privacy Notice (together with our terms of use and any other documents referred to in it) will inform you as to how we look after your personal data when you visit one of our websites (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose Of This Privacy Notice

This Privacy Notice aims to give you information on how PCG UK collects and processes your personal data through your use of any website operated by PCG UK.

It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data Controller

Although this privacy notice applies to all of the websites we operate, the legal definition of who is the Data Controller (and therefore responsible for your personal data) depends on which Local Authority area you live in. In some cases, PCG UK is the Data Controller. In other cases, the relevant Local Authority is the Data Controller and PCG UK is the Data Processor. Please see Section 10 below or contact us if you have any questions.

Contact Details for PCG UK

Full name of legal entity:	Public Consulting Group UK Limited
Name or title of Data Protection Officer:	Lee Jones, Chief Technology Officer
Email address:	info@publicconsultinggroup.co.uk
Postal address:	1 Smithy Court, Smithy Brook Road, Wigan WN3 6PS
Telephone number:	03300 582 690

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to The Privacy Notice

This version was last updated on 24 May 2018. We may occasionally modify this Privacy Notice, such variations becoming effective immediately upon posting. By continuing to use the website, you will be deemed to accept any such variations. Any changes we may make to our Privacy Notice in the future may be notified to you by e-mail.

Keep Us Updated

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal Data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and NHS number.
Contact Data includes billing address, delivery address where applicable, email address, and telephone numbers.
Health and Social Care Data includes details relating to health and social care conditions, assessments, eligibility and support received.
Financial Data includes credit card or bank account details along with financial status information required by funding bodies to determine eligibility.
Transaction Data includes details about payments to and from you and details of products and services you have purchased via, or recorded on, our website.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases made by you, other users you give delegated authority to, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website and services, such as the user's IP address, the time of the visit, and the pages and order of pages viewed.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

If You Fail To Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- create an account on our website;
- contact us through the website or otherwise (by post, email or phone);
- complete an online assessment, support plan, request for quotes or enter in to correspondence with another user via our website;
- place an order for goods or services or record a transaction via our website;
- complete a survey or give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, such as organisations that provide health or social care services to you and providers of technical, payment and delivery services.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data.

We have set out below, in a table format, a description of all the ways we plan to use your personal data. We have also identified the nature of the processing and what our legitimate interests are where appropriate.

Purpose/Activity	Type of Data	Nature of Processing
To register as a user of the website and manage your profile	Identity, Contact, Profile	To enable you to use the full functionality of the website thereby fulfilling our contract with you
To contact another user via the website (e.g. request or respond to a quote)	Identity, Contact, Health & Social Care	To enable the other user to review information so that they can respond (only data that you choose to share will be shared)
To process an order via the website (including bookings, and timesheet submission / approval)	Identity, Contact, Financial, Transaction,	To enable two parties to legally contract with each other and funding bodies to view the records
To record a transaction (e.g. an offline purchase)	Identity, Health & Social Care, Transaction	To enable a user to manage their personal budget online and funding bodies to view the records
To complete an assessment online (e.g. triage, eligibility, financial)	Identity, Contact, Health & Social Care, Financial, Profile	To enable a user to receive specific information, advice and guidance based upon the data they record (only data that you choose to share will be shared)
To view or update health or social care records	Identity, Contact, Health & Social Care, Transaction	To enable a user to view (and update) the records held by public bodies (Local Authority / NHS) on their IT systems
To manage our relationship with you	Identity, Contact, Profile, Marketing and Communications	To perform our contract with you, and comply with a legal obligation
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity, Contact, Technical	For us to comply with legal obligations and for our legitimate interests of running our business (provision of administration and IT services, network security, to prevent fraud)
To deliver relevant website content to you and measure or understand the effectiveness of the advertising we serve to you	Identity, Contact, Profile, Usage, Marketing and Communications, Technical	For our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical, Usage	For our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Marketing

We will never pass your details to any third parties for marketing purposes. However, we (or the Local Authorities that we work with) may wish to communicate with you about services available, in which case we will seek your consent at that time.

You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time on info@publicconsultinggroup.co.uk.

Where you opt out of receiving these marketing messages, this will not apply to other personal data provided to or held by us.

Cookies

Cookies are small text files the website can use to recognise repeat users and allow us to observe behaviour and compile aggregate data in order to improve the website for you. For example, cookies will tell us whether you viewed the website with sound or with text on your last visit. Cookies also allow us to count the number of unique and return visitors to our website. You can configure your Internet browser to accept or reject certain cookies or inform you when a cookie is saved. We do not cross the information recorded in the cookies with the personal information collected at the time of your registration on the website or with your online activity. Some of our local authority, business and technical partners may themselves use cookies on their own websites. We have no access or control of these cookies, therefore we cannot accept liability for any malfunctioning of your PC or its installed web browser as a result of your access to any of the websites. More information about cookies is available in our Terms of Use.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 4 above.

Health and social care bodies, including but not limited to: Local Authorities, NHS Trust, Clinical Commissioning Groups and General Practitioners.
Third party consultants, contractors or other service providers – including but not limited to: I.T support, software providers and website developers.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our or your instructions.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Please be aware that communications over the internet, including via email, are not secure unless they have been encrypted.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, insurance valuation or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available upon request from us.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact the Data Protection Officer, on info@publicconsultinggroup.co.uk.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within 28 days. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. DATA CONTROLLERS

The legal definition of who is the Data Controller (and therefore responsible for your personal data) depends on which Local Authority area you live in. In some cases, PCG UK is the Data Controller. In other cases, the relevant Local Authority is the Data Controller and PCG UK is the Data Processor as follows: -

Area	Data Controller
Barking & Dagenham, Birmingham, Buckinghamshire, Hampshire, Hillingdon, West Sussex	Please contact us in the first instance if you would like to know the name and contact details for the Data Controller for the relevant Local Authority
All other areas	PCG UK – see contact details at Section 1.