Audley Group (‘we’ or ‘us’) are the ‘Data Controller’ of the personal data that you (‘you’ means the person whose data is being processed) provide to us. We are committed to protecting your data and your rights in line with the Data Protection Act and the General Data Protection Regulation of 2018 (GDPR 2018). This notice explains how information about you is used by us.
Audley Group’s Company Registration number is 09906780 and our Registered Address is 65 High Street, Egham, Surrey, TW20 9EY.
Audley’s Privacy Principles
We know that your information privacy is very important to you. We promise that it is even more important to us.
This is central to Audley Group’s values as an organisation. We want everyone who has any dealings with us, from our customers, our team members and members of the public, to feel confident about how any personal information they share will be looked after or used.
You can be confident that:
- We only use personal information in the ways we need to and that is expected of us.
- We will use your information to keep you up to date, for example to let you know how we are progressing with your enquiry or purchase, to provide any service you may need, including care provision, to improve all of our services as well as our ongoing service provision.
- But, we only use your personal information to do this if you have previously given us your permission to do so.
- We will make it easy for you to tell us how you want us to communicate with you, including how to opt out from future communications - and we promise we will always comply with your request. Please note that you may continue to receive communications for a short period while our systems are fully updated.
- We will never release your information to organisations outside Audley Group for their marketing purposes.
- We will be especially careful and sensitive when engaging with vulnerable people or those we have reason to believe might be vulnerable in accordance with the Care Act of 2014.
- We take all reasonable care to safeguard all your personal information through security policies and secure business processes. We take extra care to ensure all sensitive personal information is properly looked after.
- We respond quickly, efficiently and lawfully if you have any queries or complaints, or if you wish to amend your records.
- We fully respect your rights relating to the personal information we process about you - we will always provide easy ways for you to contact us. Our Data Protection Officer is happy to answer any queries you have.
How we collect personal information about you
We may collect personal information from you when you get in touch with Audley Group. This may happen, for example, if you enquire about our villages, register interest with us, book a table at a restaurant, purchase a property, request some health care services, apply for a job, if you choose to provide some optional feedback or otherwise provide us with personal information. This may be when you phone us, go onto our website, through email or the post, or in person.
What information do we collect about you?
To help Audley Group to provide you with the services you have asked for, we may process the following information:
- Your personal details – such as your name, date of birth and your nationality.
- Your contact details – such as your address, telephone, email address, and other information that you may provide in any correspondence between us.
- Financial information you may provide to us – such as bank details, financial details and credit/debit card details (for example, if you are making a purchase)
- Details of others such as 'Next of kin' – this may be the contact details of a close relative or friend, or your solicitor or other agent/s.
- ‘Special categories’ of data, for example, any health conditions and other health information that are needed to provide any care services you ask for.
- Any preferences you may have, including whether you consent to any marketing contact.
- We also collect general information about the use of our websites, such as which pages users visit most often, and which services, events or facilities are of most interest. We may also track which pages users visit when they click on links in Audley Group emails. We may use this information to personalise the way our websites are presented when users visit them, to make improvements to our websites and to ensure we provide the best service for users. Wherever possible we use aggregated or anonymous information which does not identify individual visitors to our websites.
The provision of information by you is needed so that we can provide you with the contractual service you have asked for or so that we can legitimately fulfil your request. Where necessary, we will ask for permission to process data and your consent is requested when we ask for your data.
We may also obtain information about you from third party organisations such as estate agents, referral agents, list brokers, recruitment agencies, service providers and data agents.
Information about third parties
Information we process as described in this notice may also include information about third parties such as your friends and relatives, references and referrals whose details you supply to us.
A special note about the sensitive information we hold
Audley Group pride ourselves on high service standards to each valued customer. To enable us to do this we may need to ask you to provide us with details of a sensitive nature, such as any medical conditions, their treatment and medication. This may extend to other sensitive information such as racial or ethnic origin, religious or similar beliefs, or criminal record. We may gather this data in order to provide the health care service you need, or to provide other customer services such as religious service or equal opportunities monitoring.
When you share this with us, we usually ask for your explicit consent to process it for these purposes; However, occasionally we may do so without consent where required or permitted to do so by applicable law (e.g. to comply with diversity reporting requirements). Your sensitive information will not be used for any other purpose.
We will not pass on your details to anyone else without your permission except in exceptional circumstances. Examples of this might include sharing medical data with the doctor or hospital in cases of serious medical conditions, posing a threat to others, and sharing other serious issues.
Systems and applications used to process data
We gather information directly from you and via our websites, in person and other technical systems. These may include for example, our:
- Computer networks and connections
- CCTV and access control systems
- Communications systems
- Email and instant messaging systems
- Intranet and Internet facilities
- Telephones, voicemail, mobile phone records
- Social media platforms
- Face to face customer service
- Other hardware and software owned, used or provided by or on behalf of us and our group companies.
Some of the cookies we use are essential for parts of the site to operate and have already been set. You may change your settings (in the ‘options’ or ‘preference’ menu of your browser) so that you delete and block all cookies from this site – although this may mean that parts of the site will not work. To understand these settings, the following links may be helpful, or you can use the 'Help' option in your browser for more details:
- Cookie settings in Internet Explorer
- Cookie settings in Firefox
- Cookie settings in Google Chrome
- Cookie settings in Safari web and iOS
How do we use personal information?
Audley Group processes your information for an identified lawful purpose and most purposes have a legitimate basis. The purpose for processing may be for a statutory or contractual requirement: where this is the case, you have a choice as to whether you provide your information but not doing so may mean that we are unable to provide the service you have requested. On occasion, we may also process information based on your consent, or in someone’s vital interests.
For information on the conditions for processing, please contact the Data Protection Officer.
Examples of reasons for which we process your information include:
- To provide you with the services you have requested;
- To provide the direct care and treatment to our clients, including any related administration;
- For necessary disclosure (for example, to solicitors, to the police, to the Courts, and to tribunals and enquiries);
- To help ensure safety and security, as well as to prevent and detect crime;
- For fraud prevention; research and analysis, enhancing, modifying or improving our services.
Confidential client-identifiable information is only shared with other organisations where there is a legal basis for it as follows:
- When there is a Court Order or a statutory duty to share client data;
- When there is a statutory power to share client data;
- When the client has given his/her explicit consent to the sharing;
- When the client has implicitly consented to the sharing for direct care purposes.
Marketing and your choices
We would like to keep all of our customers up to date with village news, developments and our plans, as well as any events and special offers in our restaurants and health clubs in which you may be interested. You can choose how we keep in touch with you (by post, phone, email, text and other electronic means). Where necessary, we ask for your consent to do this. You can change your mind and remove or add that consent at any time, simply by contacting us using the details below:
Unsubscribe using our website form. Please note, in order to unsubscribe from email and/or post and/or phone communications, you will need to provide contact details which match those we have stored for you.
By email: firstname.lastname@example.org
Head of Marketing
Audley Group Head Office
65, High Street
By phone: 0800 093 8181.
We do not sell/share your personal information with any third party for their marketing purposes.
Who sees your personal information?
The personal information we collect about you will be used by our employees in Audley Group in the UK so that they can support you and provide the services you request.
Audley Group may share your information with our trusted partners and suppliers, who we instruct to provide Audley Group services to you. These organisations include service providers; estate agents; solicitors; security and CCTV service providers; marketing agencies and suppliers; fitness services; and other representatives.
Examples of these third parties include:
- Marketing agencies if you consent to being contacted by post or email about village updates and restaurant offers.
- Care Quality Commission upon request
- Recruitment agencies if you submit an online job application form and attach your CV
- Care monitoring providers to provide emergency assistance to our owners
- Web development companies to host our website on our behalf.
- Human resources and benefit service providers
- Car rental.
Where we share your information, it is always carried out under our instruction, and is never for their marketing approaches. We ensure that we perform our due diligence on these third parties which includes storing the data securely and deleting it when it is no longer needed.
We may also disclose your information with law enforcement agencies and regulatory bodies such as the Care Quality Commission as required by law.
Your information security
We take the security of your personal information extremely seriously.
We have implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.
Here are some of the ways we protect your personal information:
- If you provide personal information to us online that information is encrypted for protection on transmission to us. Encryption is the process through which sensitive information is scrambled before it is transmitted so that it remains private even if it is intercepted. However, unless your internet browser supports this you will not be able to take advantage of this level of security
- Offline, your personal information is kept securely on our databases and offices, or, where relevant, by our partner companies as described above.
- Our website may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites.
- We store your personal data on secure servers.
Security of processing outside the EEA
On a few occasions, Audley Group may store your personal information with international organisations outside the EEA. These are mail campaign organisations. This includes locations such as the US. Our IT service providers can access our IT systems from South Africa only for remote support purposes and IT operations. The IT service provider is a UK registered company with adequate Binding Corporate Rules governing the organisation. We comply fully with our legal obligations as a data controller and take all steps necessary to ensure that your personal information is treated securely and in accordance with legislation.
These international organisations comply with the local laws as applicable to them.
Any transfer of your data will be subject to a European Commission approved contract between Audley Group and that third party that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.
How long do we store your personal information?
We only keep your data for as long as is reasonable and necessary, which may be to fulfil statutory obligations. We ensure that any third parties that process information on our behalf adhere to these standards.
More information on our retention schedule can be found by contacting the Data Protection Officer.
We do not knowingly collect personal data relating to children under the age of 16. If you are a parent or guardian of a child under the age of 16 and think that we may have information relating to that child, please contact us at email@example.com. We will ask you to prove your relationship to the child but if you do so you may request access to and deletion of that child’s personal data.
Your communication with our teams at Audley
Your communications with our teams (including by telephone or email) may be monitored and/or recorded for training, quality control and compliance purposes to ensure that we continuously improve our customer service standards.
Your rights and getting in touch with Audley Group
If you wish to get in touch with our Data Protection Office for any reason, including your rights below, please contact us at firstname.lastname@example.org so we can help.
Your right to request a copy of your information
You can request a copy of your information which we hold, free of charge (this is known as a subject access request). You will be asked to:
- Complete a Request form;
- Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- Let us know the information you want a copy of.
We will then respond in full within one calendar month.
Your right to correct any mistakes, to erase, to restrict or to port your personal information
You can request that we correct any mistakes in your information which we hold, free of charge. You will be provided with a form to help us identify you and to inform us of the information that is incorrect and what it should be replaced with. You have the right to ask us to erase, restrict processing or to port your data. Please contact the Data Protection Officer.
Your right to ask us to stop contacting you with direct marketing
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please get in touch with our Head of Marketing using the below details, or, unsubscribe to any email.
By email: email@example.com
Head of Marketing
Audley Group Head Office
65, High Street
By phone: 0800 093 8181.
How to make a complaint
If you are unhappy with the way your personal data has been processed, you may in the first instance contact the Data Protection Officer using the contact details below.
You can get in touch with Audley Group as follows:
Data Protection Officer
Audley Group Head Office
65 High Street
By email: firstname.lastname@example.org
By phone: 01784 412826
If you remain unsatisfied with our response or believe we are processing your personal data not in accordance with the law, you can complain to the Information Commissioner’s Office (ICO).