Privacy policy Introduction We are committed to safeguarding the privacy of our website visitors and service users. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website. In this policy, “we”, “us” and “our” refer to Kent, Surrey, Sussex AHSN Limited. For more information about us, see section 12. How we use your personal data In this Section we have set out: the general categories of personal data that we may process in the case of personal data that we did not obtain directly from you, the source and specific categories of that data the purposes for which we may process personal data the legal bases of the processing. We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services. We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent. We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent. We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others . We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks. We may process any of your personal data identified in this policy where necessary for the purpose of processing your application for employment with us. The legal basis for this processing is our legitimate interest of allowing us to manage the recruitment process, assess and confirm your suitability for employment, decide whether to offer you a job and to keep records of that process. We may also need to process data from job applicants to respond to and defend legal claims. For further details of this purpose please see our Privacy Notice for Job Applicants. In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Please do not supply us with any other person’s personal data unless we prompt you to do so. Providing your personal data to others We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. We may disclose your enquiry data to one or more of those selected third party organisations identified on our website for the purpose of enabling them to contact you in connection with your enquiry. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data. In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. International transfers of your personal data In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA). We will not transfer your personal information to any country outside the EEA without your consent. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others. Retaining and deleting personal data This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain your personal data as follows: all categories of personal data will be retained for a minimum period of one year following receipt, and for a maximum period of six years. Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Amendments We may update this policy from time to time by publishing a new version on our website. You should check the website page occasionally to ensure you are happy with any changes to this policy. We may notify you of significant changes to this policy by email. Your rights In this section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. Your principal rights under data protection law are: the right to access the right to rectification the right to erasure the right to restrict processing the right to object to processing the right to data portability the right to complain to a supervisory authority the right to withdraw consent. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by sending a request to kssahsn.dataqueries@nhs.net. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest. To the extent that the legal basis for our processing of your personal data is: consent that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract; and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. You may exercise any of your rights in relation to your personal data by written notice to us. For more information about contacting us, see section 12. About cookies To comply with EU legislation we are required to tell you about the cookies used on this website. We use cookies only because we want you to find the information you need as quickly and easily as possible. A cookie is a small text file that is placed on your computer when you visit a website. Cookies help websites function usefully and can provide information to website owners. Cookies do not place viruses on your computer and cannot run programs. Our cookies do not provide us with any private or personally identifiable information about you. All data that is gathered is anonymous. Some of the cookies we use collect information about how visitors use our site. For example, one of our cookies counts the number of visitors to the site and notes which pages they visited. This anonymous information helps us to compile statistical reports, which can help us to improve the site. Your web browser gives you the ability to accept or decline cookies. Generally, web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. However, if you choose to decline cookies, some useful features of this website will not work. For example, there is the option to view this website as text only, with no graphics. The ‘useTextOnly’ and ‘setString’ cookies remember that you have chosen to view this site with no graphics. If you choose to decline cookies you will have to select the text only option every time you view a new page. Cookies that we use We use cookies for the following purposes: Cookie Purpose cookieyes-consent This cookie is used to remember the user’s consent to the use of cookies on the website. Google Analytics _ga_* _ga These cookies are used to collect information about how visitors use our site. This information can be used to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for an overview of privacy at Google You can change your cookie preferences at any time by clicking on the consent preferences button in the bottom-left corner of the site or find out more about cookies, including how to see what cookies have been set and how to manage and delete them, at these sites: http://tools.google.com/dlpage/gaoptout http://www.allaboutcookies.org/ Cookies used by our service providers and others Our service providers do not use any cookies connected with the use of our website. Websites that you may link to from our website may use additional cookies over which we have no control and for which we have no responsibility. We refer you to these websites for details of their privacy and cookie policies. We may use ‘plug ins’ and embedded media to provide additional content (for example YouTube). The suppliers of these services and content may use additional ‘third party’ cookies over which we have no control and for which we have no responsibility. We refer you to the suppliers of these services for details of their privacy and cookie policies. Managing cookies Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies for some popular browsers via the following links: https://support.google.com/chrome/answer/95647?hl=en (Chrome) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences(Firefox) http://www.opera.com/help/tutorials/security/cookies/ (Opera) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer) https://support.apple.com/kb/PH21411 (Safari) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge). Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you may not be able to use all the features of our website. Our details This website is owned and operated by Kent, Surrey, Sussex AHSN Limited. We are registered in England and Wales under registration number 08877964, and our registered office is at Amelia House, Crescent Road, Worthing, BN11 1RL. Our principal place of business is at Amelia House, Crescent Road, Worthing, BN11 1RL. You can contact us: by post, to the place of business postal address given above using our website contact form at http://kssahsn.nhsservices.org/get-in-touch/Pages/default.aspx by telephone, on the contact number published on our website from time to time or 0300 303 8660 by email, using kssahsn.dataqueries@nhs.net or the email address published on our website from time to time. Regulation For further details of the current legislation and regulations that apply to our processing of your personal data, please refer to the Information Commissioner’s website at https://ico.org.uk. Data protection officer Our data protection officer’s contact details are: dpo@exigia.com.