Last updated: April 2019

 

We (Kath Lancaster Nursing Consultancy Ltd are known in this document as “we” or “KLNC Ltd”) operates http://www. Thelancastermodel.co.uk (the “Site”) and are registered in England and Wales with the company number 06668242 and having a registered office at Windsor House, Cornwall Road, Harrogate, HG1 2PW

We are committed to protecting the privacy and security of your personal information. Our privacy policy describes how we collect, store, use and protect personal information. The legal text is below.

KLNC Ltd is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy policy.

Please note – this policy relates only the Lancaster Model website and not any services that may be provided through IDH Ltd or Kath Lancaster Nursing Consultancy Ltd.

 

DATA PROTECTION PRINCIPLES

We will comply with data protection law. This says that the personal information we hold about you must be:

1.    Used lawfully, fairly and in a transparent way.

2.    Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3.    Relevant to the purposes we have told you about and limited only to those purposes.

4.    Accurate and kept up to date.

5.    Kept only as long as necessary for the purposes we have told you about.

6.    Kept securely.

 

THE KIND OF INFORMATION WE HOLD ABOUT YOU

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).

 

 

Information Collection and Use

While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally, identifiable information may include, but is not limited to your name (“Personal Information”) is only requested if you join the membership zone or you complete a “Contact Us” form.

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

No Personally identifiable data is used for marketing or sold to any other company.

 

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the TLM zone of the website.

 

Log Data

Like many site operators, we collect information that your browser sends whenever you visit our Site(“Log Data”).

This Log Data may include information such as your computer’s Internet Protocol (“IP”)

browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics. This is purely used by us to improve our website and services.

 

 

 

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

 

We will gather information in the following ways:

·       Indirectly (through use of thelancastermodel.co.uk)

·       Directly (where information is provided by you)

 

HOW WE WILL USE INFORMATION ABOUT YOU

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

1.    Where we need to perform the contract we have entered into with you.

2.    Where we need to comply with a legal obligation.

3.    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.

 

We may also use your personal information in the following situations, which are likely to be rare:

1.    Where we need to protect your interests (or someone else’s interests).

2.    Where it is needed in the public interest (or for official purposes).

 

Situations in which we will use your personal information

We need all the categories of information in the list above (see The kind of information we hold about you) primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. We have indicated above the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.

Website Visitors

·       To improve our website

·       To answer your queries or feedback

 

 

What automated decision making and/or profiling we do with user data?

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

DATA SHARING

We will ensure that third parties respect the security of your data and treat it in accordance with the law.

Who we share this information with

Information processed through this website is not shared with any other organisation outside of Integrated Digital Health Ltd, Kath Lancaster Nursing Consultancy Ltd or its agreed associates ( who support the Data Processing function)

The following third-party providers process personal information about your for the following purposes:

1and1: website host

Attigo: Website design and developers

IDH Ltd Consultant: TLM zone facilitator and website manager (day to day)

We may also use your personal information in the following situations, which are likely to be very rare:

1.    Where we need to protect your interests (or someone else’s)

2.    Where it is needed in the public interest (or for official purposes)

Our “third parties” and other entities within the company are required to take appropriate security measures to protect your personal information in line with our policies. No third party is allowed any data for their own purposes and we only permit them to process your personal data for specified purposes and in accordance with instructions.

Website users should be aware that any comments left may be checked through an automated spam detection service

 

Why we collect and use this information

 

·      To enable us to carry out specific functions which each customer has requested or agreed

·      Provide requested information and enable training and information facilitation within the customer secure space.

·      Evaluate and improve our business services and website

·      To answer your queries or feedback

·      To make sure we are following guidelines and best practice with applicable legal requirements of governmental and regulatory bodies

The lawful basis on which we use this information

We collect and use this information under the basis of

·      Where it is in our Legitimate Interest to do so (Article 6 GDPR) such as:

o   To follow guidance and recommended best practice of governmental and regulatory bodies

o   To administer our good governance requirements for internal reporting and compliance regulations for AGM’s

o   Subject to the appropriate controls, to provide insight and analysis of our customers to business partners either as part of providing products or services, helping us improve products or services, or to assess or to improve the operating of our businesses

o   To ensure that we can carry out specifically requested functions from users, including requests or actions
The website will not collect any special category data (Article 9 GDPR)

 

DATA SECURITY

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained by emailing data.protection@tlmhapi.co.uk

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

DATA RETENTION

For how Long is your personal information retained by us?

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

  • For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
  • For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
  • Retention periods in line with legal and regulatory requirements or guidance.
  • Visitors to our website should be aware that if they leave a comment the comment and its metadata are retained indefinitely so we can recognize and approve any follow up comments automatically instead of holding them in a moderation queue. If users register through the TLM zone we also store the person information they provide in their profile. All users can see, edit or delete their personal information at any time (but cannot change their username). Website administrators can also see and edit that information.

DIRECT MARKETING COMMUNICATIONS

Customers who are using The Lancaster Model currently are able to sign in to the TLM Zone. For those customers only we may use their data to enable us to communicate by post or email further information that we believe may be of relevance or interest to them. These customers have the right to withdraw from or amend the receipt of direct marketing communications. If you would like to do so, please contact: admin@tlmhapi.co.uk and let us know.

RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION

Your duty to inform us of changes

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information in a portable format to another party.  This allows you to take your information from our IT environment to another organisation’s IT environment.  The format will be chosen based on the information provided, this is likely to be a generic file format such as CSV.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact data.protection@tlmhapi.co.uk

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.

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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

 

RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact admin@tlmhapi.co.uk . Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

 

TRACKING TECHNOLOGIES

We use cookies on The Lancaster Model Website ( in this document known as the “Service”). By using the Service, you consent to the use of cookies. Our Cookies Policy explains what cookies are, how we use cookies, how third parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.

What are cookies?

Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you. Cookies can be “persistent” or “session” cookies.

 

How Integrated Digital Healthcare Ltd (called “the Company” in this document) uses cookies

When you use and access the Service, we may place a number of cookies files in your web browser.

We use cookies for the following purposes:

·      to enable certain functions of the Service

·      to provide analytics

We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:

Session Cookies will be used to keep members logged in an associate their comments to their accounts

Persistent Cookies will be used for storage of user account interactions with posts.

Essential cookies. We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.

 

Third -party cookies

In addition to our own cookies, we may also use various third party cookies to report usage statistics of the Service and some of the plug ins required need to have cookies to work correctly.

 

What are your choices regarding cookies?

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser. Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

 

Where can you find more information about cookies

You can learn more about cookies and the following third party websites:

·      AllAboutCookies: http://www.allaboutcookies.org/

·      Network Advertising Initiative: http://www.networkadvertising.org

OTHER MATTERS

Embedded Contents from other websites and Links to other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

If you go to another website from this one, read the privacy policy on that website to find out what it does with your information. If you visit this site from another website, we may receive personal information about you from the other website. You should read the privacy policy of the website you came from to find out more about this.

 

Changes to This Privacy Policy

This Privacy Policy is effective as of June 2018 ( see version control at end of document and will remain in effect except with respect to any changes in its pro visions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

However, If we make any material changes to this Privacy Policy, we will place  a prominent notice on our website so you can revisit the policy and check you are still happy to use the website based on the changes.

 

Contact Us

If you have any questions about this Privacy Policy, please contact us at:

data.protection@tlmhapi.co.uk

or write to us at

Kath Lancaster Nursing Consultancy Ltd

Windsor House

Cornwall Road

Harrogate

HG1 2PW

Attention: Information Governance Officer

 

Date of next review April 2020

Copyright © 2019 Integrated Digital Healthcare Ltd. 

The Lancaster Model is a registered trade mark. All rights reserved.  

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