1. How we obtain your personal information
   1. We collect personal information directly from you when you:
      1. visit our website;
      2. make an enquiry or request additional information from us about our website or services either via our contact form on our website; or
      3. otherwise correspond with us by phone or by email.
2. Your personal information and how we use it
   1. In this privacy policy, we refer generally to your "personal information", which means any data relating to you which identifies you (such as your name) or could indirectly identify you (such as an online identifier).
   2. The personal information we collect, and why we collect it, varies depending on the nature of our relationship with you. In the following tables, we explain for each type of relationship what personal information we collect when you use our website and the purpose for which we collect and use your personal information.

      Visitors to our website
      We, or third parties on our behalf, will collect and use the following personal information about you if you are a visitor to our website:

      Type(s) of personal information	Purpose/activity
      Browser IP address	We use this to identify you when you return to our website
      Usage data - the resources that you access, traffic data, location data, and weblogs)	We use this to improve understanding of how our website is used
      Contact details (first and last name, email address, telephone number)	To allow us to answer any messages you send via our website or via the website contact request or job application request
      Cookies data	For more information, see the 'Cookies' section 11
      Information provided when you correspond with us	We use this to deal with any enquiries or issues you may have

      1. Job applicants
         In addition to the personal information we collect under table A (visitors to
         our website), we, or third parties on our behalf, will also collect and use the
         following personal information about you if you apply for a job via our
         website:

         Type(s) of personal information	Purpose/activity
         Contact details (first and last name, email address, telephone number)	To allow us to contact you in relation to the role you have applied for
         Education data (school, academic performance)	To assess your suitability for the role
         Employment history (current role and employer details)	To assess your suitability for the role

   3. We may also collect, use and store your personal information for the following additional reasons:
      1. to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. We may process your personal information for these purposes where it is in our legitimate interests to do so;
      2. for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of our website, and to identify and implement business efficiencies.

         We may process your personal information for these purposes where it is in our legitimate interests to do so;

      3. to comply with any procedures, laws and regulations which apply to us - this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
      4. to establish, exercise or defend our legal rights - this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
3. Special categories of personal data
   We do not collect more sensitive personal data about you, known as "special categories of personal data", through the website.
4. Our legal basis for using your personal information
   1. We consider that the legal bases for processing your personal information are as follows:
      1. use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of use of our website);
      2. use of your personal information is necessary for complying with our legal obligations (for example, if you contact us requesting access to personal information we hold about you);
      3. use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are:
         1. to provide information regarding our services to you;
         2. to correspond or communicate with you generally; especially
            in regard to any service query or job application
         3. run, grow and develop our business;
         4. operate our website;
         5. for network and information security;
         6. to verify the accuracy of data that we hold about you; and
         7. for internal group administrative purposes.
   2. In the case of "special categories of personal data" we need an additional legal basis to justify our use of that information Depending on the circumstances of our relationship with you, we justify our use of "special categories of personal data" as being necessary for: (a) health or social care purposes, and, in certain situations, protecting your vital interests (if you are a website user enquiring about our healthcare services); and (b) in connection with our employment rights and responsibilities (where you are a prospective job applicant).
5. How and why we share your personal information with others
   1. Routes Healthcare may share your personal information with any company that is a member of our corporate group where (a) it is necessary for the purposes set out above, or (b) it is in our legitimate interests to do so for internal administrative purposes (for example, ensuring consistent and coherent delivery of services to our care recipients, corporate strategy and auditing purposes). We may also share your personal information with our group where they provide products and services to us, such as shared information technology systems.
   2. We will also share your personal information with our service providers, including suppliers of technical and support services, insurers, and cloud service providers.
   3. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws. We also won't share your personal information with any other third party, unless it is for any of the purposes outlined above.
   4. We may also disclose and use anonymised, aggregated reporting and statistics about users of our website or our services for the purpose of internal reporting or reporting to our group or other third parties. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
6. How long we store your personal information
   We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
7. Your rights
   1. You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us using the details at the bottom of this privacy notice at any time. The following rights are most relevant to the services that we provide:
      1. Right of access. You have the right to ask us to provide you with copies of personal information that we hold about you and further details of how we use it and look after it as well as confirmation as to whether your personal information is being used by us.
      2. Right to update your information. You have the right to ask us to update and correct any out-of-date or incorrect personal information that we hold about you free of charge.
      3. Right to delete your information. In certain cases, you have the right to request us to delete or destroy any personal information we hold about you.
      4. Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances.
      5. Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.
   2. We will consider all such requests to exercise your rights, and provide our response, within a reasonable timeframe (and, in any event, any timeframe required by law). Please note that these rights do not always apply in all cases. If we cannot meet your request, we will explain why.
8. Transfers of your personal information outside the UK
   Your personal information is not currently transferred outside the UK by us or our suppliers.
9. How we keep your personal information secure
   1. We are committed to ensuring that your personal information is held securely. In order to prevent unauthorised access or disclosure, we put in place suitable procedures to safeguard the information we collect from you. Where possible, we store personal information on our secure servers which can only be accessed with secure passwords.
   2. While we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, no transmission over the internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal information during its transmission to us over the internet.
10. Cookies
    1. We may on occasion gather information regarding your computer while you are on our website. This enables us to improve our services and to provide statistical information regarding the use of our website.
    2. We may also gather information about your general internet use by using a cookie file. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer as cookies contain information that is transferred to your computer's hard drive. They help us to improve our website and the service that we provide to you.
    3. All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular parts of our website.
11. Minors
    Our website is not directed at children and we do not knowingly collect any personal information from children through the website. If you are a child and we learn that we have inadvertently obtained personal information from you from our website, or from any other source, then we will delete that information as soon as possible.
12. Changes to our privacy policy
    This privacy policy may change from time to time. Any changes we make to our privacy policy in the future will be posted on this page.
13. Contacting us and how to make a complaint
    1. If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights, please contact our data protection officer via the Group’s IT email address at dpo@routeshealthcare.com.
    2. You can complain to the Information Commissioner's Office (ICO) if you are unhappy with the way that we have dealt with a request from you to exercise any of these rights, or if you think we have not complied with our legal obligations. More information can be found on the ICO website: https://ico.org.uk/ or through the ICO's helpline (0303 123 1113).
14. National Data Opt-Out
    At this time, we do not share any data for planning or research purposes for which the national data opt-out would apply. We review all of the confidential patient information we process on an annual basis to see if this is used for research and planning purposes. If it is, then individuals can decide to stop their information being shared for this purpose. You can find out more information at https://www.nhs.uk/your-nhs-data-matters/.

The practices described in this privacy notice are current as of 1st June 2023.