Carveti Group Privacy Policy

Privacy Statement Summary:

This Privacy Policy (“Policy”) explains how your information is collected, used and disclosed by Carveti Group (“We” or “Us” or “our”). 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 are committed to safeguarding the privacy of our website visitors and service users. We will never sell, share, or use your personal information other than as described here.

By using our website and agreeing to this Policy, you consent to our use of cookies in accordance with the terms of this Policy.

Who will use my data?

Carveti Group

What for?

We will store and process your data in order to allow us to provide our  services. This includes managing projects such as:

• Property and Programme Management
• Property Asset Management
• Commercial Management
• Financial Management
• Installation of modular buildings
• Hard Facilities Management Services
• Refurbishment of Modular Building Ward Blocks

We may also use your data to process financial transactions including payments.

If you contact us, we may also send you information that we think you will be interested in. This may include a range of related products and services.

We will also send any relevant details to authorities such as HMRC and any other organisation that requires them by law.

What will happen if I contact you?

If you contact us, we will use your data to send you the information that you have requested and updates, offers and other information that we think you will be interested in.

If you choose to use our services, we may collect more information from you and where necessary share your information with carefully selected third parties required to provide the services you have requested.

Where we share your data, this will be as you would reasonably expect and always with your consent.

How we get your personal data

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• You contact us by email, telephone and through other written and verbal communication
• You use the “contact us” form on our website

We use the information that you have given us in order to provide you with access to all relevant parts of our website and to supply the services you have requested.

We will also collect and store personal information where:

• You apply for a job
• You contact us with a general enquiry (website, post, email and telephone
• You request information about our services
• You enter into a contract with one of the Carveti Group companies
• You complete a customer satisfaction form
• You contact us to make a complaint

The data we collect via the methods identified above is used by Carveti Group companies only. Unless required to do so by law or to deliver services to you, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.

What data will be stored?

We will store your personal details, and where necessary employment and financial information in order to provide our services to you and run our company.

We will store your details plus relevant information relating to enquiries, contracts and financial, and other information as required. This will include your contact details and company information.

What data will be shared?

We will only share data where strictly necessary to meet our obligations in order to provide the services that we offer.

We will not share your data with any third parties other than as required to fulfil our contracts and as described here. We may share your information with regulators or legal bodies that request it. We will only share any data that is particularly relevant to our process in order to provide the services that we offer.

We will only share your data with third parties who have met their obligations regarding the GDPR implementation and  comply with all other relevant data protection laws.

We will never sell your personal data to other companies / third-parties.

How long?

Your data will be stored only for as long as strictly necessary to provide our services to you and meet our legal obligations after which time your data will be deleted.

Where there is no legal or contractual obligation, we keep your personal information up to six years after any enquiry you make.

For more information, please refer to our Data Retention Policy.

Who can access my data?

We will never sell, share, or otherwise distribute your data to any other third party other than as described here.

We will share your information with any regulator or legal body that requests it as well as any parties relevant to the application process.

We ensure access is restricted to only those persons authorised by us to access your data.

How is my data kept secure?

We will primarily store your data on secure UK based servers which will be processed in the UK. We use industry standard security protocols/technology to secure your data. Where we do transfer your data outside of the UK we will take all appropriate precautions to protect your data including establishing DPA/SCCs with any third party.

We take your privacy seriously and will only use your personal information to provide the services you have requested from us and to send you information about services you may be interested in. We will never sell, share or use your personal information other than as described here.

About This Privacy Policy

This policy sets out how we will use and share the information that you give us. This policy describes your relationship with Carveti Group.

The General Data Protection Regulation (GDPR) describes how organisations must collect, handle, process, and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. GDPR is underpinned by eight important principles. These say that personal data must:

• Be processed fairly and lawfully
• Be obtained only for specific, lawful purposes
• Be adequate, relevant and not excessive
• Be accurate and kept up to date
• Not be held for any longer than is necessary
• Processed in accordance with the rights of the data subjects
• Be protected in appropriate ways
• Not be transferred outside the UK, unless that country or territory also ensures an adequate level of protection

We take these responsibilities seriously; this document describes our approach to data protection. This policy helps to protect us from data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
• Loss, damage, or other consequences of such a breach or security failure

Who We Are And How To Contact Us

Carveti Group is an NHS partner providing property and project management services in healthcare. Our operating company subsidiaries Carveti Partnership Limited and Carveti Consulting Limited are registered in the UK and with the Information Commissioner’s Office. The Data Protection Leads are Jenni Carrick and Caroline McLeod. You can contact us in any of the following ways:

Email: jenni@ccl.solutions / caroline.mcleod@carvetipartnership.com

Telephone number: +44 (0)1931420042

Address: Suite 209a, Challenge House, Sherwood Drive, Bletchley, Milton Keynes, MK3 6DP

Website: https://carveti.group/

Who this privacy policy applies to

This policy relates to data subjects of Carveti Group including customer, contractor employee, intern, supplier, and all other individuals.

We provide a range of property related services, and in order to offer you these services and for us to meet our contractual and legal commitments to you, a processing of your data is required.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:

• ames of Individuals
• Contact details
• Postal addresses
• Email Addresses
• Telephone numbers
• Financial information
• Employment information
• Criminal convictions or pending legal actions against you
• Any other information relating to individuals as required to provide our services to you

What this policy applies to

This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. This includes:

• The Information you provide when you contact us
• When you contact us in order to discuss using our services
• Information we collect about how you use the website
• Information relating to services we offer to you and other transactions including financial and other personal information required to complete these transactions
• Information that is given and stored as part of our ongoing relationship
• Information we collect from third parties and other agencies
• Information we collect from social media and other public domain sources

We do not collect or process sensitive data about you.

How your information will be used

We will only use your personal data for the purposes for which we collected it and as you would reasonably expect your data to be processed and only where there is a lawful basis for such processing, for example:

We may collect and process information about you, including your name, date of birth, address, contact details (including email address and mobile phone number), service details, purchase history and data collected as part of any finance application or payment (including previous addresses, employment details and bank account details). We may take personal information from:

• Information that you provide to us when visiting our website or using the contact mechanisms (including your email address, phone number, chat services, post etc…)
• Information that you provide to us when signing up to any distribution lists to receive correspondence from us
• Information relating to any services we provide you including any other transaction details made (including your address, telephone number and payment details)
• Other information as necessary to complete our checks, complete any contracts, and to manage our ongoing relationship

Personal data we receive will be used for the purposes it was provided, including but not limited to:

• To respond to queries from you regarding our services
• To carry out our obligations arising from any contracts entered into between you and us including provision of services, and to respond to queries from you regarding those contracts
• To manage and administer the relationships between you and us
• To notify you about changes to our services and to otherwise communicate with you
• To obtain feedback from you regarding us and our services.

How to change your preferences

We operate in line with GDPR data protection guidelines. We respect your rights and will respond to any request for access to personal information and requests to delete, rectify, transfer, data and to stop processing. We will also advise you on how to complain to the relevant authorities, namely the Information Commissioner’s Office. Any requests or objections should be made in writing to the Data Controller, or you can visit our website, call, or email us to contact us to change your preferences at any time.

Scope of Agreement

By submitting your personal data on this site or as required for us to provide services to you, you are affirming your agreement for such information to be used in accordance with this privacy policy. You will be able to change your preferences at any time by the methods described as prescribed in this document.

We may from time to time use your information for marketing, account management or relationship management purposes. The main purpose of this is to provide you with information about services which we think may be of interest to you and/or to maintain any existing relationship we may have with you.

Opting out at a later date

Where you give your consent for us to process your data, for example when you agree to us sending you marketing information or where you agree to us processing financial data, you can contact us to amend or withdraw your consent at any time. You can also choose to object to processing and request deletion of your data. We respect all user rights as defined in GDPR. If you have any comments or wish to complain please contact us.

How we store and process your data

Your data will be collected, stored and processed primarily in the UK, where we transfer your data outside the UK, we will ensure we take appropriate precautions to protect this data. Your data will normally be stored for up to 7 years to ensure we have records of service, payments, contracts and other interactions we have with you. For details on retention periods please ask for a copy of our Data Retention and Erasure policy.

In order to provide our services to you, we use recognised third parties to take payment, conduct credit reports and other checks such as BACS. We also use third parties to manage our company accounts such as Quickbooks, this third party operates outside the UK, and it has taken every measure to provide an adequate compliance with the GDPR and other data privacy regulations.

We will store transactions, payment and order data for up to 7 years or for as long as required by UK financial and company regulations.

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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may be legally obliged to disclose your personal information without your knowledge to the extent that we are required to do so by law; in connection with any ongoing or prospective legal proceedings; in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

You will only receive marketing communications from us if you have:

• Requested information from us
• Used our services previously
• If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications
• You have not opted out of receiving marketing
• Where we believe you will be interested in our services and we have a valid legitimate interest to process your information

Our obligations

We are a Data Controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the GDPR in the way we use and share your personal data. Among other things, this means that we will only use your personal data:

• Fairly and lawfully
• As set out in the legislation and this policy
• To the extent necessary for these purposes
• We will take steps to ensure your data is accurate and rectify data as necessary

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

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

You can see more about these rights at: https://ico.org.uk/

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.

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.

We try to respond to all legitimate requests within one month. 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.

Third Parties

We may have to share your personal data with the parties set out below for the purposes described in this document:

• Contractors, managing agents, and other third-parties we use for repairs, maintenance, renovation, and other services necessary to meet our obligations to you, as required to run our business, and in order to meet our legal obligations
• Utility companies, local councils, and other third parties in order to fulfil our commitments to you and to meet our contractual obligations
• Service providers who provide IT and system administration services.
• Third parties including equipment providers, and other third parties as required to run our business
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, credit scoring, banking, legal, fraud protection, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.
• Other companies as required to provide our services to you and to operate our company

Under the GDPR, we are also permitted to share some information with third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

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 such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.

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.

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

As well as your ability to accept or reject cookies, we also require your permission to store cookies on your machine, which is why when you visit our site, you are presented with the ability to accept our terms of use, including the storage of cookies on your machine. Should you not accept, then you are free to leave our website, at any time.

Contacting us, exercising your information rights and Complaints

If you have any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact: Caroline McLeod from Carveti Group at caroline.mcleod@carvetipartnership.com. We will process data protection requests within 30 days, SAR responses are usually free but we reserve the right to charge for excessive or unfounded requests. We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.

If you remain dissatisfied, then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

www.ico.org.uk