We are Home Instead Limited (“Home Instead”) a company registered in England & Wales with company registration number 5564869. Our registered office address is Unit 2 Walnut Tree Business Centre, Walnut Tree Farm, Lower Stretton, Warrington WA4 4PG.
We license a nationwide franchise network, with each franchisee operating under the Home Instead brand (referred to as a “Franchised Offices” in this privacy promise). Throughout the rest of this privacy promise, where we say “We” or “Our” we are referring to Home Instead and its Franchised Offices.
This privacy promise sets out how We collect and use personal data, in accordance with the UK’s General Data Protection Regulation (“GDPR”) and Data Protection Act 2018 (“Data Protection Legislation”).
We respect your privacy and comply with data protection law whenever We process your data. The law 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.
Home Instead and each of its Franchised Offices have a “Privacy Champion”, who takes the lead on all data protection and privacy related matters. They should be your first point of contact for any queries or concerns you have around the way your personal data is collected or processed.
If your query or concern relates to a Franchised Office, you should contact that Franchised Office using the Contact Us page of their website and ask to be put through to their Privacy Champion. You can use the “Find care near you” search tool on the front page of this website to locate your Franchised Office.
If your query or concern relates to Home Instead, you can contact our Privacy Champion using the details below:
Ben Damm
Head of Legal
Email: [email protected]
The kind of information Home Instead and our Franchised Offices collect about you will depend on who you are. The sections below explain in detail what information is collected on each group of individuals.
Your personal information will only be used for the purposes for which it was collected, unless We reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If We need to use your personal information for an unrelated purpose, We will notify you and We will explain the legal basis which allows us to do so.
Please note that We may process your personal information without your knowledge or consent, but We will only do so where this is required or permitted by law.
It is important that you read this privacy promise together with any other privacy policy or fair processing policy We may provide on specific occasions when We are collecting or processing personal data about you so that you are fully aware of how and why We are using your data. This privacy promise supplements other notices and privacy policies and is not intended to override them.
Enquiries about provision of care services
Enquiry form. If you are enquiring about the services which our network offers and complete the enquiry form on our website, Home Instead records the following information about you and/or the individual who may require our services:
Home Instead collects the above data for the purposes of matching you with the Franchised Office for the area where the services are to be provided. If we do not have a Franchised Office in your area, we will pass your details to the closest Franchised Office. The relevant Franchised Office will then contact you to discuss your requirements and to provide further information about the services they can offer.
“Save for Later” function. This is a function which allows you to save your enquiry form without submitting it to us. If you use this feature, your partially completed form will be saved to our database, and you will receive an email with a randomly generated link which you can use to retrieve the form and continue to complete it. If you do not retrieve your form within 8 weeks of the date when it was saved, all data will be automatically deleted from our server.
Call recording. Please note that we and our Franchised Offices may record incoming and outgoing calls for the purposes of monitoring and training. You will be notified when recording is occurring. We store recorded calls in accordance with our retention policy. Franchised Offices have their own retention policies.
If you’re a client of one of our Franchised Offices
Franchised Office. If you are a client, prospective client or former client of a Franchised Office, or a family member, our Franchised Office may collect and store the following categories of personal information about you:
Our Franchised Office will collect and process your personal data for the purposes of providing the client with their services. Please note that without collecting and processing certain personal data including any data required from you, your family or next of kin, our Franchised Office will be unable to provide their services.
The Franchised Office may share some of your information with other health and/or social care professionals and emergency services where appropriate (i.e. required in order to provide you with their services, if it is in their legitimate interest to do so, or if it is in your vital interests). They may also share some of your information with other Franchised Offices under common ownership where necessary to facilitate your care, for example where back office functions are shared across a wider group.
National Data Opt Out (England only). The Franchised Office’s Privacy Champion reviews all of that office’s data processing on an annual basis and will assess if the national data opt-out applies to its processing. This is recorded in their record of processing activities. All new processing is also assessed to see if the national data opt-out applies.
You should note that the data opt-out does not apply where the Franchised Office only use your data for providing our care services. In most cases this will be the case.
Should at any time, the Franchised Office’s data processing fall within scope of the national data opt-out they will use NHS Digital’s MESH system to check if any of their clients have opted out of their data being used for this purpose.
Home Instead. We process your personal data for a number of reasons:
If you are an employee of one of our Franchised Offices
Franchised Office. If you are employed by one of our Franchised Offices, they will collect a range of personal information about you. This will include:
They may also collect, store and use the following special categories of more sensitive personal information:
The Franchised Office collects this information in a variety of ways. For example, data is collected directly from you through the application form, the recruitment process and during work-related activities throughout the period of working for them.
In some cases, the Franchised Office collects personal data about you from third parties, such as references supplied by former employers.
Data is stored in a range of various places, including in your personnel file, in our HR system and in other IT systems (including the email system).
Our Franchised Office needs to process this data to form an employment contract with you and to meet its obligations under your employment contract. In addition, they may need to process data to ensure that they are complying with their legal obligations, for example, they are required to check an employee’s entitlement to work in the UK, and in some cases, it may be necessary to carry out criminal records checks to ensure that individuals are permitted to undertake a particular role.
Where multiple Franchised Offices are under common ownership, some of your information may need to be shared with other Franchised Offices within the corporate group in order to utilise shared back-office services.
Home Instead. We process this data in order to ensure that our Franchised Offices comply with our franchise agreement with them, specifically as relates to safe and proper recruitment practices.
In other cases, we have a legitimate interest or legal obligation in processing personal data before, during and after the end of the employment relationship. For example, we may contact employees who are leaving Home Instead in order to conduct an exit interview with them. We will share the names and work email addresses of franchise owners and key players nominated for the purpose with our US parent company Honor Inc for purposes of invoicing royalties.
Applying for a job with Home Instead or one of our Franchised Offices
If you apply for a position at Home Instead or one of our Franchised Offices, we or the Franchised Office (as applicable) will collect and process the information you provide to us as part of your application. This information will be processed for the purposes of assessing your suitability for the role you have applied for.
If you are successful in your application the information you have supplied will form part of your HR record and processed as set out above in the “employee” section.
In addition, We will analyse information provided as part of the application process in order to identify trends and ensure that Home Instead remains an employer of choice in the market place. We will always anonymise your data before we extract it from our systems to share with other parties.
If you are unsuccessful, unless you have given us permission to keep your application data, we will delete it once it is no longer lawful for us to retain it.
Enquiries about becoming a Franchise owner
If you apply (directly or via our website) to become a franchise owner whether for a new franchise opportunity or to take over an established Franchised Office that is for sale, Home Instead will require the following information from you:
This information will be processed via our franchise development system for the purposes of assessing your application, inviting you to meetings to discuss opportunities, speaking with other franchise owners and identifying factors that may affect your suitability.
If you are successful, your information will be maintained in our franchise development and legal systems. If your application is unsuccessful your information will be deleted from our systems once it is no longer lawful for us to retain it.
If you engage with Home Instead Charities (registered charity number (England and Wales) 1156700 and (Scotland) SC044921) we will always collect the minimal amount of information needed. When applying for a grant we may collect the following information:
We require this information to understand your needs and provide you with an effective service, and in particular for the following reasons:
When volunteering for Home Instead Charities they may collect the following information:
Home Instead Charities may periodically send promotional emails about new products, special offers or other information such as for market research purposes which they think you may find interesting using the email address which you have provided (with your permission).
If you apply for a grant and are successful
If you apply for one of Home Instead Charities’ grants, we will ask for additional materials relating to your application. Such information will be stored within our systems for the purposes of assessing your application, and if successful, to issue the grant.
If your grant application is successful Home Instead Charities will also share your information with a Franchised Office which is closest to your organisation, unless you have already told us you have a connection with one of our other Franchised Offices. Your data is shared for the purposes of issuing the grant, via the Franchised Office, and for local PR and marketing purposes (with your permission).
Our website is not intended for children and we do not knowingly collect data relating to children.
Using the Contact Us function
If you complete a Contact Us form on our website, We typically collect the following information:
Depending on what contact form you’re using, We may also collect additional information. It will be obvious what we’re collecting and why We need this additional information, and We will only use it for the purposes of the original contact. Although, as set out elsewhere, Home Instead may share your information with our Franchised Offices if necessary, in order to assist with your query.
If you contact Us by email and telephone, we will only collect and process the personal data which you provide to us, also, it shall only be used for the purposes for which you provide your personal data to Us. For example, if you contact Home Instead with an enquiry about the provision of care, we may share your details with one of our Franchised Offices.
Cookies
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
Our website uses cookies to distinguish you from other users of our website. This helps Us to provide you with a good experience when you browse our website and allows Us to improve our site.
We use cookies for a number of reasons on our website:
We also make use of specific website addresses (called “Urchin Tracking Module” or “UTM”) which allow Us to identify an individual from how they interact with our website. For example, it enables Us to track specific marketing campaigns, the source of those campaigns (e.g., on social media) and if you provide Us with contact information, we’re able to build up a profile of how you have engaged with our website and marketing activities. Such information will only be stored in our CRM if you have consented to the use of the cookies that are needed for the UTM to work.
Before We make use of these technologies via the website, where required you will be prompted to provide consent for their use. If you do not consent to their use, these cookies and pixels will not be used, and We will not be able to measure the effectiveness or provide our marketing messaging to you. However, if you do consent to the use of these cookies then certain information about you and your web activity will be shared with Facebook and Google for the purposes of their advertising services, and as such this data may be processed outside the UK and EEA. Via our cookie control settings, you may change your mind at any time.
From time to time Home Instead, or our Franchised Offices may obtain your consent to send you educational and promotional material. You will have the opportunity to specify how you wish to receive such material and we and our Franchised Offices will only contact you by the means you have specified, i.e. email, mobile, landline or all contact options. You will have the opportunity to unsubscribe from all or some of the marketing material at any time. If you wish to unsubscribe, simply choose the Unsubscribe option or contact us or the relevant Franchised Office and let us or them know that you no longer wish to be on the mailing list.
Your information is safe with us, and we will not share your personal data for marketing purposes with any third party other than as specified in this privacy promise or with your consent.
How long we keep your data
We will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Home Instead
Where data has been shared with us by your Franchised Office, we will retain access to that data for as long as the Franchised Office holds that data, in accordance with their data retention policy.
Website users
For all data submitted to us via our website, We will keep your details for a period of 6 months from the date of submission. Upon expiry of that period, your data will be automatically anonymised.
If you have used the “Save for Later” function you will have 8 weeks from the date on which you saved your form to retrieve it, complete it and submit it to us. If you do not retrieve and submit your form during this period, your data will be deleted automatically upon the expiry of 8 weeks.
Franchised Offices
Clients & clients’ families
To comply with their legal and regulatory obligations our Franchised Offices have to retain your personal data for a period of 7 years from the date of last entry. Once this period has expired, all of your personal data will be permanently deleted.
Job Applicants
If your application is successful, the retention of your personal information will be governed by the retention timescales applicable to the Franchised Office’s employees.
If your application is unsuccessful, to comply with its legal obligations the Franchised Office may retain your personal information for up to 6 months after you have been notified of the recruitment decision, unless you have given your express explicit permission to retain your information for longer.
Employees
To comply with their legal obligations our Franchised Offices have to retain the majority of your records for 6 years from the date your employment ends.
We do not, as a matter of course, transfer your data outside of the European Economic Area and use, as far as possible, UK or European data centres. Where We use data processors who only have overseas-based data centres, We only do so in limited circumstances and always only after completing a thorough due diligence process to ensure the continued safety and security of your data.
We use a number of third-party cloud-based services for the purposes of effectively running our business and providing our services to you. We also use a number of third-party organisations, e.g. accountants, HR support, CRM system etc.
In all cases where We are using a third-party service or company, We will only provide the minimal amount of information required.
We always carry out due diligence against all our third-party suppliers for the purposes of ensuring their compliance with Data Protection Legislation and specifically that they have suitably security measures in place to protect your data. We also make sure a legally binding contract (sometimes called a Data Processing Agreement or DPA) is also in place to protect your
Because the data We hold about you is your data, you have the following rights in respect of the personal data We hold about you:
If you would like to exercise any of the above rights please contact the relevant Privacy Champion using the contact details above.
If you have any concerns about our handling of your personal data, we’d rather you brought it to either Home Instead or the relevant Franchised Office (as applicable) in the first instance, but of course you have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) by visiting https://ico.org.uk/concerns/ or telephoning the ICO helpline on 0303 123 1113.
For more information about your data rights and privacy or data protection in general visit the Information Commissioner’s Office website: https://ico.org.uk
We keep our Privacy Promise under regular review. This Privacy Promise was last updated in December 2023.
If you have any questions about this Privacy Promise, please contact our Home Instead Privacy Champion via [email protected].