Privacy Policy

The Rowan Organisation Privacy Policy

This privacy policy sets out the privacy practices for The Rowan Organisation, a company incorporated in England & Wales with company number 2783681. The Rowan Organisation is limited by guarantee and registered charity No 1017932, having its registered office at the Eliot Park Innovation Centre (EPIC), Barling Way, Nuneaton CV10 7RH ("we", "us", "our"). Our website is http//: www.therowan.org (the "Website") and all associated sub-domains.

In order to provide our services to you and to promote our business, we will need to collect and process certain personal information about you.

We are committed to protecting the privacy and security of your personal information, in accordance with the applicable data protection laws, including the General Data Protection Regulation, together the “Data Protection Laws”. This privacy policy describes how we collect and use personal information about you during and after our involvement with you.

If you have any questions at all about this policy or the Website, or about how we use and process your personal information, please do not hesitate to contact us by e-mail at info@therowan.org or, alternatively, in writing to The Rowan Organisation, EPIC, Barling Way, Nuneaton CV10 7RH.

If we change our privacy policy we will post the changes on this page, and may place notices on other pages of the Website, so that you may be aware of the information we collect and how we use it at all times. Continued use of the Website will constitute your agreement to any such changes.

1. Our role

In order to enable us to provide our services to you, we have been provided with certain personal data by either yourself or a referring organisation such as a Local Authority, Clinical Commissioning Group or Local Health Trust. We have been provided with certain personal data as described further within this privacy policy. We will only contact you directly if we have permission to do so.

For the purposes of the applicable Data Protection Laws, The Rowan Organisation is the data controller of your personal data collected in connection with your use of, or interest in, our services.

2. What information we collect

In addition to the information provided to us, we will collect certain personal information about you when you contact us by phone, e-mail, text, online chat or through face to face conversation. We will hold this information in order to tailor the information that we provide to you and to ensure that it is appropriate and accurate.

With regard to each of your visits to our Website we will automatically collect the following information:

technical information, including the internet protocol (IP) address used to connect your computer or mobile device to the internet, type of mobile device you use, a unique device identifier, mobile network information, your login information, browser type and version you use, browser plug-in types and versions, operating system and platform;
information about your visit to our Website, including the full uniform resource locators (URL) clickstream to, through and from our Website (including date and time); pages you viewed or information you searched for; page response times, download errors, length of visits to certain pages; and
details of your visits to other websites via our Website.

3. Lawful basis and purposes of processing of your personal information

We collect information about you so that we can:

identify you and manage your account on our Customer Relationship Management System (CRM).
liaise with relevant partners on your behalf, including but not restricted to your funding authority, HMRC, Government agencies,
deliver bespoke support to help you to manage your funding
improve our services;
promote our business and market our services;
manage our business, including for accounting and auditing purposes;
conduct our regular group reporting activities on the performance of our company, in the context of a business reorganisation or group restructure;
maintain our IT systems and manage hosting of our data;
deal with any legal disputes involving you directly
prevent fraud; and
comply with our regulatory obligations.

We will only use your personal information when the law allows us to, i.e. when it is necessary to:

perform our contractual obligations towards you, as set out in our contractual terms and conditions for orders and support services;
comply with our legal and regulatory obligations;
pursue our legitimate interests (e.g. conducting our business in an efficient, compliant and profitable manner and the overall promotion of the business), and where your interests and fundamental rights do not override these interests.
If you have provided us with your individual contact details (for example, your personal email address), we will rely on your consent to send you electronic communications such as our newsletters and emails with information about our products and/or services. If we hold business contact details (for example, your work email address), we will rely on legitimate interests of the business to send you electronic communications, but we will always provide you with an option to opt out from future communications of this kind. See the “Direct mailings” section below for more details.

Some of the above grounds and purposes for processing will overlap and there may be several grounds which justify our use of your personal information.

We will only use your personal information 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 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, in compliance with the above rules, where this is required or permitted by law.

4. Uses made of the information

We will use the information we receive from you to:

communicate with you in response to a query or support requirement
to provide you with support related to the management of and the associated responsibilities of your Direct Payment, Personal Budget or Personal Health Budget
to provide you with information about the support that we offer.For more details see “Direct Mailings” section;
to notify you about changes to our services, our terms and conditions of our services, our website or this privacy policy; and
to ensure that our services are presented in the most effective manner for you according to your individual requirements and preferences.

We will use the information we collect about your use of our Website:

to administer our Website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our Website to ensure that content is presented in the most effective manner for you and for your computer and/or your mobile device;
to help us improve and personalise our services;
to allow you to participate in interactive features of our Website when you choose to do so;
as part of our efforts to keep our Website safe and secure;

5. Disclosures of your Information

We do not sell or share your personal data with third parties for them to use for marketing purposes.

We may allow our staff, consultants and/or external service providers acting on our behalf, and our provider of payment services, to access and use your personal data for the activities we have described above. We only permit them to use it to deliver the relevant service, and if they apply an appropriate level of security protection.

We will share your personal information with the following third parties:

your funding providers in order to comply with contractual monitoring requirements, to which you have already provided permission;
our regulators, including the Financial Conduct Authority;
law enforcement agencies in connection with any investigation to help prevent unlawful activity.

We require third parties to respect the security of your data and to treat it in accordance with the law. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

We also reserve the right to disclose the information collected about you to our professional advisors and/or if we, in good faith, believe it necessary to protect the personal safety of users or the public.

We may share aggregated demographic information with our stakeholders. This is not linked to any personal information that can identify any individual person.

We may partner with another party to provide specific services. When you sign up for these services, we will share names or other contact information that is necessary for the third party to provide these services.

These parties are not allowed to use any personally identifiable information except for the purpose of providing these services. We may also use such aggregated information and statistics for monitoring the Website usage in order to help us develop the Website and our services and may provide such aggregate anonymous information to third parties.

6. Links

The Website may contain links to other websites. Please be aware that we are not responsible or liable for the privacy practices of other websites. We encourage you to be aware when you leave the Website and to read the privacy policies of each and every website that collects personally identifiable information. This privacy policy applies solely to information collected by us on the Website.

7. Direct mailings

We may occasionally send out newsletters, offers or alerts to our members and to other business contacts. We may also wish to provide you with information about special features of our Website or any other service or products we think may be of interest to you.

Where required by the Data Protection Laws (for example, if you have provided your personal contact information) we will send you such information only if you have specifically elected to receive it. You can opt-out from receiving such communications at any time – please see “Your rights” section below. From time to time the Website may request information from you via surveys or contests. Participation in these surveys or contests is completely voluntary and you, therefore, have a choice whether or not to disclose this information. Information requested may include contact information (such as name and address), and demographic information (such as postcode or age level). Survey information will be used for purposes of monitoring or improving the use of and satisfaction with this Website.

8. Keeping your data 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.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any personal data that are transferred via the internet. If you have any particular concerns about your information, please contact us (see our contact details below). 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.

9. Transfers of your information out of the EEA

Due to the nature of our business, it is highly unlikely that we would ever need to transfer your personal data outside the European Economic Area (EEA). However, in the event that we did, we will ensure that any transfer of your data will be subject to appropriate safeguards, such as a European Commission approved contract (if appropriate) that will ensure you have appropriate remedies in the unlikely event of a security breach.

10. Retention periods

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer our customer, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

11. Your rights

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current.Please let us know if your personal information changes during your relationship with us.

Your rights in connection with personal information

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 confirmation from us as to whether we process any of your personal information or not, and if this is the case, to receive a copy of such personal information 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 deletion of your personal information (often referred to as “the right to be forgotten”). 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.
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, or if we no longer need your data for our legitimate interests but we need to hold some of it for the purpose of legal proceedings.
Request the transfer of your personal information to another party.

If you would like to exercise any of the above rights, please:

email, call or write to us (see our contact details below);
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill). This is to allow us to verify your identity and prevent disclosure to unauthorised third parties; and
let us know the details of your request, for example by specifying the personal data you want to access, the information that is incorrect and the information with which it should be replaced.

Please note that if you request erasure, object to our processing of your personal data or request the restriction of our processing of your personal data we may not be able to provide our services and we may need to deactivate your account with us.

You can always unsubscribe from our email communications by updating your contact preferences. In order to us please contact us at info@therowan.org , by telephoning 02476 322860 or by writing to us at The Rowan Organisation, EPIC, Barling Way, Nuneaton CV10 7RH.

12. Contact us or the ICO

If you have any concerns or complaints about our privacy activities, you can contact us at info@therowan.org - You can also contact the Information Commissioner’s Office on 0303 123 1113. For more details about your rights under the Act, the rules we have to adhere to in collecting and storing your information, and how you can check your data records, please visit https://www.gov.uk/data-protection/the-data-protection-act.

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