Privacy policy

July 2021
 

CLN is committed to respecting and protecting your privacy. We comply with the UK General Data Protection Regulation and Data Protection Act 2018 and in this notice, we will tell you in detail how we use, share and look after your personal information and explain your rights regarding your information when you apply to join the CLN Network, register to attend one of our events, use our website or contact us.

Who we are

We are CLN, also known as CLN Community Limited a company registered in England and Wales under company number 13362003 with our registered office at 25 Moorgate, London, England, EC2R 6AY.

We are a “data controller” in respect of the information we hold about you (registered with the ICO under registration number ZB130127). This means that we are responsible for deciding how we use your personal information.

The information we collect about you

“Personal data” is any information that relates to you and that identifies you either directly from that information or indirectly, by reference to other information that we have access to. The personal data that we collect, and how we collect it, depends upon how you interact with us. Categories of personal data that we might collect include:

  • Contact details, such as your first and last name and your email address.
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  • Biographical information which you provide on your CLN profile; Your employment information, such as your job title, location, type of care you provide, and company;
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  • Your marketing and communication preferences (such membership notifications) and related information;
    Technical data such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not knowingly collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) or any information about criminal convictions and offences.

How we collect your personal data

We collect data about you from the following sources when you:

  • apply to join the CLN Network
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  • register to attend one of our events
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  • use our website – we collect information about your visit and how you interact with our website
    give us feedback or contact us

Cookies and data we collect automatically

When you visit one of our websites, we automatically collect, store and use technical information about your equipment and interaction with our website via cookies. 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 also allows us to improve our site.

We will also receive information about you from Google Analytics, a web analytics service provided by Google, Inc. (“Google”) whose servers are based in the United States of America. Google Analytics uses cookies to help us analyse how users use our site.

The cookies we use

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website.
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  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
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  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
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  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests. We may also share this information with third parties for this purpose.

By continuing to browse the site, you are agreeing to our use of cookies.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the website may become inaccessible or not function properly.
If you wish to find out more about cookies and which cookies have been set on your device, you can visit: www.aboutcookies.org or www.allaboutcookies.org.

What do we use your personal information for?

We will only use your personal data fairly and where we have a lawful reason to do so.

We want you and your other members to get the most out of the network, however, it is up to you how much information you want to share about yourself. You are able to choose what other members and our suppliers can see about you via your profile apart from your name, job title, organisation and location which is mandatory to share with other members and our suppliers.

The purpose of the CLN Hub is to help you to connect with other members of the Care Leaders Network. To enable you to get the most out of the network, we need to use some of your personal information, however it is important to us that you understand how we use this information.

View the ways that we use personal data, and which of the reasons we rely on to do so:

Use of your personal data

To manage our relationship with you, which includes: Registering you as a CLN member; notifying you about changes to our terms or privacy statement; and contacting you where you have requested; ensuring the accuracy of your information; updating your membership notification preferences; and enabling you to connect with and maintain contact with other members of the network.

Events: From time to time, we may contact you about events that we think you might be interested in attending.

Marketing: From time to time, we may send you communications and/or information about us and our services which we think you may be interested in.

To administer and protect our organisation and our website including website maintenance and trouble-shooting.




To use data analytics to improve our website, to deliver relevant website content and advertisements to you, and to measure the effectiveness of the advertising we serve to you.

Our lawful basis for the use of your personal data

Contract: It is necessary in order to take steps to enter into a contract with your or for us to perform our contract with you. Legal obligations: It is necessary to meet our legal obligations. Legitimate interests: It is necessary for our legitimate interests for the running of our network and the improving of our services.

Consent: Where you have consented and expressed a preference to receive such marketing communications.

Legitimate interests: Necessary for our legitimate interests to develop our services and grow our network.

Legitimate interests: It is necessary for our legitimate interests for running our organisation, provision of administration and IT services, network security, and to deal with any enquiries/issues you may be experience with the website.

Legal obligations: It is necessary to meet our legal obligations.

Legitimate interests: it is necessary for our legitimate interests to keep our website updated and relevant, to develop our organisation and to inform our marketing strategy.

Who has access to your personal information?

Information in your profile (such as contact details) will only be available by default to the CLN team so that we can keep in touch with you. It will not be visible in the directory and searchable to other members unless you choose to make it visible. It may also be made available to registered members by other means – for example, when you are a part of the Care Leaders Network, your name will appear in our directory on the CLN Hub and will be searchable by other members and suppliers.

If you choose to provide us with your personal address, personal phone number or personal email address, these pieces of personal information will only be available to the dedicated professionals in our team so that they can make contact with you and will not be available to other members unless you choose to make them available by adjusting your settings in your profile.

The only information which will be available to other members and our suppliers will be your name, job title, location and organisation.

To edit your profile, including adjusting what can be seen by whom, select ‘Edit your profile’ on the Hub.

Sharing and transferring your data

We treat your personal data with respect and do not share it with third parties except as described below.

We may share your personal data with:

  • our suppliers and service providers including event organisers (for instance, our suppliers will have access to certain information on your profile including your name, location, job title and organisation);
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  • to police or other law enforcement and regulatory authorities in relation to security related or law enforcement investigations or in the course of cooperating with authorities, protecting and defending our rights or property or comply with legal requirements;
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  • to our professional advisers including lawyers, auditors and insurers who provide consultancy, legal and accounting services;
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  • to third parties to whom we may choose to sell, transfer, or merge parts of our organisation or our assets. Alternatively, we may seek to acquire other organisations or merge with them. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy policy;
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  • to regulators and other authorities who require reporting of processing activities in certain circumstances.
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  • We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in July 2021.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third party links

The CLN 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 encourage you to read the privacy policy of every website you visit. We do not control these third-party websites and are not responsible for their privacy policy.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms to enable you to exercise your right to prevent such processing by:
Checking certain boxes on the forms we use to collect your personal data; or
By contacting us at support@careleadersnetwork.co.uk

Promotional material from us

You will receive marketing communications from us if you have subscribed to receive news from us, and you have not opted out of receiving that marketing.

Third party marketing

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

Opting out

You can ask us to stop sending you news at any time by following the unsubscribe links on any message sent to you or by contacting us at support@careleadersnetwork.co.uk at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any other interaction you have had with us.

International transfers

Some of our external third parties are based outside of the UK in the USA and EEA, so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data outside of the UK, we ensure a similar degree of data protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Change of purpose

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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at support@careleadersnetwork.co.uk.

If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we protect your personal data

We protect your personal data and implement appropriate technical and organisational security measures to protect it against any unauthorised or unlawful processing and against any accidental loss, destruction, or damage.

Keeping your personal data

Your personal information will be retained for as long as necessary to enable your participation in the Care Leaders Network. We do not keep your personal data for any longer than necessary to fulfil the purpose for which we collected it, or to comply with any legal, regulatory or reporting obligations or to assert or defend against legal claims.

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.

If you choose to leave the Care Leaders Network, your personal information will be deleted from the CLN Hub. Please note that leaving the CLN Hub does not guarantee that we will not hold information about you elsewhere.

Your rights regarding your personal data

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 to another party.

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 support@careleadersnetwork.co.uk

Complaining about our use of your personal data

We respect your rights and want you to be comfortable with our use of your personal data. If you have a complaint or concern about how we use your personal data, we would like to work with you to resolve it. You can report a concern or ask us a question by contacting the CLN team.

Right to complain to the ICO

You have the right to complain to the Information Commissioner’s Office (the ICO) if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.