- www.adlsmartcare.com – information on ADL Smartcare services
- Citizen Access Websites – Self-Help sites for Healthy Ageing
- Staff Access Website
- LifeCurve™ Mobile App
- ADL Passport Website – Single Sign on Service to ADL Smartcare services
- Version 2.5 - 1st March 2020 (Latest)
- Version 2 - 1st February 2020
- Version 1 - 25th May 2018
1. Data Protection Officer Contact Information
The Data Protection Officer can be contacted at firstname.lastname@example.org or
Sheffield Digital Campus,
3 Concourse Way,
ADL Smartcare is the Data Controller.
2. No Advertising or Marketing
ADL Smartcare does not have any third-party advertising within the service and we do not send marketing emails or share your information to third parties for marketing purposes.
3. Personal data collected
Analytics and Navigation data
IP address, the website you came from, the device you are using, whether you return to the site and how the site performs for you such as load time.
To register for the service, we need your first name, last name, email address, postcode. You can also share other personal information such as address details and data of birth by entering this in the Account area.
Your current ageing position on the LifeCurve, based on research from Newcastle University and ADL Smartcare Research into the order of Instrumental Activities of Daily Living, such as the ability to cut your toe nails.
Personal capability and environmental questions regarding your home such as bathroom, kitchen, how easily you can bend your knees or hips and other questions relevant to finding solutions to your specific needs.
Tasks you save to complete at a later date such as reactivation exercises and activity relating to those activities such as completing or removing a task from your saved items.
Managing contacts and sending messages
Personal Data: address, company name, country, email address, first name, last name, phone number and Usage Data
4. Use of personal data
Analytics and Navigation data – Google Analytics, Google Tag Manager
Personal information – remains within ADL Smartcare’s ultra-secure infrastructure at all times
Uses navigation data and personal information to provide specific solutions to needs you indicate you have. Specific solutions are matched to your needs through automated decision support, which is clearly indicated within the service through a "matching" page.
You can request this decision to be reviewed by a real person through the options available when solutions are presented to you.
We do not perform profiling of individuals or use artificial intelligence and we never "hide" what we are doing with your data, which you provide with consent.
Interaction with external social networks and platforms
The ability to sign in with an account from Scotland’s myAccount enables the transfer of personal data between two Data Controllers with the consent of the individual. This is only true if you are using the service in North Lanarkshire. During the sign on process, the personal data shared is clearly communicated to you e.g. name and email address.
We currently do not allow Facebook, Twitter or other social media sign on.
Managing contacts and sending messages - Mail Chimp and Salesforce
When you register on the service, we may send you the occasional email to inform you of new content or improvements within the service to support Healthy Ageing.
We will not use your contact information to send you marketing emails.
5. Data Sharing
Data is collected when you perform a self-assessment through the website. This is collected in order to provide healthcare related guidance, and direct you to relevant information and services. It includes, your Instrumental Activities of Daily Living capabilities, your record of performing the recommended activities and any answers to questions to support the matching of solutions to your needs for a given area of interest such as struggling to get up and down from the bottom of the bath.
This service is provided to you by ADL Smartcare on behalf of East Lothian Health and Social Care Partnership. By using the service, you expressly give East Lothian Health and Social Care Partnership permission to access your data
We do not share personally identifiable information with any third party other than the partner organisation of ADL Smartcare and the service e.g. the Public Authority such as the Local Authority.
LifeCurve™ Partners – connecting to authorised partners from within the LifeCurve™ App
Subject to your consent and clear authority, you can request to connect with third party organisations to support your healthy ageing. From within the app you can browse or use a QR code to connect to a LifeCurve™ Partner. You can withdraw this consent at any time by opting to disconnect to them. The process has two steps:
- select the partner in the app
- click confirm to connect to the partner
For example: You could connect to a LifeCurve™ Partner who is a Local Authority to access local tasks to support you in your current position on the LifeCurve. They in turn can then see your LifeCurve™ position either anonymously or in an identifiable format within their secure website. They can use this information to further improve the content they can provide but also see how you are improving.
You are in control of your who you share your data with at all times. Within the LifeCurve™ App, you can always see the partners you are connected too and their LifeCurve™ Partner Privacy Policies. Please do contact us if you have any questions.
Analytics and Navigation data (not relevant to the LifeCurve™ App)
Navigation data is shared with Google Analytics to provide information on how you use the service. You can opt out of this by going to: https://tools.google.com/dlpage/gaoptout
Ethical Research into ageing
We and our current users, are proud to support research into improving ageing across the UK and internationally. You can join us by opting in be part of our global ageing research. Just tick the box to give your approval for your anonymised data to be collected and used as a part of this service supports and to develop and improve the service; promote healthy ageing; and to help people live happily for longer.
At no point are you identified as part of this research. The aims of the research are to improve services, ageing and products for us all to promote healthy ageing and happier lives for longer.
You can opt in during the registration process and once registered, you can opt in or out within the account area.
1. ADL Smartcare
ADL Smartcare Limited is a private company limited by shares incorporated in England and Wales. If you have a general enquiry you can contact ADL Smartcare via info@ADLSmartcare.com or by writing to ADL Smartcare, Electric Works, Sheffield Digital Campus, 3 Concourse Way, Sheffield, S1 2BJ, United Kingdom.
This Policy applies to our collection and use of your data in connection with our service and its modules such as the ADL Platform with the LifeCurve™.
2. Our Data Protection Officer
If you have any queries regarding us processing of your personal data, please contact our Data Protection Officer by email: email@example.com.
3. Changes to this Policy
4. Your Rights
ADL Smartcare recognises that your personal data belongs to you and we don’t wish to use it in ways that you don’t want us to.
You can exercise a number of rights regarding our use of your data from within the service:
- You can access a copy of the information we have on you, through the account area of the service. This is for yourself or any profiles you created for a friend/relative.
- You can correct any information we have on you through the account area of the service.
- You can access a copy of your name and address details in a common, machine-readable format such as Comma-Separated Values (CSV) to share with another supplier.
You can exercise a number of rights regarding your data by using the GDPR dedicated contact form found within the service or by contacting the Data Protection Officer.
- You can make a request for us to delete your data, however we may be prevented from doing this if it impacts our ability to defend a claim against the advice we provide or if it is detrimental to you or the public’s health.
- You may withdraw your consent for ADL Smartcare to collect and process data about you at any time.
- You can ask us to restrict the processing of your data.
Please note that some of these rights aren’t absolute - for example, we may not be able to forget you if we have to keep some of your data to comply with the law—but we’ll evaluate your request in accordance with applicable data protection laws.
ADL’s Data Protection Officer will respond to your request within one month of the date we receive it
Also, note that you are not satisfied with the way we are handling your data then you have the right to lodge a complaint with the UK Information Commissioner’s Office or the supervisory authority in your country of residence or place of work.
5. Information Collected, how information is used and the legal basis
In running and maintaining our Services we may collect and process the following data about you:
Navigation and Insight
- Information about your use of our site including details of your visits such as pages viewed and the resources that you access. Such information includes traffic data, location data and other communication data.
- We use technology to collect information indirectly - such as your IP address and mobile device identifier and how much time you spend on the site. This is commonplace across all internet services to enable the investigation of issues such as malicious use. This information is then kept in our internet access logs.
- We collect information directly from you in a number of ways. One way is by using cookies. Cookies are small data files that save and retrieve information about your visit to our website, such as how you entered our website, how you navigated through the website and what information was of interest to you. This information is collected for a number of reasons, for example, to help develop the website and associated services.
- Site features such as whether the show or hide the accessibility bar, acceptance to the Cookie question.
Navigation and Insight Legal Basis – Legitimate Interest
We use the data you provide and how you navigate and use our service in order to improve the website experience and develop a better self-help solution so you get to advice faster and inform our research and development; so we can better understand our users and how they are ageing. We also send you surveys about our Services, but completion of these are voluntary. The use of this data is required for our mutual interests are met by improving the tools and platform available, through better use of technology, user design and communications.
- ADL Smartcare collect your email address as a part of the registration process. The email address is tied to your user account and checks that you are a verified user. We use your email address to send you important updates about the service.
- We would never user your email address for marketing purposes or sharing with third parties other than with the Public Authority/ partner organisation you have signed up with.
Communication Legal Basis – Legitimate Interest
Sending You Emails: We will send users important notices about issues with the service such as any service availability or security concerns. ADL Smartcare has a legitimate interest in sending these emails to keep you informed as it may affect your experience of the service.
- Information provided voluntarily by you. For example, when you request information or register an account, we will collect your name, email address, postcode and password.
- Data is collected when you perform a self-assessment through the website. This is collected in order to provide healthcare related guidance, information and services. It includes, your Instrumental Activities of Daily Living capabilities, your record of performing the recommended activities and any answers to questions to support the matching of solutions to your needs for a given area of interest such as struggling to get up and down from the bottom of a bath.
- This service is provided to you by ADL Smartcare on behalf of East Lothian Health and Social Care Partnership. By using the service you expressly give East Lothian Health and Social Care Partnership permission to access your data
- We will never use your identifiable personal to support our ethical research into ageing and improving healthy ageing for others. However, subject to your approval we would like to use your anonymised data for this purpose. You can opt out at registration or change your approval by accessing your account within the service.
- Information that you provide when you communicate with us by any means such as a contact form or via email.
- Where we are responding to your specific instructions (either directly or through a third party), we will forward information to othersin order to fulfil your request. (We can assure you thatyou will NOT receive unsolicited information from commercial companies because of data we collect).
- In addition to your specific requests, there are times when providing access to some or all of your personal data to authorised users from other organisations such as the NHS, Social Services, GPs and the Voluntary Sector, will allow us/ them to provide you with a better service, and/or reduce or avoid duplication.
- Within the service we provide links to third parties. Where we provide a link, it does not mean that we endorse or approve that site’s policy towards visitor privacy. You should always review their policy before visiting the service or sending them any personal data.
Personal Information Legal Basis – Explicit Consent
When you register for the service, you provide consent for us to use your non-identifiable data for the purposes of ethical research into ageing and healthy ageing at our research centre based in Newcastle University. You can opt out at any time by accessing your account within the service and withdrawing your consent.
Personal Information Legal Basis – Legal Duty
Where we provide the service for a Public Authority, ADL Smartcare has a legal duty to comply with their rights as a Health and Social Care service are followed. For example, they may need to share your data with other public bodies in the interests of public health. Additionally ADL will need to retain data to protect them from any future legal challenge regarding the advice provided
We employ safeguards, such a formal data governance programme and robust security measures, to protect your data and your privacy.
6. If You Don't Want Us to Have Your Data
You are not required to provide personal data to us however, your failure to do so may affect our ability to provide some of the services you request. For example, we are unable to save an assessment if you do not open an ADL Smartcare account.
7. Marketing and Advertising
There is no advertising within the service.
We do show retailers or suppliers of services and products so that you can source solutions matched to your needs. We do not get paid to show these suppliers. Amazon do pay us a small affiliate fee if a product is purchased through them.
We do not send marketing emails or allow third party to send marketing emails.
8. Automated Decision Making (not relevant to the LifeCurve™ App, www.adlsmartcare.com or ADL Passport Website)
ADL Smartcare uses your answers to the questions within the service, to match solutions including advice, information and equipment to your personal capability and environment, that will help you with your independence and healthy ageing.
The matching process takes place through an automated decision-making process, which is visible to you at all times and can be challenged if required by a real person following the outcome of the matching.
The matching is based on 17 years of independent professional advice, so the outcomes follow best practice across the UK.
ADL Smartcare does not use artificial intelligence, profiling or hidden automated decision making which the user is not aware of.
9. How we May Share Your Data
We use the following service providers in the administration and delivery of the service:
|Data Controller||Data Processor||Reason||Data|
|ADL Smartcare Limited||Infrastructure Provider||Dedicated ultra-secure infrastructure for providing the software as a service.||Data centre for the service where personally identifiable data is stored securely.|
|ADL Smartcare Limited||Google Analytics||Website performance and usage information||IP address and usage of the service|
|ADL Smartcare Limited||Post Code Lookup service||Provide address and Local authority of a given psotcode - used for registration of an account holder and any associated profiles.||Post code only (the user is not identified and the third-party service does not store information)|
We also may disclose your information if required by law, requested by law enforcement authorities or to enforce our legal rights. We may share your information in connection with a sale or reorganisation of ADL Smartcare, but in any such case, the terms of this Policy will continue to apply.
10. Where Are We Sending Your Data?
The service is hosted on dedicated, segregated infrastructure within a former nuclear bunker in Kent, UK (within the EU). Your identifiable information does not leave this secure location.
11. How Long Do We Keep Your Data?
We keep your personal data in an identifiable form for as long as we have a legitimate reason to use the data and as required by law.
12. Privacy by Design
We have built a Privacy Impact Assessment process into the organisation’s project management and idea creation framework. Any project which is being proposed will have a PIA completed so that its privacy is reviewed.
13. Visitors accessing our www.adlsmartcare.com website
If you work for a company that has a business relationship with ADL Smartcare, we use your data in slightly different ways than for individual users of the services.
We collect a business user’s name, work email address, office number and fax number. We use this data to enable you to sign into your business’ account and to access your reporting information. In addition, we may use your data to perform business services you request.
Finally, we will send you the following email communications: operational emails, customer service emails and business marketing emails. When you receive one of these emails, you can opt out of receiving emails from us, other than service emails related to your requests.
ADL Smartcare assumes that we are undertaking B2B marketing (sending emails to members of another organisation).
If you are a sole trader or individual from outside of an organisation, ADL Smartcare requires your consent to contact you.
Under PECR B2B guidelines (https://ico.org.uk/for-organisations/guide-to-pecr/what-are-pecr/), ADL Smartcare will provide an opt out or unsubscribe button on every email.
Legal Basis – legitimate interests
ADL Smartcare uses the principle of legitimate interests as a basis for processing and holding your data as we have gathered your information through interaction with your business and assume that you want to hear from us. We communicate with you via email marketing as we believe there is not a less intrusive and timely way to convey the same information.
ADL Smartcare assumes we are sending you communications in a way that you would reasonably expect and that we are not causing you unjustified harm.
Further information and help
If you have any questions then please review the privacy help area with in the service or contact the Data Protection Officer on firstname.lastname@example.org