Privacy Notice

​INTRODUCTION

• Welcome to Quality Trusted Solutions privacy notice.

• Quality Trusted Solutions (“QTS”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. We ask that you read this privacy policy carefully as it contains important information about what to expect when QTS collects personal information about you and how QTS will use your personal data.

• QTS is a wholly-owned subsidiary of Central and North West London NHS Foundation Trust (“CNWL”).

• Please use the Glossary at the end to understand the meaning of some of the terms used in this privacy notice. This policy applies to information we collect about:

  • patients, service users, staff and key personnel of CNWL for the purposes of delivering estates and facilities management services;

  • patients, service users, staff and key personnel of other customers we engage with to provide management of estates and facilities services;

  • those individuals contracted to CNWL and/or our customers;

  • visitors to our website; and

  • those who enquire about our services.

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PURPOSE OF THIS PRIVACY NOTICE

• This privacy notice aims to give you information on how QTS collects and processes your personal data when you enquire about our services or from your use of our website.

• This privacy notice is not intended for children and we do not knowingly collect data relating to children when processing personal data of our customers. However, there may be limited circumstances where we inadvertently collect data about children who use our services. Where this happens, such personal data will usually only be a first and last name and no other contact information will be processed about them.

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WHO WE ARE

• This privacy notice is issued on behalf of the QTS (see below) so when we mention "we", "us" or "our" in this privacy notice, we are referring to QTS.

• QTS is a data controller in respect of data collected in running its business and is responsible for your personal data.

• Where we engage with customers and CNWL, we act as a data processor.

• If you have any questions about this privacy policy or our privacy practices, please make contact in the following ways:

  • Full name of legal entity: QTS LLP (CRN: OC419167)

  • Email address: cnwl.qts.enquiries@nhs.net

  • Postal address: 350 Euston Road, Regent’s Place, London, NW1 3AX

  • Telephone number: 0203 2145950

• You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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THE DATA WE COLLECT ABOUT YOU

• Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

• When you visit our website, enquire about our services, or in performance of our contract with customers we may collect, use, store and transfer the different kinds of personal data about you. Personal data collected include those in all formats (paper copy, digital, CCTV etc.).

• The different kinds of data we may process are as follows:

  • Identity Data includes first name, last name, marital status, date of birth and gender.

  • Contact Data includes business and home address, email address and telephone numbers, including mobile numbers (including additional emergency contact numbers).

  • Employment Data includes information to conduct workforce analyses including working hours, job title and staff number.

  • Health Data includes data relating to patients mental or physical health conditions.

  • Verification and Background Data includes passport, driving licence, and criminal offence data in limited circumstances.

  • Finance Data includes information relating to salary.

  • Technical Data includes 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 our website or email communication from us.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

• We gather this information to allow us to perform our obligations under contract with our customers by providing our services. As part of our services we will use this information to communicate with you where required (for example if you are a key contact).

• 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.

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SPECIAL CATEGORIES OF PERSONAL DATA

• We may, in the normal course of our business activity, collect Special Category Data about you (this includes sensitive information 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).

• In limited circumstances, we may also collect information about criminal convictions and offences (“criminal offence data”) where this is required in the performance of a contract, in compliance with our legal obligations or where this is otherwise necessary.

• Where we process Special Category Data and criminal offence data about you, we will ensure that we have a lawful basis for doing so in compliance with our obligations under the Data Protection Legislation.

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WHY WE USE YOUR PERSONAL DATA

• We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

  • Where you have consented to the processing of the personal data for the purpose of providing the services.

• We will use your personal data to perform the following activities:

  • to register and respond to your enquiry on our website;

  • to carry out the service contract that we have entered into with our customers; or

  • to tell you about our services (unless you have asked us not to contact you).

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WHO WE MAY PROVIDE YOUR PERSONAL DATA TO

• We may share your personal information with our clients when performing our contract with them. We may also pass on your personal data to our suppliers and other third parties (acting as data processors or separate data controllers) who support our business to provide our services, although this information will only be that which they require to deliver their services to us or on our behalf.

• Such suppliers and other third parties would include, but is not limited to:

  • HM Revenue & Customs, regulators (including NHS England, NHS Improvement, NHS Digital and CQC) and other public authorities based in the UK who require reporting of processing activities in certain circumstances;

  • professional advisers including lawyers, bankers, auditors, pension providers and insurers who provide consultancy, banking, legal, pension, insurance and accounting services.

  • service providers acting as processors who provide website, IT and system administration services.

  • CNWL which provides some shared resources to support QTS’ business operations.

  • third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

• We require all third-party data processors to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

• Where we are required to transfer your personal data to other data controllers, such as regulators as set out earlier in this notice, we do so to perform the obligations under our contract with our customers. Details as to how these third party organisations process this personal data should be obtained directly from their privacy notices. Your right to object directly to any data controllers in relation to the processing of personal data remains intact.

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MARKETING

• We strive to provide our customers with choices regarding certain personal data uses, particularly around marketing and advertising.

• We may use our customer’s personal information to form a view on what we think they may want or need, or what may be of interest to them. This is how we decide which products, services and offers may be relevant for them. (we call this Marketing and Communications Data).

• You will receive marketing communications from us if you have requested information from us and/or previously engaged us to provide services and, in each case, you have not opted out of receiving that marketing.

• We won’t ever share your personal data with any company outside of QTS for marketing purposes.

• Opting out - you can ask us to stop sending you marketing messages by contacting us at any time by contacting us using the details contained in this privacy notice.

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COOKIES

• Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. The information is used to track visitor use of the website and to compile statistical reports on website activity. For further information about cookies visit www.aboutcookies.org or www.allaboutcookies.org.

• We do not currently operate any cookies on our website and we will update this policy if should this change.

 

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.

• 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.

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INTERNATIONAL TRANSFERS

• We do not transfer your personal data outside the UK.

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DATA 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, suppliers, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

• We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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DATA RETENTION

• We will only retain your personal data 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.

• Where we process personal data of our customers, we will either delete this information or return it to our customer on conclusion of our contract with them. We will only retain personal data for longer if we feel that this is in our legitimate interests or if required in compliance with our statutory or regulatory obligations.

• In some circumstances you can ask us to delete your data: see below for further information.

 

YOUR LEGAL RIGHTS

• Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of these rights, please contact us.

• 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.

• You have the legal right:

  • To request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • To request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • To request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • To object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms.

  • To request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain circumstances.

  • To request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

  • To withdraw consent at any time where we are relying on consent to process your personal data.

 

CONTACT US

• If you have any questions in relation to this privacy notice, please contact our Data Privacy Manager by email at CNWL.QTS.enquiries@nhs.net.

 

This Privacy Notice was last updated on 28 September 2023.