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Privacy Policy

  • ICO Registration Number: Z7105141
  • Registered Address: 20 Gracechurch Street, London, EC3V 0BG.

"PPP Taking Care" Services comprise of telecare products and monitoring, and support services.

PPP Taking Care Limited ("PPP Taking Care”, ”Taking Care”, “us”, “our” and “we”) is part of the AXA Group of companies. We take your privacy very seriously. We promise to take steps to protect it. The information below tells you how we collect, store and use personal data about you. Please read it carefully. Any personal information you supply to PPP Taking Care will be treated in accordance with the Data Protection Act 2018 and other legislation intended to protect your personal information and privacy.

This privacy policy tells you what information we collect and what we can do with it.

  1. Who we are
  2. What information we collect and how do we use it
  3. Privacy Principles, Lawful Basis & Data Subject Rights
  4. Sharing Personal Information
  5. Processing outside the UK and the European Economic Area
  6. Data Retention
  7. Recording telephone calls
  8. What happens if you don't give us some of your information?
  9. Marketing & Live Chat
  10. Complaints

 

1. Who "we", “PPP Taking Care Customer”, “PPP Taking Care User”, and “participants” are

a) “We”

    We are PPP Taking Care Limited ("PPP Taking Care" "we", "us" or "our"), part of the AXA Group of companies.

    b) “PPP Taking Care Customer”

    Who has paid for the service and therefore who is assuming responsibility under the contract. The customer would typically be a next of kin and any information exchanged will be subject to the duty of confidentiality.

    c) “PPP Taking Care User”

    The end user of our social care products and services.

    d) "Participants"

    PPP Taking Care Customers and or PPP Taking Care Users who have provided us with information about themselves.

     

    2. What information we collect about Taking Care Customers and/or Taking Care Users and/or their representatives (collectively the "Participants")

    (a) Information collected from anyone using any of the PPP Taking Care Services (“Taking Care Customers”) and/or any beneficiaries of PPP Taking Care Services (“Taking Care Users”) and/or their, representatives.

    The personal information PPP Taking Care collects in connection with the PPP Taking Care Services includes:

    1. Information about PPP Taking Care Customers (e.g. next of kin) such as their name, email address, home address, telephone number, date of birth, bank/credit card details.
    2. Information about PPP Taking Care Users such as their name, home address, email address, telephone number, date of birth and details about their physical and/or mental health condition(s). (we may collect information about a PPP Taking Care User from a PPP Taking Care Customer).
    3. Information collated as part of a Safe Home Assessment.

    Personal information is collected by PPP Taking Care in relation to PPP Taking Care Services when Taking Care Users provide such details to us either via an enquiry into, or through their use of, any of the PPP Taking Care Services.

    Where we have appropriate legitimate business needs to use your personal information such as maintaining our business records, developing, and improving our products and services, all whilst ensuring that such business need does not interfere with your rights and freedoms and does not cause you any unnecessary harm.

    When required, we anonymise personal information so that individuals cannot be identified before we use it for management information and analysis of our products and services. Analysis of anonymous information provides us with insights about our business, and with opportunities to improve our products and services and the health and wellbeing of the people who use them. Analysis of anonymous information also allows us to demonstrate the value of the services we provide to our clients. The way that we anonymise personal information aligns with regulatory guidance and is achieved using different techniques, for example removing identifying data or overwriting it with randomised non-identifiable data. Anonymisation still constitutes use of your personal information and so to do so lawfully, we rely on the legal ground that was used when your data was originally collected. 

    (b) Information collected from others

    We can collect information about PPP Taking Care Customers and the Taking Care Users from others. This includes:

    1. We may collect information about a PPP Taking Care User from a PPP Taking Care Customer (e.g., the next of kin).
    2. Information about PPP Taking Care Users from the individual assigned to conduct a Safe Home Assessment or Wellbeing Check ("Taking Care Assessors") for us to manage the PPP Taking Care Services and to help us select and manage the Taking Care Assessors properly.

    (c) Sensitive personal data

    We may process sensitive information about PPP Taking Care Users that falls under the definition of "special categories of personal data". This includes data concerning a PPP Taking Care User's physical and mental health, data revealing their racial or ethnic origin and/or religious beliefs. We may obtain this from the following people:

    1. PPP Taking Care Users may directly provide us with sensitive information about themselves
    2. PPP Taking Care Customers (e.g. next of kin) may provide us with sensitive information about the relevant PPP Taking Care User
    3. PPP Taking Care Assessors will take notes and keep records of their home visits to the Taking Care User as part of the Safe Home Assessment and share this information with PPP Taking Care.
    4. PPP Taking Care Assessors will take notes and keep records of their calls with the Taking Care User as part of the Wellbeing Check and share this information with PPP Taking Care and the corresponding Taking Care Customer
    5. PPP Taking Care securely manages your data applies additional security measures including by not limited to encryption, access control passwords to special category data. 

    (d) People who use our website, mobile apps, and other means

    When people visit our website, mobile apps, and other means, personal data is collected both through automated tracking and interactions with various forms on the website or apps (collectively referred to as the websites).

    Personal data may also be collected when individuals contact us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our websites, subscribes to our services, makes an enquiry, comments on publications, enters a competition, promotion, or survey, applies to work for a PPP Taking Care business or reports a problem with our websites.

    When individuals visit our websites, certain personal data may be automatically collected.

    We work closely with third parties who may collect data on our behalf (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, aggregators and data brokers).

    Often, individuals who visit our website additionally fall into another category as listed by this privacy policy. For instance, users of our websites may be current clients, business contacts or become clients in the future. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose.

     

    Why do we process data?

    There are several reasons why we will process the personal data that an individual may provide to us when visiting our websites. For examples, these include:

    1. Administration – to administer our website and to improve internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. For example, we use this data to ensure that the website is presented well for individuals and is optimised appropriately;
    2. Functionality – in order to allow individuals to use some functionality of our website, certain personal data must be entered in order for features to work as intended;
    3. Security – in order to keep our website safe and secure, we may sometimes collect personal data, for instance login information and other data that can be used to vouch an individual’s identity;
    4. Promotion and development of our offerings – some personal data may be used in order to measure or understand the effectiveness of advertising we serve to individuals, and to ensure that only relevant advertising appears.

     

    What data do we hold?

    The data that we hold depends on what data was entered and for what purpose.

    Where data was entered in order to engage with functionality of our website, that personal data may include names, addresses, e-mail addresses and phone numbers, financial and credit card information, personal description, and photographs.

    Where data is collected automatically, including technical information, such as IP addresses used to connect an individual’s computer to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.

    We may also collect other data about an individual’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

    Our website uses cookies to distinguish individuals from one another. This helps us to provide a better experience when individuals browse our website and, also allows us to improve our site. For detailed information on the cookies, we use and the purposes for which we use them see our Cookie policy.

     

    (e) Third Party Websites

    Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

     

    How we use your Information

    We use the information from the PPP Taking Cares User and the PPP Taking Care Customers to provide our services. This can either be done through a contract or social care, or a combination of both:

    A. Provide PPP Taking Care Services

    When a PPP Taking Care, Customer asks about or requests us to provide a PPP Taking Care Service, we use information about the Taking Care Customer and/or Taking Care User:

    1. To contact the PPP Taking Care Customer about the PPP Taking Care Service (e.g., for verification or billing purposes)
    2. To provide the agreed PPP Taking Care Service on the PPP Taking Care Customer's request (e.g., for a Safe Home Assessment, to send a PPP Taking Care Assessor to conduct an assessment at the PPP Taking Care User's home and making appropriate recommendations, to enable the Wellbeing Check call to take place). 

    B. Legal basis to process sensitive information

    It is important that we identify an appropriate legal basis to process sensitive information. This is particularly relevant when dealing with medical information. This will apply across all our activities and can be summarised as follows:

    1. The principal basis for processing special category data under the UK Data Protection Act is the performance of a contract with you or to which you are a party.
    2. In the event of an emergency, we will process and potentially share your information (emergency services) under the lawful principle of vital interest

    C. Do what we are required to do by law

    Because we are part of the AXA Health, which provides health insurance services, sometimes we are required by law to use information about you:

    1. To assist regulators where we have a legal duty to do so; and
    2. To help prevent and detect crime.

    D. Prevent fraud

    Fraud has an impact on all Customers as it increases costs for everyone. We use Participants' data to check for signs that Participants or others might be dishonest. (e.g., if someone has behaved dishonestly in the past it may increase the risk they will do so in future). 

    E. Recover debt

    If a PPP Taking Care Customer owes us money, we will use PPP Taking Care Customer information to help us recover it. 

    F. Using your Information for Management Purposes

    Where we have appropriate legitimate business need to use your personal information, such as maintaining our business records, developing, and improving our products and services, all whilst ensuring that such business need does not interfere with your rights and freedoms and does not cause you any harm.

    We will also use Participant information, under the principle of legitimate interest, to ask Participants to provide feedback on the PPP Taking Care Services we provide and to help us understand our business and monitor our performance. We may provide reports that contain aggregated data to a level which means you cannot be identified.

    We may use your personal information collected from customer satisfaction surveys and where possible, we will anonymise such information. However, sometimes we may need to use your personal information. Where necessary, we will obtain your consent as our legal ground to process your personal information under data protection rules.

     

    3. Privacy Principles, Lawful Basis and Data Subject Rights

    When we collect and use your personal information, we ensure we look after it properly and use it in accordance with our privacy principles set out below, keep it safe and will never sell it.

    1. Personal information you provide is processed fairly, lawfully and in a transparent manner
    2. Personal information you provide is collected for a specific purpose and is not processed in a way which is incompatible with the purpose for which we collected it
    3. Your personal information is adequate, relevant, and limited to what is necessary in relation to the purposes we collected it
    4. Your personal information is kept accurate and, where necessary kept up to date
    5. Your personal information is kept no longer than is necessary for the purposes for which the personal information is processed 
    6. We will take appropriate steps to keep your personal information secure
    7. Your personal information is processed in accordance with your rights
    8. We will only transfer your personal information to another country or an international organisation outside the United Kingdom or outside the European Economic Area when we have taken the required steps to ensure that your personal information is protected. Such steps may include placing the party we are transferring information to under contractual obligations to protect it to adequate standards
    9. Taking Care do not sell your personal information and we also prohibit the selling of customer data by any company which provides a service to us

    Lawful Basis:

    The lawful bases for processing are set out in Article 6 of the UK GDPR. At least one of these must apply whenever personal data is to be processed:

    1. Consent: you have given PPP Taking Care your freely, specific, informed or unambiguous consent for your personal data to be processed for a specific purpose;
    2. Contract performance: the processing is necessary for the performance of a contract you have with PPP Taking Care, which had asked you to take specific steps before entering into a contract;
    3. Compliance with legal obligation: the processing is necessary for PPP Taking Care to comply with the law for the tax, social security obligations and employment law purpose (not including contractual obligations);
    4. Protection of vital interests: the processing is vital to an individual’s survival.
    5. Public interest: the processing is necessary for PPP Taking Care to perform a task that is in the public interest or for its official functions, and the task or function has a clear basis in law; or
    6. Legitimate interests: the processing is necessary for PPP Taking Care ’s legitimate interests, or the legitimate interests of a third-party unless there is a good reason to protect the individual’s personal data that overrides those legitimate interests.

    Your data subject rights are listed below:

    1. The right of access;
    2. The right to rectification;
    3. The right to erasure or right to be forgotten;
    4. The right to restriction of processing;
    5. The right to be informed;
    6. The right to data portability;
    7. The right to object; and
    8. The right not to be subject to a decision based solely on automated processing.

     

    4. Sharing Personal Data

    We may disclose your personal data to third parties when we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements, or to protect the rights, property, or safety of the organisation, or other individuals. We may also share your personal data with third parties when we are legally permitted to do so. Before engaging with third parties, we conduct vendor risk assessments and regulation tests to verify the compliance level of those third parties. When we decide to share your data with those third parties, we put contractual arrangements and security mechanisms in place to protect your data in order to maintain compliance with our data protection, confidentiality, and security standards. 

    Age UK Personal Alarms

    PPP Taking Care has entered into a commercial contract with Age UK (registered charity, no. 1128267) to provide Personal Alarms services. 

    Chichester Careline provided by PPP Taking Care

    Chichester Careline is a PPP Taking Care brand which provides telecare by a 24-hour staffed Alarm Receiving Centre (ARC). Chichester Careline is provided by PPP Taking Care.

     

    5. Processing outside the UK and the European Economic Area

    Some recipients may be in countries outside the UK and the EEA notably in (i). Where we make a transfer of your personal information outside the UK and the EEA, we will take steps to ensure that it is protected. Such steps may include placing the party we are transferring personal information to under contractual obligations to protect it to adequate standards. 

     

    6. Data Retention

    We have comprehensive record retention schedules. The retention periods differ depending on the purpose of the processing and the nature of the information. How long we keep data is primarily determined by the period we need to keep it to protect ourselves or others against legal action and how long we need it for the purposes we told you we were going to use it for. We typically keep information for approximately 7 years either from the point we obtained the information or the end of our relationship with you. In some cases, such as if there is a dispute or legal action, we may keep it longer.

     

    7. Recording telephone calls

    Participants should be aware that any telephone calls with PPP Taking Care for the provision of PPP Taking Care Services may be recorded for quality monitoring and training purposes, as evidence of our conversation and to assist us in preventing and detecting fraud.

     

    8. What happens if you don't give us some of your information?

    Where a Participant does not provide the information, we need in order to provide the requested PPP Taking Care Service or to fulfil a legal requirement, we will not be able to provide the PPP Taking Care Service requested.

     

    9. Marketing & Live Chat

    We are committed to only sending you marketing communications that you have clearly expressed an interest in receiving.

    When submitting your contact information, including email, postal address, and phone number, you affirm consent for PPP Taking Care to contact you for marketing purposes.

    If you wish to unsubscribe from emails sent by us, you may do so at any time by following the unsubscribe instructions that appear in all emails with a hyperlink to PPP Taking Care Email Preference Centre. Alternatively, you can always contact us by

     Please note that we may retain any data provided to us on our websites for a limited period, even if you do not complete your quote. The information may be used to enquire as to why you did not complete your quote or for us to better understand your needs but only if you have agreed for us to contact you.

    Business to business marketing, that is commercial marketing may rely on legitimate business purposes when contacting the organisation rather than marketing choices made by an individual.

     

    Live Chat

    Taking Care offers a chat platform called LiveAgent, via this website, which connects the customer with Taking Care’s support team. To begin the ‘chat’ the customer is taken through a verification process (a combination of name, email, and phone number) and asked for consent to process his/her personal data for the strict purpose of resolving customer enquiries.  The personal data shared is processed in accordance with our retention schedule and statutory legislation, including the Data Protection Act 2018. The messages and data exchanged are stored within chat applications, which are in data centres in the EEA.

    PPP Taking Care’s ‘Falls Risk Score’ Bot is supported by Quirobot, a third-party processor, with all personal data being retained in the EEA and use of data restricted to technical support of the Bot.

     

    10. Complaints

    The Data Protection Office can be contacted at: dataprotection@ppptakingcare.co.uk

    Address: The Data Protection Officer, PPP Taking Care Limited, Linhay House, Linhay Business Park, Eastern Road, Ashburton TQ13 7UP

    Participants have the right to complain about how we treat their personal data to the Information Commissioners Office (the "ICO"). The ICO can be contacted at:

    Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

    Telephone: 0303 123 1113 (local rate) or 01625 545 745

    Email: https://ico.org.uk/global/contact-us/email/                          

     

    Last updated 26/05/22