Personal Data is an increasing concern for individuals and it is understandable that service users are interested in how companies look after their data and privacy.

This privacy notice covers how Advo Health:

• Collect;
• Use;
• Disclose;
• Transfer; and,
• Store your data.

Scope

This Privacy Notice applies to anyone whose data we process, including visitors to our website. For the avoidance of doubt, this Privacy Notice does not apply to:

• Our employees and prospective employees (handling of their Personal Data is governed by our employee and recruitment privacy notices);
• Services we provide to others (e.g. our partner or client organisations) as a data processor of Personal Data which will be governed by a written agreement with the third party data controller. For example, Independent Assessment Services (IAS) may contract us to perform a Personal Independent Payment assessment on you. While we will of course process your data in accordance with our usual high standards in security, technology and data protection by design and by default in such circumstances, our partners or clients will be the controller of your data and so you should refer to their privacy notices for details of how your data is processed. We are not responsible for the privacy or data security practices of our clients or partners, which may differ from those explained in this notice.

We may change this Privacy Notice from time to time, so please check back regularly to keep informed of any updates. This version of the Privacy Notice was updated on 01/10/2022.

About us

Firstly, some information about us;

Advo Health is the trading name of Ascenti Physio Limited (Company Number 04530716) & Ascenti Health Limited (Company Number 03225768), who are members of the Ascenti Group.

In this Privacy Notice, the terms “we”, “us”, and “our” (and other similar terms) refer to Advo Health and no other part of the Ascenti Group. The Ascenti Group Privacy Notice can be found here: https://www.ascenti.co.uk/privacy

Advo Health recruitment also goes through the Ascenti Group, for which the Privacy Notice can be found here: https://www.ascenti.co.uk/recruitment-privacy-statement

Our registered office is Carnac House, Cams Hall Estate, Fareham, Hampshire, PO16 8UZ.

Your Data Protection Officer

Data Protection Officer: The DPO Centre Limited

Privacy queries: dpo@ascenti.co.uk

Our commitment to you

Advo Health is committed to protecting and respecting your privacy. Any decision we make regarding data will have considered the 6 principles for processing personal data contained in Data Protection Legislation.

Data Protection Legislation means the Data Protection Act 2018 (DPA 2018), United Kingdom General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with the aforementioned legislation. Where data is processed by a controller or processor established in the European Union or comprises the data of people in the European Union, it also includes the EU General Data Protection Regulation (EU GDPR). This includes any replacement legislation coming into effect from time to time.

The Information Commissioner’s Office (ICO) is the UK supervisory authority for data protection issues. More information regarding processing principles, as well as information on our additional data protection obligations, can be found on the ICO website.

Information we may hold on you

Personal Data means any information about you from which you can be identified. The data we collect depends on the nature of the services we are providing but can include:

• Basic details such as name, address and contact details;
• Information surrounding complaints and incidents which may have arisen;
• Details of visits to our website (including your IP address, login information, and other analytical information). Please refer to the Ascenti Group Cookie Policy for more details; and,
• Any other Personal Data we collect in the course of your interactions with us or in the course of operating our business.

Collect

• Your data may be collected:
• By telephone;
• By correspondence (including post, text, email or otherwise);
• Via our website or online portals (e.g. when submitting an enquiry on our contact form); or
• From your employer.

Use

In general we use your data to provide our services to you, including the following specific purposes:

• Responding to your initial queries and requests for further information about Advo Health, including quotes;
• Sending you your service related information;
• Record keeping and administration purposes;
• Compilation of statistical data (Personal Data will not be published or passed on without consent);
• To allow the billing of services provided and to obtain payment;
• To process and respond to any complaints, concerns or incidents;
• To comply with any other legal, professional or regulatory obligations imposed on us; and,
• To audit our services and the use of our websites.

We will not use your data for automated decision making.

We rely on the following legal reasons for processing your Personal Data:

• Legal obligation: We will process your Personal Data when it is necessary to comply with a legal or regulatory obligation (e.g. record keeping, external auditing)
• Legitimate interests: We will process your Personal Data when we, or a third party, have a legitimate interest in processing it (e.g. responding to complaints, ensuring our business policies are adhered to, or improving our business by monitoring and recording information relating to our services). We only process for this reason if the legitimate interest is not overridden by your own interests or fundamental rights or freedoms. Please contact us if you would like more information on our, or a third party’s, legitimate interests and the balancing test we use to ensure processing is lawful.
• Consent: Where we require consent to process your Personal Data will specifically request this from you (verbally or in writing) and provide information on the purpose of that processing. If you have given consent, you can change your mind at any time and withdraw it by contacting us.

Advo Health will not intentionally process ‘special category data’ in its role as a controller.

We will only use your Personal Data for the purpose, or purposes, for which we have obtained it. If we reasonably consider that we need to use it for another reason we will only do so if that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will inform you and explain the legal basis which allows us to do so.

We may process your data without your knowledge or consent where this is required by law.

Please contact us if you would like further information on the exact lawful basis for any specific data processing activity.

Disclose

We will share your data with carefully selected third parties when:

• You specifically request it, or a disclosure is required in order for us to provide our services;
• We are under a legal or regulatory duty to disclose your information; or,
• As a result of any changes in business ownership or organisation.

Advo Health may share your personal information, where required and to the extent permitted and on which we have a lawful basis, with:

• Any member of our group
• Solicitors, Insurers, or any other instructing party;
• Our auditors, including external accreditation bodies;
• Law enforcement agencies and regulators (e.g. CQC);
• Public bodies;
• Our external trusted service suppliers who provide business support services (including IT, security, building maintenance, hosting, archiving, data storage, email and text services and surveys);
• Analytics and search engine providers who assist in improving our website; and,
• Any other third party you may ask us to share your data with.

Where our professional duties of confidence as medical clinicians require that we seek your consent before sharing your Personal Data with a third party, we will do so. Such consent has a different legal basis to consent for the purposes of EU/UK privacy law and seeking consent further to our professional duties will not therefore affect the basis of processing in privacy law. The processing under privacy EU/UK privacy law will be on the bases as set out above.

Transfer

Advo Health will not typically transfer any of your data outside of the UK or EEA.

If we do have occasions to transfer your data outside of the UK or EEA to countries not deemed by the ICO (and/or European Commission as relevant) to provide an adequate level of personal information protection, the transfer will be based on safeguards that allow us to conduct the transfer in accordance with the data protection legislation, such as the specific contracts approved by the ICO (or European Commission as relevant) providing adequate protection of personal information.

Store

Advo Health has in place physical, electronic and operational procedures intended to safeguard and secure the information we collect.

These measures are updated as necessary and audited on a regular basis. All the data we process is done so by our staff in the UK and kept on UK only servers.

How long we retain your data for will vary from matter to matter but will be determined in accordance will the following criteria:

• Any time limits for establishing or defending legal claims or responding to complaints/incidents;
• Any period necessary to comply with our legal obligations under EU/UK law; and,
• Any periods for retention that is recommended by regulators or professional bodies.

Your rights

You have the right to obtain confirmation from us as to whether we are processing your Personal Data and, if we are, to request a copy of the Personal Data we hold about you. This is known as a ‘subject access request’.

If your subject access request relates to your Personal Independence Payment Assessment, as Independent Assessment Services are the Data Controller for this information, please direct your subject access request to them. You can find more information at their website: https://www.mypipassessment.co.uk/. If you wish to make a subject access request for other information Advo Health holds about you, please submit your request to SAR@Ascenti.co.uk.

For all other types of data subject rights requests (below), please email dpo@ascenti.co.uk

You also have the right to ask that we update any information we hold about you that may be incorrect. It is important that the information we hold about you is accurate and up to date. If any of your personal information changes please let us know.

In certain circumstances, you have the right to request that we restrict the way in which we process your data, or that we erase all personal information that we hold about you.

You have the right to object to certain types of processing.

We will try our best to comply with any request to restrict, object or erase your data, however processing of some data may still be required for legitimate business purposes or to comply with legal obligations. Please note that if you want us to restrict or stop processing your data this may prevent us from providing our services to you.

You have the right to request that we send a copy of your data, that you have provided to us, to another organisation for your own purposes (e.g. if you wish to change service provider). This data must be provided in a structured and usable format. This right only applies to Personal Data processed by way of consent or in pursuant to our contract with you. If you wish us to transfer your Personal Data in accordance with this right please let us know.

You will not have to pay a fee to access your Personal Data or to exercise any of your other rights. However, we may charge a reasonable fee should your request be clearly unfounded, repetitive or excessive. In order to prevent unauthorised access to information we may ask for proof of identity. We will do our best to respond to your request within one month, however, if that is not possible due to the repetitive nature or complexity of requests, we will notify you and keep you updated.

For further information on your rights, please visit the ICO website.

Concerns

If you wish to raise a query on how we have handled your Personal Data you can contact our Data Protection Officer using the details above.

You have the right to raise a concern at any time to the ICO. However, we hope that you would consider raising any concern you have with us first. Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have. For more information on submitting a concern to the ICO, or the data protection regime in general, please visit the ICO’s website.