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Cornwall Mobility
North Buildings
Royal Cornwall Hospital
Truro
Cornwall
TR1 3LQ

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Privacy policy

Purpose of this privacy policy

Cornwall Mobility Centre Limited fully respects the privacy of every individual who visits our website www.cornwallmobility.co.uk.

This privacy statement provides information on our data collection practices and of the ways in which the information may be used. For the purpose of the Data Protection Act 2018 (DPA 2018), the data controller is Cornwall Mobility Centre Limited of Mobility Centre, North Buildings, Royal Cornwall Hospital, Treliske, Truro, Cornwall, TR1 3LJ whose data protection registration number is Z8027896.

This privacy policy will provide you with information about how we look after your personal data and tell you about your privacy rights and how the law protects you.

This privacy policy aims to give you information about how “Cornwall Mobility” collects and processes your personal data, including any data you may provide to us or may be provided by third parties when you have been referred for an assessment.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware about how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
When we refer to an assessment in this document we mean;

• the assessment of your fitness to drive a vehicle (including car, scooter, power wheelchair, manual wheelchair)
• assessments for hoists, passenger access or vehicle adaptations

including recommendations we make to you and third parties that may have referred you to us.

Controller

Cornwall Mobility Centre Limited registered at Companies House with company number 04713856 registered address Mobility Centre Tehidy House, Royal Cornwall Hospital, Treliske, Truro, Cornwall, TR1 3LJ is the controller and responsible for your personal data (collectively referred to as “Cornwall Mobility”, "we", "us" or "our" in this privacy policy)

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy please contact the data privacy manager using the details set out below.

Email address: [email protected]

Postal address: Data Privacy Manager, Cornwall Mobility Centre, Tehidy House, Royal Cornwall Hospital, Treliske, Truro, Cornwall, TR1 3LJ

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.

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 on 6th September 2019. Historic versions can be obtained by contacting us.

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.

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).

We may collect, use, store and transfer different kinds of personal data about you

  • your name
  • your contact details (including postal address, telephone number and e-mail address)
  • your date of birth
  • your gender
  • a record of your contact with us (including details of any phone calls or emails)
  • information set out in your driving licence
  • information held by the DVLA in relation to your entitlement to drive a vehicle
  • Special Category Data concerning physical or mental health, any medical condition or disability that you may have and how it affects you
  • criminal convictions (including past convictions) and allegations of criminal offences relevant to your entitlement to drive a vehicle
  • any information obtained from you or third parties for the purpose of carrying out assessments, including information contained in prior assessments whether carried out by us or another assessment centre
  • correspondence about you we have with the DVLA, the Police or other authorities.

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your assessment outcome to assess the performance of our service. 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 collect Special Categories of Personal Data about you (details about your health, including disability) where that is necessary for us to carry out an assessment.

We collect information about criminal convictions and offences, for example if you have been referred to us by the Police or DVLA for an assessment we may be told by them about the circumstances which lead to that referral.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to provide an assessment. In this case, we may have to cancel the assessment but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you request an assessment with us, attend an assessment centre or contact us to follow up the outcome of an assessment.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    • DVLA
    • Medical practitioners
    • Family members, friends or a guardian where they attend the assessment with you
    • Motability
    • The Police where you have been referred to us for an assessment by them

How 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 with you, usually to provide you with an assessment
  • 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 obligation
  • Consent where it is necessary for us to process Special Category Data and personal data relating to criminal convictions and criminal offences

Lawful basis we rely on when we use your personal data

We have set out below a description of the legal basis we rely upon to process personal data.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

  • Legitimate Interest means our interest in conducting and managing our business to enable us to give you great service and the best and most secure experience. We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. When we rely on a legitimate interest we do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. This is usually the information we need to provide an assessment and the information including payment.
  • Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. We rely on this when communicating with the DVLA and Police.
  • Consent. Save in certain circumstances (which are outlined below), we will only process your Special Category Data when you have given us your explicit consent to do so. Consent is initially obtained at the outset of the process when an application for a driving assessment is made and thereafter will continue to be requested at each stage of the assessment as appropriate.

As noted above, in very limited circumstances we may need to process your information without your consent where required by law or where we have another legitimate interest in doing so. For further information as to when this might apply, please refer to the ‘sharing your personal information’ section below.

You have the right to withdraw your consent at any time, but this will prevent us from being able to continue with the assessment process (see below for further detail).

Withdrawal of consent may not prevent us from continuing to process certain personal data where we have the right to do so or are under a legal obligation to provide it to third parties.

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.

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.

Disclosures of your personal data

We sometimes need to share your personal data with other people or organisations. This includes:

  • family members,
  • occupational therapists who have been involved in the driving assessment
  • your general practitioner or consultant.

We will generally only do this when you have given us your consent to share the information with the third party or, in some limited circumstances, where required by law or where we have another legitimate interest in doing so.

We may need to share your information with the following third parties without your consent:

  • DVLA
  • Police

If we need to do this, we will notify you and explain the legal basis which allows us to do so. For example, in rare circumstances we may need to inform the DVLA if the outcome of your assessment is such that you are not fit to drive and we have serious concerns over your safety and other road users. We will only do this where you do not self-report to the DVLA and continue to drive against our advice.

We will always write to you and give you two weeks to self-report in this first instance, but if we are concerned that you have not done this and continue to drive, we will proceed to contact the DVLA. We will share your name and address with the DVLA and highlight our concern that you are unsafe to drive.  We will only share a copy of your assessment outcome with the DVLA when we are expressly asked to do so.

We may also be required to share personal information with regulatory authorities, government agencies and law enforcement agencies from time to time. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.

If you have been referred to us by the Police then we will report the outcome of your assessment to them.

We may share your personal data with 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 assessment centres or merge with them. If a change happens to our ownership, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties 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.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

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, agents, 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.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for your personal data are available in our retention policy which you can request from us by contacting us.

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

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data (see section below).

If you wish to exercise any of these rights please contact us.

No fee usually required

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 could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Your legal rights

You have the 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.

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.

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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.

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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.