Last update: April 2024
Glossary
Controller: the person or organisation who determines what Data is to be
processed, and the purpose for which it is processed. For the purposes of
this notice, ADL Smartcare holds this role. Where the Local Organisation
downloads or saves any Data available to them, then the Local Organisation
becomes the sole Controller of such Data. You should refer to them for more
information on how Your Data will be handled.
Data: Information which can be used to identify a specific individual
person.
‘Our’, ‘Us’, or ‘We’ refers to
ADL Smartcare Limited
: Owner of the LifeCurve™ Software, including the knowledge and code
it contains.
Processing: any action involving personal Data – including working with the
Data in some way as well as collecting, storing, sharing and deleting the
Data.
‘Website’ means Our LifeCurve™ Public website (
https://adlpublic.co.uk
), including the Content and any subsequent updates or supplements to it.
‘You’ or ‘Your’ means the user of the LifeCurve™ Public Website.
Introduction
The LifeCurve™ Public Website is available to residents of the Local
Organisation. The purpose of the Website is to assist You with Your
functional ageing journey, and if required, suggest equipment, exercise
routines or other resources tailored to You – all without the need to be
assessed at home or at a clinic by a Healthcare Professional.
How should I trust it is safe?
The expert advice offered through the LifeCurve™ websites has been
gathered by panels of Expert Professionals in the Healthy Ageing field
(older person Physiotherapists, Occupational Therapists, Nurses etc) – from
best practice, experts in Ageing, and related research over the last twenty
years. They are intended to replicate the process and clinical reasoning
used by a Professional if they were to carry out an assessment in-person. In
addition, accurate use of the Website is covered by Professional Indemnity
Insurance.
Why can We process Your Data?
In order to facilitate Your access and use of the LifeCurve™ Public
Website, We ask for Your
explicit consent
to process the required Data. You may withdraw Your consent at any time by
contacting ADL Smartcare or the Local Organisation – however, We will not be
able to provide help or advice for Your ageing journey without the Data
above, or Your consent.
ADL Smartcare and the Local Organisation are equally committed to protecting
Your rights and privacy in respect of Your Data, in accordance with the UK
Data Protection Act.
What Data about You is collected?
We request the following Data about You or the person relying on the advice:
- First name
- Surname/family name
-
Year of birth (to allow Us to benchmark You against other users if You
wish)
-
Postcode (to confirm service/delivery eligibility, and to provide local
resources)
- Email address
-
Phone numbers and full address (to enable us to process equipment
orders)
In addition, through assessments of Your needs, We will collect information
regarding Your health and ability to complete activities of daily living.
This may include information about Your home environment and ability to
complete specific tasks or movements. We will only ever ask questions
relevant to the assessment or goal You are hoping to complete.
We consider this to be sensitive health information, and so We ask for Your
explicit consent for Us to collect and Process it. You may withdraw Your
consent at any time by contacting the Local Organisation – however, We will
not be able to provide help or advice for Your ageing journey without either
this Data, or Your consent.
May I remain anonymous?
It is possible to complete a LifeCurve™ assessment without first
registering on the Website. This will show You where You are on Your ageing
journey. You will be required to provide Us with information regarding Your
ability to complete activities of daily living. If You remain anonymous, You
will not be able to retrieve this assessment result in the future.
By setting up an account on the Website, and providing Us with the Data
listed above, You will be able to:
- save and track Your progress
- receive additional help towards specific goals or ambitions
-
access local support such as equipment or other resources or activities.
What do We do with Your Data?
Information You have given Us in an assessment will be used by Our software
algorithms, embedded in the Website, to generate the best solutions for You
based on healthcare professional assessments processes, knowledge and expert
practice recommended to Us over twenty years. This is known as
Automated Decision Making
, and by consenting to using the Website You acknowledge Your Data will be
subjected to this process. However, it is for You to decide whether You
accept the outcome and any suggested movement routines, equipment or other
help offered (which has itself been reasoned by Professionals).
Your Data may be available to authorised employees of the Local Organisation
who may use it to support You on Your ageing journey. It may be possible for
them to link the information You provide to other health records they hold.
ADL Smartcare may also use your anonymised Data to provide the Local
Organisation with insight into how the people in Your area as a whole are
ageing. However, no personally-identifiable Data will be shared with any
other person or organisation.
In addition, You have the option to consent for Your anonymised Data to be
used for the purposes of research into healthy ageing, to improve ageing and
wellbeing in future. Declining to opt-in will not affect Your rights or
ability to use Our Website for Your own healthy ageing journey.
How will Your Data be kept and stored?
Your Data will be stored in the UK by ADL Smartcare on secure, dedicated
infrastructure. ADL Smartcare itself is Cyber Essentials accredited. ADL
Smartcare outsources IT/Data Support and hosting to organisations which are
compliant and certified with Cyber Essentials and/or ISO 27001.
Your Data will be retained for seven years following the last recorded
activity (such as an assessment).
Staff of the Local Organisation receive training on handling Your Data
securely and professionally. In addition, there are a number of physical and
technical features built into the LifeCurve™ Pro platform, to ensure
Your Data is secure when kept by Us.
To aid the management and administration of the platform, from time to time
it is necessary for specific employees within ADL Smartcare (or its
suppliers or contractors) to have brief access to Your Data. Where this does
happen, Your Data will be protected by, and handled in accordance with, the
UK’s Data Protection Act (2018). This includes an expectation that Your Data
will be handled with due security, confidentiality, care and respect. It is
supported by staff training and other technical and organisational measures,
including encryption.
Your rights concerning Your Data
You have a number of rights relating to Your Data or how We use it:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to Data portability
- The right to object
- Rights in relation to automated decision making and profiling.
If You would like to exercise any of these, or would like a copy of the Data
We hold about You, please get in touch with ADL Smartcare using the email
address below. However, please note that some of these rights are not
absolute - for example, We may not be able to forget You entirely where We
are required by law to retain Your Data for a specific reason or length of
time.
In addition, if You are concerned Your Data is inaccurate, You may update it
on the Website Yourself or contact
[email protected]
in the first instance.
If You have a complaint regarding how Your Data has been handled by Us,
please first raise this with ADL Smartcare’s Data Protection Officer. If You
are not satisfied with the outcome of this, You may escalate Your complaint
to the Information Commissioner’s Office. For more information, visit:
https://ico.org.uk/make-a-complaint/
ADL Smartcare:
Electric Works, Sheffield Digital Campus, 3 Concourse Way, Sheffield S1 2BJ
Registered in England: Company 4456225
Email:
[email protected]
