HaloCare Group | Privacy Policy

This is HaloCare’s Privacy Policy and is to be read in conjunction with our Cookie Policy.

HaloCare is committed to protecting and respecting your privacy. This policy (together with our terms of use) and any other documents referred to on it, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat your data.

Contents:

Who are we?
Why we collect information about you
The information we process about you
Why we use your information
How long we hold your information and how it is secured?
Processing your information outside the EEA
What are my rights when you process my data?
Contact us
HaloPad
HaloCare Companion app (Circle of Care app)

1. Who are we?

For the purposes of the General Data Protection Regulation (EU) 2016/379 [‘GDPR’] and the Data Protection Act 2018, the data controller is HaloCare Group, Waterfront House, Mill Lane, Carlow, R93N6F5. This statement sets out how we, as a data controller, collect and process personal data about:

Visitors to our websites
Business referrals passed to us (with the consent of the referred person)
Individuals who we communicate or interact with in the course of our business
Clients and or service users
Individuals nominated by a client and or service user to be a part of their ‘Circle of Care’ (e.g. emergency contacts/next-of-kin for a client or service user)
Note: The ‘Circle of Care’ is a small group of client’s or service user’s nominated family or friends who are contacted (with their consent) by HaloCare at specified events (e.g. in case of emergency, at a scheduled time, to provide assistance to a service user, to make contact with a service user, etc.).
Individuals whose personal data is provided to us in connection with the provision of our Services
Employees

Our “websites” includes this website, all our associated sites (such as our knowledge sites and blogs) and our social media pages. This statement also sets out information about data subject rights and our obligations under data protection law.

We use optional cookies to enabling user movement around our website, to optimise site functionality and give you the best possible experience. We only set strictly necessary cookies by default and you can accept optional cookies if you wish. For more information, please see our Cookie Policy.

2. Why we collect information

In order to carry out our business functions, we need to collect and use personal information about the individuals who come into contact with us. Most of the personal information we process is provided to us directly by a client, service user or potential client or service use, or individuals referred to us with the consent of the referrer:

To enter into, to take steps to enter into and or to process a request to enter into, a contractual relationship with HaloCare (e.g. or services and or products).
To respond to any enquires from any client, prospective clients or authorised circle of care members.
To respond to any enquiries from any potential contractee.
To provide (with consent) monitoring and or remote home care to a service user.
To provide assistance to a client or service user.
To respond to emergency alarms or situations (in order to provide assistance).
To contact (with consent) a services users nominated Circle of Care.
To contact medical professionals and emergency services in the event an individual requires assistance.
To investigate any suspected or actual unauthorised use of our services and or products.
To prevent, monitor, investigate and or report any suspected criminal activities that may impact on HaloCare.
To protect the vital interests of user on a case-by-base basis.
To provide reasonable accommodation, where applicable, under the Equal Status Acts on a case-by-case basis.
To comply with a legal obligation to which we are subject to, e.g. mandatory reporting of any vulnerable adult in harm, etc.
For the purpose of any legitimate interest pursued us on a case-by-case basis.

Please note that all calls to HaloCare Hub, including calls made via the HaloPad or Circle of Care app, are recorded for training and quality purposes and also to protect the legal interests of a user and HaloCare.

The above purposes also apply to employees of Halocare and Circle of Care users.

Personal data is collected by us when:

Individuals provide us with data directly as part of any interaction with HaloCare e.g.

when they contact us with a query or request.
when they visit our offices.
when they write, email or phone us.
when they contact us via the HaloCare Hub.
when they contact us via the HaloPad.
when they contact us via the HaloCare Companion app (or Circle of Care app).
when they sign up as a client
when they enter into a contractual relationship with HaloCare
when they engage with the ‘onboarding process’ (i.e. when HaloCare’s assesses a users needs and what products and services apply to a client).

We also receive personal information indirectly in the following scenarios:

Via a referrer who, with consent, has asked us to make contact with an individual for the purpose of providing or exploring the potential to provide HaloCare products and services to that individual.
Via a referrer who, with consent, has asked us to make contact with an individual for the purpose of entering into, or for taking steps to enter into, a contractual relationship with HaloCare.
CareHub / Customer Care.
Retail market monitoring and reporting activities.
Where a client or employee of HaloCare provides contact details as an emergency contact or a referee.

3. The information we process

Identity – Name, surname, title, and other identifying information provided by you

Details left in voicemails or in call recordings to CareHub and records of these discussions Details provided when you contact us through our webform.

Contact information – Address, email address, phone number.

Circle of Care and Subscribers – Persons listed in the Managed Service Contract, including, if appliable, details of successors, assignees or those with power of attorney or other authorised or legal representatives.

Details of a client’s health and habitation status – illnesses, medical conditions, health status, living status, cohabitation status, medications, emergency contacts, daily routines, etc. in order to provide monitoring and care.

Supplier details – Contact information, bank details, VAT details and tax clearance information.

Stakeholder details – Contact information, role, meeting minutes / notes.

Licence & Authorisation Applicant details – Contact information, Names of company directors, Engineers.

Website user statistics (Google Analytics) – Location, time, date and details of your visit to our website (as anonymous statistics) Please see our Cookie Policy for more information.

Other personal information – Telephone recordings (made to our CareHub /customer care); CCTV images at our offices; Information in relation to subject access requests (including proof of identity if required); Responses to surveys.

Recruitment and Employee details – Applicant CV’s, credentials, references etc, tax and bank details of successful applicants.

Marketing information – If you have expressed an interest in our Services or requested updates, we will contact you with relevant information until such time as you opt – out of communications.

4. Why we use your information

We fully respect your right to privacy and, in addition to the above, will only collect or process your personal data, where required, for one or more of the following purposes (or lawful basis for processing):

To enter into a contract, or to take steps to enter into a contract, or to fulfil the terms of a contract:

To provide information to prospective clients on our products and services.
To provide our products and services to a client on foot of a contract with HaloCare.
To provide follow up services, aftercare, repairs, review of products and services, to a client on foot of a contract with HaloCare.
To ensure payment to HaloCare of any monies due.
Engaging service providers and suppliers and for the provision of and payment for goods and services.
Filling vacant positions and for the engagement and payment of employees.
Monitoring and recording the conversations when you speak on the telephone to our CareHub (to analyse, assess and improve customer service experience and for quality, training, and contract management purposes).

To run our organisation on a day-to-day basis including to:

Contact stakeholders: Business contact information relating to stakeholders (e.g. business card information, contact details, role/position in company, etc) is processed for legitimate business-related purposes.
Compile and process your information for audit, statistical, reporting or research purposes (including, in some instances, making your data anonymous) in order to help us understand market trends.
Protect our business, reputation, resources and equipment and manage our network systems, and information.
Provide security and prevent and detect crime including using CCTV at our premises.
Manage and administer our legal and compliance affairs.
Managing and responding to complaints about us.
Effectively manage the functionality and usability of the website.
We will only process your personal data for the purposes for which they were originally collected, and it will only be processed further for the following closely related business purposes:
- transferring the personal data to an archive.
- conducting internal audits or investigations.
- implementing business controls.
- conducting statistical analysis or research as required.
- preparing for or engaging in dispute resolution.
- using legal or business consulting services; or
- managing insurance issues.

To protect the vital interests of a person and or HaloCare, such as:

In order to protect the health, safety and wellbeing of a client.
To contact emergency services in case of an accident or emergency to seek aid for a person.
To report any suspected criminal activity to the relevant authorities.
To initiate, continue with or defence any legal claim or prospective legal claim.
To obtain legal advice on a specific matter.
To investigate, monitor or prevent any unauthorised or illegal use of HaloCare’s products or services.

Complying with our legal obligations, such as:

Preparing returns to relevant authorities including preparing income tax, VAT3 and other revenue returns.
Making reasonable accommodation, where applicable and on a case-by-case basis, under the Equal Status Acts.
Making reasonable accommodation, where applicable and on a case-by-case basis, under the Employment Equality Acts.
Complying with your data protection rights under GDPR.
Complying with legal requests or investigations from regulatory bodies, e.g. the Data Protection Commission.
Facilitating employees making of a protected disclosure(s) under the Protected Disclosures Act 2014.
To investigate or report a notifiable incident as mandated by the Health and Safety Authority and or the Health, Safety and Welfare at Work Act 2005.
To prevent, monitor, investigate and or report any suspected criminal activities to that may impact on HaloCare.
Complying with any court order.
Any other legal obligation not stated here.

Special categories of personal data.

We process special categories of personal data in accordance with Article 9 of the General Data Protection Regulation on the following basis:

Explicit consent of the data subject in order to provide contracted monitoring and or support products and services to the data subject.
Explicit consent of the data subject to enter into or perform a contact of services with HaloCare.
Where processing is necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on HaloCare or the data subject in connection with employment, social security, or social protection.
For the establishment, exercise, or defence of legal claims.
Where processing is necessary to protect the vital interests of the data subject or of another natural person on a case-by-case basis, e.g. in the event of an emergency in order to contact emergency services.

5. Who we share your information with?

We only share your information where it is necessary. We will not share your information with any third parties for the purposes of direct marketing. Sharing can occur in the following circumstances and with the following organisations.

A client’s Circle of Care (a client’s nominated family and friends).
Emergency services or medical professionals (with the consent of the client).
Mandated bodies under statute, e.g. An Garda Síochána, etc.
Data processors who are third parties who provide services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They are contractually bound to maintain an equivalent level of data protection and privacy as set out in this policy document and as required under GDPR.
Website Analytics: When you visit halocare.ie, we use a third-party service, Google Analytics, to collect standard statistical information and details of visitor behaviour patterns. We do this to find out such things as the number of visitors to the various parts of the site. This information is only processed in a way that does not directly identify anyone. Please see our Cookie Policy for more information.

How long we hold your information and how it is secured?

We will keep your personal data for as long as it is necessary to fulfil the purposes for which it was collected as described above and in accordance with our legal and regulatory obligations. The length of time we hold your personal data depends on a number of factors such as:

The type of data we hold about you.
Whether there is a legal obligation to hold the data for a minimum specified period.
Where there is a sound evidence-based reason to hold the data for a specified period.

Generally speaking, HaloCare has a personal data retention period of eight years after a client ceases to be a client.

The eight-year data retention policy is based on Medisec’s data retention policy, Record Retention Periods (2013) by the Health Service Executive, and the Processing of Patient Personal Data: A Guidelines for General Practitioners v2.3 by the Irish College of General Practitioners

6. Processing your information outside the EEA

We store your data on EU based servers that are based in other EU countries and are still protected by GDPR by application of the Data Protection Commission’s “One Stop Shop Mechanism” with the Irish Data Protection Commission as the lead National Supervisory Authority.

In order to protect the integrity of our data, some back-up is stored outside of the EU, in the USA and Israel, but still subject to the same protections under GDPR by application of the EU-US Privacy Shield, Standard Contractual Clauses and an EU adequacy decision (relating to Israel).

For more information on the Data Protection Commission’s “One Stop Shop Mechanism”, EU-US Privacy Shield, Standard Contractual Clauses and EU adequacy decisions, please visit the Data Protection Commission’s website at www.dataprotection.ie.

7. What are my rights when you process my data?

You have a number of rights in relation to your personal data. You may request access to your data, correction of any mistakes in our files, erasure of records where no longer required, restriction on the processing of your data, objection to the processing of your data or the basis for any international transfers.

HaloCare does not engage in any automated processing, automated decision making or profiling of data subjects or clients.

In order to request your personal data, or to object or correct any error, please put your request in writing to:

Data Protection
HaloCare
Waterfront House
Mill Lane
Carlow
R93N6F5

Or email your request to dataprotection@halocare.com

You also have the right to complain to the Data Protection Commission at www.dataprotection.ie or:

Data Protection Commission
21 Fitzwilliam Square
Dublin 2
D02 RD28

We would kindly ask you to email us first at dataprotection@halocare.com before contacting the Data Protection Commission so we can try to resolve any issue to your satisfaction.

8. Contact Us

The primary point of contact for all issues arising from this Policy, including requests to exercise data subject rights, is our Data Protection Officer. You can get in touch by emailing us at dataprotection@halocare.com.

Once we receive an enquiry or request from you, we will try to complete it within a month.

9. HaloPad

The HaloPad is a smart device/tablet that provides users with access to video interaction with the CareHub and their nominated family members or friends.

With the user’s permission, the HaloPad can also provide a user with information about the user’s location, medical information (for general information purposes and not diagnosis or treatment purposes) and hobby specific information (as requested and set by the user).

As part of entering into any agreement with HaloCare to provide monitoring and assistance, a user would set the parameters of any monitoring or assistance required and consent to the processing of their personal data. The HaloPad is a tool that allows HaloCare provide the monitoring and assistance that the user requested. The HaloPad does not process any personal data beyond what was explicitly consented to by a user as outlined above with the specific exceptions listed below.

The HaloPad needs the following permissions to be permitted by a user on the HaloPad to function:

Allow HaloPad use push notifications on the HaloPad.
Allow HaloPad to take pictures, transmit video and or record video via the HaloPad camera.
Allow HaloPad to make audio calls and or record audio calls via the HaloPad microphone.
Allow HaloPad to store user’s photos and media on the HaloPad.
Allow HaloPad establish or monitor the geographical location of the HaloPad.

The reason the HaloPad requires the user to consent to the above access is to allow the user to do the following activities via the HaloPad:

Notify the user of any activities, notifications, events or communications on the HaloPad from the HaloCare Hub or nominated family/friends
Make and receive audio calls to the HaloCare Hub or nominated family/friends.
Make and receive video calls to the HaloCare Hub or nominated family/friends.
Send and receive media (photos, video clips, etc.) to the HaloCare Hub or nominated family/friends.
Use the HaloPad’s geographical location to provide the user with services and activities within the local geographical location of the user.

Upon installation of the HaloPad, either by the user or a HaloCare service provider, or upon using the HaloPad for the first time, a user will be promoted to allow or reject access to the above permissions on the HaloPad for the above uses. The HaloPad cannot function as a method of communication with the HaloCare Hub, or nominated family/friends, without a user consenting to the above. As such, access is necessary to provide ongoing care and support to a user via the HaloPad.

Cookies used on the HaloPad

The HaloPad does not use cookies, however, the HaloPad allows users access the internet, but HaloCare is not responsible for the content or cookies used on any non-HaloCare website.

10. HaloCare Companion App (Circle of Care app)

The HaloCare Companion app, which is also referred to as the Circle of Care app, is an app for a user’s phone or smart device that provides a secure link to the HaloPad (monitoring center) to allow video calls, photo sharing, carer schedule and activity dashboard to the primary caregivers as required and requested by a user.

As part of entering into any agreement with HaloCare to provide monitoring and assistance, a user would set the parameters of any monitoring or assistance required and consent to the processing of their personal data. The HaloCare Companion app is a tool that allows HaloCare provide the monitoring and assistance that the user requested. The app does not process any personal data beyond what was consented to by a user as outlined above with the specific exceptions listed below.

The HaloCare Companion app needs the following permissions on a user’s phone or smart device in order to function:

Allow HaloCare Companion app to appear on top of a user’s phone screen or smart device screen.
Allow HaloCare Companion app use push notifications on a user’s phone or smart device.
Allow HaloCare Companion app access a device’s camera and take pictures and record video at the request of the user.
Allow HaloCare Companion app to access device’s microphone and record audio at the request of the user.
Allow HaloCare Companion app to access photos and media on a user’s device in order to store user’s pictures, photos, files and or share same with the CareHub, or any nominated family member or friend, at the request of the user.

The reason the HaloCare Companion app requires the above access to a user’s phone or smart device is to allow the user to do the following activities via the HaloCare Companion App:

Access and use the HaloCare Companion app on their phone or smart device.
Notify the user of any activities, notifications, events or communications on the HaloCare Companion app or from the HaloCare Hub or nominated family/friends.
Make and receive audio calls to the HaloCare Hub or nominated family/friends.
Make and receive video calls to the HaloCare Hub or nominated family/friends.
Send and receive media (photos, video clips, etc.) to the HaloCare Hub or nominated family/friends.

Upon installation of the HaloCare Companion app, or upon using the app for the first time, a user will be promoted to allow or reject access to the above permissions by their phone or smart device. The HaloCare Companion app cannot function without the above access. As such, access is necessary to provide ongoing care and support to a user via a user’s phone or smart device.

Cookies used on the HaloCare Companion App

The HaloCare Companion App does not use cookies, however, the App may allow users to access the internet, but HaloCare is not responsible for the content or cookies used on any non-HaloCare website.

Last review: November 2022

This Policy may be updated without further notice and data subjects, client and service users are encouraged to review all HaloCare’s privacy policies regularly.

This Privacy Policy was drafted by Argent Business Consultants and used by licence by HaloCare Group.