Personal information about individuals is typically provided to Clinevo by the individual themselves (e.g., young person, parent or guardian, foster carer, contractor, customer, or visitor). Additionally, personal information that individuals provide to other organisations may also be forwarded to Clinevo (for example, from a local authority social worker when placing a young person with us).

Clinevo may collect and process the following personal information:

• Personal details (name, date of birth, email address, home address, telephone number, NI number, unique pupil number, gender, disability, sexual orientation, criminal convictions, racial or ethnic origin, religious or other beliefs).
• Family details (contact details and relationships).
• Financial information (bank details).
• Safeguarding, special educational needs, physical and mental health.
• Education details (school admission, attendance, absences, behaviour, exclusions, certificates, exams or tests records, and progress).
• Visual images, personal appearance and behaviour (photographs, CCTV recordings).
• Information related to offences or alleged offences.
• Details of goods and services provided.

Personal details about physical or mental health, alleged commission, or conviction of criminal offences are considered “sensitive” personal information. We will process such information only if you have given your explicit consent, it is necessary for a legal reason, or you have deliberately made it public.

If you contact Clinevo, we may keep a record of that correspondence, along with details of your visits to Clinevo’s site and the resources you access.

Reasons Why Clinevo Collects Personal Information

We collect personal information to enable us to fulfill our legitimate business needs, such as:

• Providing education and training
• Offering residential healthcare, welfare, and educational support services
• Offering fostering for children and young people
• Administering school property and library services
• Maintaining our accounts and records
• Managing boarding and organizing alumni associations and events
• Administering shareholders’ registrations and dividends services
• Raising funds for our businesses
• Supporting and managing our staff
• Advertising and marketing

Clinevo’s Legal Basis and Purposes for Using Your Personal Information

We collect and use your personal information in the following situations:

1. Performance of a Contract:
   1. We use your information to perform contracts we have with you. For example, recording the personal details of healthcare providers for children or young people and staff from local authorities commissioning our services.
   2. Without this information, it may be impossible to agree on a contract or provide services under a contract.
2. Legitimate Business Needs:
   1. We collect visual images and personal appearance through CCTV to maintain security and prevent crime. This information may be shared with data subjects, employees, agents, service providers, police, security organisations, and inquirers.
   2. We keep records of communications (emails, phone calls) to help fulfill requests, maintain contact, and offer relevant communications.
3. Compliance with Legal Obligations:
   1. We track and record pupils' progress to share with Ofsted and the Department for Education.
   2. We cooperate with local authorities on arrangements for children and young people with special educational needs.
4. Public Interest Tasks:
   1. We share information with the Police, Local Authority, or other agencies if a child or vulnerable person may be at risk.
   2. We monitor visitors' movements to ensure the safe running of our schools and homes.
   3. We We keep records of daily observations of young persons to manage risks and track progress.
5. Protecting Vital Interests:
   1. We maintain family or carer contact details for emergency situations.
   2. We record young persons' health needs, including food allergies.
6. Consent:
   1. We use your photographs to promote or market our business with your consent.
   2. If you subscribe to marketing information (e-newsletters, service updates), you will have the option to unsubscribe.
   3. You can withdraw your consent at any time using the same method you originally provided it.

Who Will Clinevo Share Your Personal Information With?

We may share your information for any of the purposes mentioned in sections 3 and 4. These include performing contracts, fulfilling legitimate business needs, complying with legal obligations, carrying out public interest tasks, protecting vital interests, or where we have your consent.

Specifically, information may be shared with:

• Family and representatives of the person whose personal data we are processing
• Ofsted, Department for Education, and local authorities
• Welsh Inspectorate for both care and education
• Care Quality Commission (England)
• Police, courts, tribunals, and security organisations
• Contractors who provide services
• Healthcare professionals, social and welfare organisations
• Staff, students, governors, and school boards
• Debt collection and tracing agencies
• Financial organisations
• Foster parents
• Education, training, and examining bodies

Transferring Your Personal Information Internationally

Occasionally, it may be necessary to transfer personal information overseas (outside the UK). Information is only shared within the European Economic Area (EEA), in full compliance with the General Data Protection Regulations and the Data Protection Act 2018.

The Period for Which We Will Keep Your Personal Information

We will retain your personal information only as long as necessary for the purposes it was collected or to meet legal and regulatory requirements. For instance, we must keep child protection information for 25 years after birth.

The retention period depends on the type of information and its use. For example, if you opt out of marketing emails, we will stop storing your email for marketing but will keep a record of your preference. We are updating our data retention schedule, which will be published soon. We regularly review retention periods and delete information no longer required.

How We Keep Your Personal Information Safe and Who Has Access to It

We follow strict security procedures to protect your personal data against accidental loss, unauthorized access, destruction, or damage. Personal information held electronically is stored on secure systems, with controlled access. Our staff receive data protection training and adhere to our data protection policies and procedures.

We conduct detailed checks on external companies collecting or processing personal data on our behalf and establish contracts outlining our expectations and requirements for data management. Clinevo’s site may link to third-party websites, which have their own privacy policies. We are not responsible for these policies. Please check them before submitting personal data.

Automated Decision Making and Processing

Automated decision-making involves processing your personal information without human intervention to evaluate your situation, such as your preferences, interests, or behavior. For example, decisions about whether to admit or exclude a pupil from one of our schools are made by an employee, not solely by automated devices.

Your Data Protection Rights

Under certain circumstances, you have the right to:

• Request information about whether we hold your personal information and why we are using it.
• Request access to your personal information (a "data subject access request").
• Request correction of any incomplete or inaccurate personal information.
• Request erasure of your personal information where there is no good reason for us to continue processing it.
• Object to the processing of your personal information based on legitimate interests or for direct marketing purposes.
• Object to automated decision-making, including profiling.
• Request the restriction of processing of your personal information.
• Request the transfer of your personal information to you or another party ("data portability").
• Withdraw consent at any time for processing your personal information for a specific purpose

To exercise any of these rights, please email enquiries@clinevo.co.uk FAO: Data Protection Officer, or visit our registered office at Venture House, 12 Prospect Park, Longford Road, Cannock WS11 0LG.

Access to your personal information is free of charge, but we may charge a reasonable fee if your request is unfounded or excessive. We may request specific information to confirm your identity and ensure your right to access the information or exercise other rights.

IP Addresses and Cookies

Clinevo may collect information about your computer, including your IP address, operating system, and browser type, for system administration. We may use cookies, which are stored on your computer's hard drive, to improve our site and provide a personalized service. You can refuse cookies by adjusting your browser settings, but this may restrict access to certain parts of our site. Unless you refuse cookies, our system will issue them when you log on to our site.

Changes to Clinevo's Privacy Policy

Any changes to our privacy policy will be posted on this page.

Contacting Our Data Protection Officer

We have appointed a Data Protection Officer (DPO) to oversee compliance with this policy. You can contact our DPO with any complaints or concerns about how we process your personal information using the details provided in section 10.

Your Right to Contact the Information Commissioner

If you are not satisfied with our handling of your complaint or believe we have not processed your personal information in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO). You can contact the ICO directly, regardless of whether you have first raised the issue with us.

Contact Us

Questions, comments, and requests regarding this privacy policy are welcome, including inquiries about your privacy rights. Please address them to the Data Protection Officer using the contact details in section 10.