Site Visitors Privacy Statement

1. Purpose of our privacy statement
1.1 Under the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), we are required to explain to you why we are asking for this information about you, how we intend to use the information you provide and whether we will share this with anyone else.

2. Who are we?
2.1 Sanctuary LumaLiving is a brand name used by Sanctuary Home Care Limited and Sanctuary Housing Association, each a part of Sanctuary Group (“Sanctuary”). We are one of the UK’s leading providers of housing, care and commercial services. Our address is Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ.

3. Our data protection officer
3.1 Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
3.2 If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing dataprotection@sanctuary.co.uk.

4. Why are we collecting your information?
4.1 When visiting our premises we collect and process your information for site security, safety and fire evacuation purposes, as well as to ensure you are identifiable.

5. What information are we collecting?
5.1 Most of the personal information we process is provided to us directly by you when completing our signing-in and signing-out sheet.
5.2 We collect and process the following information:
• Name
• Contact details (if applicable)
• Vehicle registration number (if applicable)
• Site location
5.3 In relation to visitors to our Worcester head office site, we also take a photograph of you which is printed as part of your visitor pass which is required to be worn while on site for security purposes to ensure you are identifiable.

6. What is our lawful basis for using your information?
6.1 Under Article 6 of the UK GDPR, the lawful bases we rely on for processing this information are:
(c) Compliance with a legal obligation – using your information is necessary for us to comply with a legal obligation to which we are subject in accordance with the Health and Safety Act 1974.
(f) Our legitimate interests or that of a third party – for the purposes of security.

7. Sharing your information
Members of Sanctuary Group
7.1 Sanctuary Group is made up of several related companies. We will share your information with other members of Sanctuary Group where necessary to best facilitate this process.
7.2 For more information on which companies make up Sanctuary Group, please go to www.sanctuary.co.uk/about-sanctuary.
Regulators and other legal obligations
7.3 We may also be required to share your information with our regulators who are permitted access to this information by law and with other organisations where we have a legal obligation to share the information with them.
Data processors and Transfers
7.4 To facilitate this process, information is shared with the following categories of data processors who process information on Sanctuary’s behalf:
• System providers for technical IT support (to enable the creation of ID badges and provide fob access – if applicable).
• security companies that are responsible for on-site security (where applicable).

8. Can we use your information for any other purpose?
8.1 In limited circumstances, we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.

9. Security of your information
9.1 The information that you provide will be stored securely. Our technological and organisational security measures and procedures reflect the seriousness with which we attach to the confidentiality, integrity and availability of your information.
9.2 Only relevant members of staff will access the information you provide to us.

10. Storing your information and deleting it
10.1 We will not keep your personal data for longer than we need it or are required to by law.
10.2 Information captured via our Visitor Management System at our Worcester Head Office, is retained for one week from the date of visiting the premises.
10.3 We will keep the information that is provided to us in our signing in and out sheets for 9 months from the date of visiting the premises.

11. Your rights
11.1 In relation to the information which we hold about you, you are entitled to:
11.2 Ask us for access to the information;
11.3 Ask us to rectify the information where it is inaccurate or is incomplete;
11.4 Ask us to limit and restrict what we do with your information;
11.5 Ask us to provide the data you have provided us in a structured, commonly used, and machine-readable format (for example, a CSV file) in order transmit the data to another data controller.
11.6 Our obligations to comply with the above rights are subject to certain exemptions.
11.7 To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing dataprotection@sanctuary.co.uk.

12. How to complain
12.1 If you have any concerns about our use of your personal information, you can contact our Data Protection Team on dataprotection@sanctuary.co.uk.
12.2 You also have the right to complain to the Information Commissioner’s Office (the ‘ICO’) if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.