Privacy Policy

Last updated: May 2018

Protecting your personal information is extremely important to IVG Group. It’s especially important for a company like ours, as our customers trust us to look after their personal data.

The way we collect and share your information is equally important. Our customers expect us to manage their information privately and securely. If we don’t, they’ll lose their trust in us.

This policy tells you how we collect and process your personal information. Please take a few minutes to read it, and show it to anyone else connected to the policy.

What is personal information?

When we talk about personal information we mean information about an individual that can identify them, like their name, address, e-mail address, telephone number and financial details. It can relate to customers, employees, shareholders, business contacts and suppliers. Any reference to “information” or “data” in this policy is a reference to personal information about a living individual.

What information do we hold?

We may collect and process the following personal information about you:

Type of data Description

Examples of how we use it

Contact
  • Who you are
  • Where you live
  • How to contact you
  • Sending offers relevant to you
  • Marketing our villages close to you
  • Analysis & profiling
  • Enhancing our product and service offering

Personal Details

    • Age
    • Gender
    • Family details
    • Financial Details
    • Lifestyle and social circumstances
    • Marketing
    • Analysis & profiling

    Consent & preferences

    •  Ways you want us to market to you
    • Marketing
    Technical
    • Details on the devices and technology you use
    • Making sure our products and services are fit for purpose
    Documentary data & national identifiers
    • Details about you that are stored in documents like:
    • Your passport
    • Drivers licence
    • Birth certificate
    • National insurance number
    • Prevent financial crime

    Where do we get our information from?

    • Information you give us directly (when you fill in forms or contact us by phone, e-mail etc.).
    • Information we collect about you or receive from other sources. This could be information you provide to us electronically (through our website or an online portal, for example), information we get from your online browsing activity, information from a third party or from publicly available sources such as social media platforms or the electoral register (e.g. to detect fraudulent claims). For more information on how we use cookies, please refer to our cookie policy.

    How do we use your information?

    We use personal information that we hold about you:

    • To carry out our responsibilities resulting from any agreements you’ve entered into with us (e.g. to carry out our responsibilities under HMRC Money Laundering Regulations) and to provide you with the information, products and services that you’ve asked from us.
    • To provide you with marketing information about services and products we offer across the IVG Group group which may be of interest to you. Based on your marketing preferences, we may deliver this information by post, telephone, e-mail, SMS or personalised online marketing via our own systems social media platforms and/or other third party websites e.g. YouTube. Please note that if you choose not to receive online marketing, you will not see personalised messages using your personal data, however you may still see generic online advertising. We will not sell your data to third parties for them to market to you. We may also send marketing to you using our “legitimate interests”, please see below for further information.
    • To tell you about changes to our services and products.
    • To comply with any applicable legal or regulatory requirements (including “know your customer” checks, or to comply with any applicable regulatory reporting or disclosure requirements).
    • For carrying out market research, statistical analysis and customer profiling to help us to improve our processes, products and services and generate new business (e.g. to understand digital behaviours, identify lifestyle and care attitudes and develop more engaging communications).
    • To run our business in an efficient and proper way. This includes testing our systems, managing our financial position, business capability, planning, communications, corporate governance, and audit.
    • For any other purpose that we’ve agreed with you from time to time.

    When you apply for a product or to receive a service from us, the application form you fill out or the resulting contract may contain additional conditions relating to the way we use and process your personal information. These will apply in addition to the above uses.

    In some cases, we may use systems to make automated decisions (including profiling) based on the personal information we have, or collect from others. These may include:

    • The prevention and detection of fraud.
    • Personalising the content and design of communications and online services.
    • Determining when to provide tailored servicing communications (e.g. changes in your personal circumstances or lifestyle), and the appropriate channel(s) to use.

    Using your information in accordance with data protection laws

    Data protection laws require us to meet certain conditions before we’re allowed to use your personal information in the way we describe in this privacy policy. We take these responsibilities extremely seriously. To use your personal information, we’ll rely on the following conditions, depending on the activities we’re carrying out:

    • Providing our contracts & services to you: We’ll process your personal information to carry out our responsibilities resulting from any agreements you’ve entered into with us and to provide you with the information, products and services you’ve asked from us, which may include online services.
    • Complying with applicable laws: We may process your personal information to comply with any legal obligation we’re subject to.
    • Legitimate interests: To use your personal data for any other purpose described in this privacy policy, we’ll rely on a condition known as "legitimate interests". It’s in our legitimate interests to collect your personal data as it provides us with the information that we need to provide our services to you more effectively. We may use your information to:
    • Carry out market research and product development, which can include creating customer demographics and/or profiling. We may sometimes work with carefully selected third parties to do this, for example using advertising services provided by organisations such as Google or Facebook and may share data with them, which could be combined with the information they hold about you.
    • Continue to send marketing information, via post only, to customers who asked forus to provide information about our villages before 25th May 2018 and did not opt-out, until such time as they have reviewed their marketing preferences (which can be done at any time).
    • Develop and test the effectiveness of marketing activities.
    • Develop, test and manage our brands, products and services.
    • Study and also manage how our customers use products and services from us and our business partners.
    • Manage risk for us and our customers.

    This requires us to carry out an assessment of our interests in using your personal data against the interests you have as a citizen and the rights you have under data protection laws.

    The outcome of this assessment will determine whether we can use your personal data in the ways described in this privacy policy (except in relation to marketing, where we’ll always rely on your consent). We’ll always act reasonably and give full and proper consideration to your interests in carrying out this assessment.

    • Consent: We may provide you with marketing information about our services or products where you’ve provided your consent for us to do so.

    You may opt out of marketing at any time by e-mailing or telephoning our Village Advisers.

    • Special category (sensitive) data: Where you have consented, we will process any medical & health, racial & ethnic origin, genetic & biometric or sex life & sexual orientation information you have provided, and any other sensitive information obtained from a third party (e.g. your GP or other medical professional), solely for the purposes of allowing us to manage the provision of care within our villages.

    Please be aware that the personal information you provide to us, and which we collect about you, is required for us to be able to provide our services to you and without it we may not be able to do so.


    Job Applicant Privacy Policy

    How we will use information about you

    IVG group ('we' or 'us') provide this notice to make job applicants aware of our policies relating to the processing of personal data in accordance with the Data Protection Act 1998, the General Data Protection Regulation 2016 and the Data Protection Act 2017 (‘Data Protection Legislation’). References to ‘Personal Data’ and ‘Sensitive Personal Data’ within this notice shall be references to those terms as defined in Data Protection Legislation.

    Personal Data

    We ask for Personal Data from job applicants including C.V’s and any ancillary information provided as part of your application to assist with our recruitment processes. Any Personal Data about you which is obtained by us during the application process (including any information obtained directly from you or from third parties such as your referees or as part of pre-employment checks) may be retained and used by us for the purposes of considering your suitability for employment, conducting appropriate checks and as otherwise reasonably required for our legitimate interests and compliance with applicable law.

    Sensitive Personal Data

    You may also supply us with Sensitive Personal Data including but not limited to data relating to your racial or ethnic origin, religious or similar beliefs, physical or mental health and sexual orientation by completing our equal opportunities monitoring form. This information is gathered for equality of opportunity monitoring purposes and is anonymised.

    If you have any medical condition or disability which may require special facilities or support at interview we will only use this information for the purpose of providing any necessary adjustments in accordance with equality legislation, to ensure compliance with employment law and making decisions regarding your fitness for work. If applicable, we may also require that you supply us with additional information to support any criminal referencing check.

    Storage of your Personal Data

    The ‘Personal Data’ and ‘Sensitive Personal Data’ will be stored, processed, used and disclosed by us in the following ways:

    • To provide our recruitment services to you and to facilitate the recruitment process;
    • To enable you to submit your CV and/or application form,
    • To enable you to apply online for jobs;
    • To improve our customer service;
    • To make our services more valuable to you (including tailoring our website and our group companies websites when you log on to enrich your personal online experience);
    • To answer your questions and enquiries;
    • To share with third parties where we have retained them;
    • To provide services that we or you have requested including health assessments, references, qualifications and criminal reference checking services (DBS), verification of the details you have provided from third party source, psychometric evaluation or skill test;
    • To use your information on an anonymised basis to monitor compliance with our equal opportunities policy;
    • To carry out our obligations arising from any contracts entered into between you and us; and
    • To undertake statistical analysis of anonymised data (equality and diversity) and internal reporting through a job applicant’s recruitment journey.

    From time to time we will seek your express consent to process, use or disclose your information for any other purpose not listed above.

    We reserve the right to transfer your information to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company, provided that the third party agrees to adhere to the terms of this Privacy Policy and provided that the third party only uses your ‘Personal Data’ and ‘Sensitive Personal Data’ for the purposes that you provided it to us. You will be notified in the event of any such transfer and we will seek your express consent.

    Deleting your Personal Data

    We will automatically archive your personal details after 6 months of inactivity. Inactivity means that neither IVG nor the job applicant have had any activity against that job applicant’s record (e.g. status updates, changes to details, emails / job alerts sent).

    You will receive an automated email to advise of how you can ‘interrupt’ the archiving process if you still wish for your details to be held for future recruitment purposes.

    After the email notification has been sent to advise you that your details are set to be archived, the system will wait for a response/activity for a period of 30 days.

    If there has still been no further activity against your record, your personal details will then be archived, and will be permanently deleted after a further period of 30 days. Key details from your application will be anonymised and retained for reporting purposes and statistical analysis.


    How long do we keep your information for?

    We’ll keep your personal information in accordance with our internal retention policies. We’ll determine the length of time we keep it for based on the minimum retention periods required by law or regulation. We’ll only keep your personal information after this period if there’s a legitimate and provable business reason to do so.

    Who do we share your personal information with?

    We’ll only disclose your information to:

    • Other companies within the IVG Group, third-party suppliers, contractors and service providers for the purposes listed under “HOW WE USE YOUR INFORMATION” above.
    • Selected third parties, so that they can contact you with details of the services that they provide, where you have expressly opted-in or consented to the disclosure of your personal data for these purposes.
    • Our regulators, government (e.g. HMRC) and law enforcement or fraud prevention agencies, reassurers, as well as our professional advisers etc.

    Additionally, we may disclose your personal information to third parties:

    • In the event that we sell or buy any business or assets, in which case we’ll disclose your personal data to the prospective seller or buyer of such business or assets.
    • If we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
    • If you have been dealing with a financial adviser, we’ll provide information about your product and, where appropriate, and with other information about your dealings with us, to enable the adviser to give you informed advice.
    • In order to enforce or apply the terms of any contract with you.
    • If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
    • To protect you and IVG Group from financial crime, IVG Group may be required to verify the identity of new and sometimes existing customers. This may be achieved by using reference agencies to search sources of information relating to me (an identity search). This will not affect my credit rating. If this fails, IVG Group may need to approach me to obtain documentary evidence of identity.

    If you’ve been introduced to us by another company (such as an estate agency), we may share your information with them to enable them to:

    • Carry out market research, statistical analysis and customer profiling.
    • Where you have consented, send you marketing information by post, telephone, e-mail and SMS about their products and those of carefully selected third parties.
    • Assist you with your application process.

    Fraud prevention

    IVG Group will check your details with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We may also share information about you with other organisations and public bodies, including the police and we may check and/or file your details with fraud prevention agencies and databases.

    IVG Group and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

    • Checking details on reservation.
    • Recovering debt.
    • Checking details of job applicants and employees.

    IVG Group and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

    IVG Group may also check the details of other parties related to your contract, including verification of identity. This includes beneficiaries, trustees, settlors, third party premium payers, executors or administrators of your estate, parties with power of attorney and any other beneficial owner.

    Transferring your data outside the EU

    The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") to third-party suppliers, delegates or agents. We’ll take all reasonably necessary steps to make sure that your data is treated securely and in accordance with this privacy policy.

    We’ll only transfer your data to a recipient outside the EEA where we’re permitted to do so by law (for instance, (A) where the transfer is based on standard data protection clauses adopted or approved by the European Commission, (B) where the transfer is to a territory that is deemed adequate by the European Commission, or (C) where the recipient is subject to an approved certification mechanism and the personal information is subject to appropriate safeguards, etc.).

    Unfortunately, sending information via e-mail is not completely secure; anything you send is done so at your own risk. Once received, we will secure your information in accordance with our security procedures and controls

    Your rights

    You have rights under data protection law that relate to the way we process your personal data. More information on these rights can be found on the Information Commissioner’s website. If you wish to exercise any these rights, please get in touch with our Village Advisers. Alternatively, you can also use the Contact Us section of our website

    1. The right to access the personal data that we hold about you.
    2. The right to make us correct any inaccurate personal data we hold about you.
    3. The right to make us erase any personal data we hold about you. This right will only apply where for example):
      1. We no longer need to use the personal data to achieve the purpose we collected it for
      2. You withdraw your consent if we’re using your personal data based on that consent
      3. Where you object to the way we use your data, and there is no overriding legitimate interest
    4. The right to restrict our processing of the personal data we hold about you. This right will only apply where for example:
      1. You dispute the accuracy of the personal data we hold
      2. You would like your data erased, but we require to hold it in order to stop its processing
      3. You have the right to require us to erase the personal data but would prefer that our processing is restricted instead
      4. Where we no longer need to use the personal data to achieve the purpose we collected it for, but you need the data for legal claims.
    5. The right to object to our processing of personal data we hold about you (including for the purposes of sending marketing materials to you).
    6. The right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to make us transfer this personal data to another organisation.
    7. The right to withdraw your consent, where we’re relying on it to use your personal data (for example, to provide you with marketing information about our services or products).

    Contacts and complaints

    If you have any questions about this privacy policy or wish to exercise any of your rights, including changing your marketing preferences, please get in touch with your usual IVG Group contact or our Village Advisers.

    Data Protection Officer

    IVG Group has appointed a Data Protection Officer to provide independent expert advice and monitor compliance with data protection laws: Contact dataprotection@inspiredvillages.co.uk