This privacy notice describes how Welltower OP LLC and its subsidiaries which process data about individuals in the UK (‘we’, ‘us’) collect and process personal information about you, how we use and protect this information, and your rights in relation to this information. Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.
This privacy notice applies to all personal information we collect or process in relation to:
If you would like to understand how we process your personal data in other contexts, please visit our Privacy page.
1. Residents in our UK care homes
1.1 Personal information we collect
(a) Information we collect from third parties:
We collect information about you from the care home provider(s) which provide you with the Services. For details about how they process your personal data visit the website of the registered provider for your care home. If you need help finding their website, please contact the registered manager at your care home. The categories of information that we collect about you from the care home provider(s) are:
In addition, depending on the care home you are in, we may also collect:
We also collect information about prospective residents from third-party data analytics companies, such as Experian, to better understand whether prospective residents would be suited to the care homes we own. This consists of high-level indicators about households in a particular postcode which summarise household composition, age and income brackets as well as information about your likelihood for certain tendencies such as being retired, being interested in the arts, or having children.
We also collect information about the friends and family of residents when they visit the care home, or in the context of them managing the care of a resident. In these contexts we process name, contact information, the correspondence between us and any information relating to payments for our services.
(b) Sensitive information
We may also collect health-related data from your care home provider when carrying out regular audits of its provision of the Services and in order to ensure high standards of quality and safety of care we provide. These may include:
1.2 How we use your personal information and the basis on which we use it
We use your personal information to:
We must have a legal basis to process your personal information. In most cases the legal basis will be to meet our legitimate interests, for example to assess demand for the Services and to derive knowledge from that to enable us to fund expansion of our properties for new services. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
Audits of the Services provided to you by your care home provider will be carried out by medically qualified nurses. Our legal basis for collecting your health data through such audits and for undertaking analysis for the above mentioned purposes will be for the public interest in the area of public health for the purposes of ensuring high standards of quality and safety of health care.
1.3 Information sharing
We may share your health data and other personal information with third parties under the following circumstances:
In addition to the above, we may share categories of your personal information other than health data with third parties under the following circumstances:
Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which you are provided with the Services). See the section on “International Data Transfer” below for more information.
2. Employee recruitment data collection
We will collect data about you when you apply to work for us, either directly through our careers page or through third party agencies and recruiters acting on your behalf.
2.1 Personal information we collect
(a) Information we collect directly from you:
The categories of information that we collect directly from you are:
(b) Information we collect from third parties:
The categories of information that we collect about you from other sources are:
(c) Sensitive information
We may also collect, in the event that it is necessary, sensitive information (also known as special category information) about you as permitted or required by law. This is a category of personal information that has special protection under data protection laws, such as:
information about race, ethnic origin, religion or sexual orientation for diversity monitoring purposes;Where we process such sensitive personal information, we will usually do so on the basis that it is necessary for reasons of substantial public interest or to establish, exercise or defend any legal claims. In any case, we will carry out the processing in accordance with applicable laws.
Depending on the position you are applying for, we may also conduct a criminal background check for employee vetting purposes, and will do so with your consent.
2.2 How we use your personal information and the basis on which we use it
We use your personal information to:
We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:
Please note that we may be required by law to collect certain personal information about you for recruitment purposes, or as a consequence of our relationship with you as an employer. Failure to provide this information may prevent or delay the fulfilment of these obligations.
We may obtain your explicit consent to collect and use certain types of personal information when we are required to do so by law (for example, when we process some categories of sensitive personal information). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice.
2.3 Information sharing
We may share your personal information with third parties under the following circumstances:
The recipients referred to above may be located outside the jurisdiction in which you are located. See the section on “International Data Transfer” below for more information.
We will collect data about you when you visit our Website.
3.1 Personal information we collect
(a) Information we collect from you:
We may collect data directly from visitors to our Website where visitors are requested to voluntarily provide their personal information through online web forms. The information provided in this manner may include name, age and contact details.
We may also use cookies, web beacons (including pixels and tags), web server logs, and similar technologies on our website that collect certain information about you by automated means.
We use these automated technologies to collect information about your devices, browsing actions, and usage patterns. The information we obtain in this manner includes
Please see our Cookie Notice, for further information about the cookies and other tracking technologies we use, and the choices you have to control them.
3.2 How we use your personal information and the basis on which we use it
We must have a legal basis to process your personal information when you visit our website. In some cases the legal basis will be to meet our legitimate interests, for example to ensure that you are able to use all of the features of our website. In other cases we will ask for your consent, for example where we use cookies to display targeted advertisements or carry out analysis of website interactions to better target our provision of the Services. If we ask for your consent to process your personal information, you may withdraw your consent at any time.
3.3 Information sharing
We may share your personal information with third parties under the following circumstances:
The recipients referred to above may be located outside the jurisdiction in which you are located. See the section on “International Data Transfer” below for more information.
4. Information security and storage
We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.
We will keep your personal information for a period of time that enables us to:
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
5. International data transfers
Your personal information may be transferred to, stored, and processed in the USA, where our headquarters is located, or in countries where our vendors or professional advisors are located.
For transfers to countries not recognised as offering an adequate level of data protection, we have put in place adequate measures as required by applicable laws, such as entering into standard contractual clauses recognised by the UK authorities as protecting your personal data. For more information on the appropriate safeguards in place, please contact us at the details below.
6. Your rights over your personal information
You have certain rights regarding your personal information, subject to local law. These include the following rights to:
If you would like to discuss or exercise such rights, please contact us at the details below.
We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.
We will contact you if we need additional information from you in order to handle your requests.
If you have questions or concerns regarding the way in which your personal information has been used, or you would like to contact our Data Protection Officer, please contact privacy@welltower.com or fill out our online rights request form. We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your local data protection authority, the Information Commissioner’s Office.
8. Changes to this Privacy Notice
We may modify or update this privacy notice from time to time.
If we change this privacy notice, we will notify you of the changes in a form commensurate with the significance of the changes. Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).
Last updated: 12 September 2024