Welltower UK Privacy Notice

Residents in our UK care homes
Employee recruitment data collection
Visitors to our website
Information security and storage
International data transfer
Your rights over your personal information
Contact us
Changes to this privacy notice

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:

the senior housing, post-acute care or and services (the “Services”) that we provide in the United Kingdom;

if you are resident in the UK or EU, your interactions with our website, www.welltower.com (“Website”); and

any job applications you make to Welltower in the UK.

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:

contributions to resident questionnaires and surveys; and

the charges you incur at the care home you stay in, the care level you receive and your occupancy dates.

In addition, depending on the care home you are in, we may also collect:

personal details including your title, full name, maiden name, marital status, date of birth, gender, contact details including address (billing address or correspondence address), telephone numbers, email addresses, contact details for next of kin, your GP and other allied health professionals; and

compliments and complaints.

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:

information about your health-related conditions, symptoms, status, testing, treatments, diagnoses or medications, including your use and purchase of such medication, accidents and incidents information, and any practical care-related requirements such as equipment needs and allergies;

certain types of genetic information that may be associated with a diagnosis or condition you have, or medication you receive;

information about your sexual orientation;

data revealing your race or ethnicity; and

information revealing your religious or philosophical beliefs.

1.2 How we use your personal information and the basis on which we use it

We use your personal information to:

ensure high standards of quality and safety of the Services being provided to you by the relevant care home provider;
undertake statistical analysis to help manage our business and assess prospective demand for health care infrastructure in order to inform our future investment decisions; and
otherwise inform our operational and strategic business decision making.

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:

Care home providers. We may share analytics incorporating your personal information with the care home providers which provide the Services.

Law enforcement agency, court, regulator, government authority or other third party. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.

In addition to the above, we may share categories of your personal information other than health data with third parties under the following circumstances:

Independent accountants and auditors. We may share your personal information with these parties where we believe it is necessary for them to carry out accounting and audit reviews of our business.

Welltower group companies. We work closely with other businesses and companies that fall under the Welltower group family. We may share your personal information outlined above with other Welltower group companies to support our business operations and internal reporting.

Asset or share purchasers. We may share your personal information with any third party that purchases, or to which we transfer, all part of our assets or shares. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy notice.

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:

personal details (e.g. name, date of birth);

contact details (e.g. phone number, email address, postal address or mobile number);

information contained in your resume or CV, and other documents related to the application or recruitment process (e.g. previous employment, cover letter, transcripts, certifications);

educational details (e.g. educational history, qualifications, certifications, skills);

information for diversity monitoring (such as race, ethnicity, gender and sexual orientation).

citizenship or immigration information;

CCTV on our premises; and

other information you may choose to submit to us in connection with your application

(b) Information we collect from third parties:

The categories of information that we collect about you from other sources are:

publicly available professional profiles on websites or social media (e.g. LinkedIn);

professional or regulatory bodies;

information about your performance or conduct from referees, other Welltower group employees, clients or service providers you work with who may provide feedback about you; and

information about your relationship with the Welltower group of companies, including prior work experience or association you may have with any current or former Welltower employees

(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 any health issues or disabilities for the purposes of making reasonable accommodations;

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:

create and manage the recruitment system and job applications;
assess your skills, qualifications and interests against the position applied for or other positions within the Welltower group of companies;
communicate with you in relation to your application and the recruitment process;
verify your information, including through reference checks and, where applicable, background checks;
send you information about other positions which may be of interest to you;
comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies; and
deal with your enquiries and requests.

We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:

to fulfil our contractual obligations to you in connection with your employment contract with us or taking steps at your request prior to entering the contract;
to comply with our legal obligations, for example obtaining proof of your identity and right to work status to enable us to meet relevant obligations;
to fulfil our legitimate interest to ensure that we maintain accurate and comprehensive records regarding the recruitment process, to communicate with you effectively, and to preparing for and act in relation to enquiries, investigations or proceedings, by governmental, administrative, judicial or regulatory authorities, including civil litigation;
to comply with our legal obligations to you, for example health and safety obligations that we must comply with during the recruitment process, to resolve complaints and grievances; and
to protect your or another person’s vital interests, for example by providing your health information to a doctor in a medical emergency.

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:

Service providers and business partners. We may share your personal information with our service providers and business partners that perform business operations for us. For example, we partner with other companies for payroll administration, to provide insurance or other benefits, expenses and other compensation services, for IT hosting and maintenance, recruitment agencies and background screening companies, to analyse information to improve performance or for external advice provided by law firms or accountants.

Welltower group companies. We work closely with other businesses and companies that fall under the Welltower group family. We may share your personal information outlined above with other Welltower group companies for recruitment purposes, human resource management and internal reporting.

Law enforcement agency, court, regulator, government authority or other third party. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.

Asset purchasers. We may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy notice.

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.

3. Visitors to our Website

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

IP address;

Device ID, and other identifiers associated with your device;

Device type;

Device characteristics (such as operating system);

The pages you visit on our websites;

How you arrived at our websites;

Browser preferences and characteristics;

Clickstream data; and

Other information about your online activities.

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:

Analytics providers such as Google Analytics. We may share your personal information with analytics providers in order to carry out analytics of how users interact with our websites and to report usage statistics in relation to our website.
Third-party advertising networks. We may share your personal information with third-party advertising networks in order to help make the advertising you see on our website and elsewhere on the internet more relevant to you, and to measure the effectiveness of the advertising on our website.
Welltower group companies. We work closely with other businesses and companies that fall under the Welltower group family. We may share your personal information outlined above with other Welltower group companies to support our business operations and internal reporting.

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:

Maintain business records for analysis and/or audit purposes;

Comply with record retention requirements under the law;

Defend or bring any existing or potential legal claims; and

Deal with any relevant complaints.

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:

access your personal information;

rectify the information we hold about you;

erase your personal information;

restrict our use of your personal information;

object to our use of your personal information;

receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and

lodge a complaint with your local data protection authority, the Information Commissioner’s Office.

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.

7. Contact us

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