What information does this Privacy Policy apply to?

This Privacy Policy applies – both to the individual who is being cared for with the assistance of Encircle (the “Cared For”) and the individuals who use the Encircle App to provide care (either the primary “Carer” or any member of the “Care Circle”) and anyone else whose personal information we may capture if they express an interest in the service or otherwise engage with the service.

Please read this Privacy Policy carefully, and if you are a Carer please make sure your Cared For is familiar with it and knows where to find it. We will use your personal information (whether you are the Carer, a member of the Care Circle or the Cared For) in accordance with this Privacy Policy in order to provide the Encircle service.

We have a separate Privacy Policy that sets out how we collect, store and use your personal information if you purchase any other BT products or services, which you can find on our website www.bt.com. For our collection and use of information collected using cookies and similar online technology please see our cookie policy which can be found here.

What is Encircle?

Encircle is a service designed to allow individuals with mobility or care needs live a more independent life, by giving their Carer the reassurance that they are maintaining their normal daily habits and routines. This is done through a system of smart devices, namely: motion sensors, smart plugs, door sensors (the “Sensors”) and a Help Button - together the “Devices” - installed in the Cared For’s home. Data from the Devices will result in notifications being sent to the Carer (and other members of the Care Circle, where they are registered) informing them of movements and activities in the Cared For’s home.

A bit of background detail first

Encircle is a service that is provided by BT. In this privacy policy, “We”, “our”, “BT” or “us” means British Telecommunications Plc. BT’s company no. is 04190816. BT’s registered office is BT Centre 81 Newgate Street, London EC1A7AJ

A few terms that need explaining:

  • Where we use the word “process” throughout this Privacy Policy, we mean the ways in which we use your personal information.

  • When we say “control” we mean take responsibility for your personal information.

  • Where we talk about our “lawful basis” for doing something we mean the reason that we are legally able to process your personal information.

  • Where we talk about “special category personal data” we are talking about information that is considered particularly sensitive such as data revealing your racial or ethnic origin, political opinions, religious beliefs or health data.

Personal information that we process:

Whether you are a Carer, a member of the Care Circle, a Cared For or a potential customer who has expressed an interest in the service, we will need to process certain personal information to deliver Encircle, this largely depends on what features of the service you use – for example, the Help Button uses different information to the Reminders feature.

When setting up Encircle, or at a later date, you may choose to use all or only some of the features – so the nature and volume of personal information we process will vary. Depending on your role (as a potential customer, Carer, Cared For, Care Circle member, or someone who is otherwise engaged with Encircle), the processing relevant to you is set out in the table below.

A few terms to explain first:

  • Early Access Sign Up Data: Including your name, contact details and date of birth and any other optional information you choose to provide in answer to the questions asked in the Early Access Sign Up form which includes the capture of special category personal data;

  • Registration Data: If you are a Carer or member of the Care Circle including your name and contact details (such as email address, postal address and phone number) and note any marketing consent you give us.

  • Payment Data: if you are the account holder, your payment details;

  • Delivery Data: We will need to process the name and address provided in order to ship the Devices to the address provided;

  • Account Data: If you are the Carer or a member of the Care Circle we will need to process your login details including your BTID and password details. We will also need to know your device details in order for the App to be installed on your phone. If you are the Cared For your name and phone number may be included by the Carer as part of the account set up;

  • Sensor Data: any personal information captured by the sensors installed in the Cared For’s home. We will also note if the Sensors don’t appear to be working;

  • Notification Data: The data from the Sensors will be analysed and will result in Notifications being sent to the Carer or members of the Care Circle highlighting patterns in the Cared For’s home and inferences made. The Notification Data results in notifications being sent to the devices of the Carer and Care Circle member;

  • Reminder Data: Any personal information that the Carer or member of the Care Circle inputs into a reminder set on the App;

  • Medical Data: If medication reminders are included in a Reminder this may contain health information related to the Cared For – this is considered special category personal data;

  • Mood Data: The Carer may choose to input the Cared For’s mood into the app when using Encircle. If they choose to use this feature we will need to process this information;

  • Customer Services Data: If you interact with the Encircle Customer Service team we will need to take notes and store a record of any interactions;

  • Survey Data: We may send out surveys to better understand how Encircle is working and to know if there are areas to develop. We will store responses to these survey;

  • R&D Data: We may use all personal information processed through our provision of Encircle to find ways to improve and develop the service. Where possible we will do this on the basis on anonymised and aggregated data, however sometimes we may use information that remains personally identifiable; and

  • Help Button Data: If you take the optional Help Button, we will need to register the Cared For’s full name and contact details to ensure that we can get in touch with them or with emergency services in the event it is pushed.

How we process that personal information:

We have included below details demonstrating all of the processing activities we undertake in order to provide Encircle to you as well as the personal information used for that processing, the purpose and the lawful bases for using it.

We rely on one of five legal bases for processing your personal information:

  1. If we need to process your personal information in order to provide the service to you, we rely on contractual necessity.

  2. When we are processing either the Cared For’s health data or any individual’s data to send you direct marketing we will ask for your consent. We explain below how this consent can be withdrawn.

  3. Having assessed whether our use would be fair and not override your right to privacy, we may come to the view that it falls within our legitimate interests to use the information (for example, to improve and develop Encircle or to process the data of the Cared For or Care Circle members where we have no contract).

  4. When it comes to the Help Button we rely on vital interests as we may process this data to assess an urgent situation and provide emergency assistance to the Cared For, in a non-urgent situation we rely on legitimate interests.

  5. We may also have to process and share data to fulfil our legal obligations.

Purpose of processing

Who: Potential customer/Carer

Purpose of the processing: We capture the Early Access Sign Up Data prior to an account being set up to enable us to contact potential customers and grant early access. We also use this data to ensure that potential customers who are looking to gain access to the early access programme represent a diverse audience.

Lawful Basis: (a) Contractual Necessity (for the contact details and confirmation of interest); (b) Consent (for those questions where the answers are optional including all those questions involving special category data; and (c) Legitimate Interests (for your date of birth) (being our ability to grant early access to a representative audience).

Who: Carer; Care Circle member; Cared For

Purpose of the processing: We capture the Registration Data and Account Data of the Carer and Care Circle members and, if provided during onboarding, the Cared For to facilitate the registration and manage our contract with you, to provide you with the Encircle App and to ensure compliance with Encircle’s terms and conditions.

Lawful Basis: (a) Contractual Necessity; and (b) Legitimate Interest (being the ability to develop our service and build a better understanding of what our customers want).

Who: Carer; Cared For; Third party

Purpose of the processing: We capture the Delivery Data in order to deliver the Devices to the correct location. The Carer will determine whose personal information is provided as the Delivery Data – and it may be theirs the Cared Fors or any other third party whose name and address they select (such as the Cared For’s neighbour).

Lawful Basis: Contractual Necessity

Who: Carer

Purpose of the processing: We will process your contact details (email, address, phone number) to send you marketing communications, where we have your consent to do so.

Please note, we may contact you on the basis of a marketing permission we already hold for you as you are an existing customer of ours – here we may have sought your consent or simply gave you the opportunity to opt-out of marketing on sign-up (and continue to do so via our unsubscribe channels).

Lawful Basis: Consent

Who: Carer

Purpose of the processing: We will process your Payment Data in order to facilitate the purchase

Lawful Basis: Contractual Necessity

Who: Cared For

Purpose of the processing: We process Sensor Data to inform us of what motion has been detected in the Cared For’s home that needs to be notified to the Carer or other members of the Care Circle.

Lawful Basis: Legitimate Interests (being the provision and improvement of the Encircle service and signaling the wellbeing status of the Cared For through motion sensors).

Who: Cared For

Purpose of the processing: We process Notification Data to ensure that the Sensor Data is appropriately notified to the Carer and other members of the Care Circle.

Lawful Basis: Legitimate Interests (being the provision and improvement of the Encircle service and signaling the wellbeing status of the Cared For through motion sensors).

Who: Cared For

Purpose of the processing: We process the Reminder Data where a reminder has been programmed to be sent to the Cared For.

Lawful Basis: Legitimate Interests (being the provision and improvement of the Encircle service and signaling the wellbeing status of the Cared For through motion sensors).

Who: Cared For

Purpose of the processing: Where the reminder is in relation to medication, this may mean that we are required to process Medical Data (depending on what level of detail is included).

Lawful Basis: Explicit Consent (provided by the Cared For during the onboarding).

Who: Cared For

Purpose of the processing: If the Carer inputs the mood sore of the Cared For into the app we will process this Mood Data.

Lawful Basis: Legitimate Interests (being the provision and improvement of the Encircle service and signaling the wellbeing status of the Cared For through motion sensors).

Who: Carer; Care Circle member; Cared For

Purpose of the processing: In the event that someone contacts customer services we will store information regarding the interaction including the email exchange and any notes taken (the Customer Services Data) to keep a record and to ensure that any issues are dealt with or improvements made in response to the concern (where it is in our legitimate interests to do so).

Lawful Basis: This may be done under (a) Contractual Necessity; or (b) Legitimate Interest (being the provision of and improvement of the Encircle service, signaling the wellbeing status of the Cared For and ensuring BT’s compliance and ability to respond to complaints and legal claims), depending on the nature of the call.

Who: Carer; Cared For

Purpose of the processing: We may send out surveys to Carers and Cared Fors to gain insights that enable us to develop and improve Encircle. These will always be optional. Any responses will be considered Survey Data.

Lawful Basis: Legitimate Interests (being the development and improvement of the Encircle service).

Who: Carer; Care Circle member; Cared For

Purpose of the processing: R&D Data is important for us to be able continually improve and develop this service and others for you and future customers. Market development is one of the best ways of ensuring a service is developed to be the best fit for our customers. Where possible we will analyse this data in an anonymized form.

Lawful Basis: Legitimate Interest (being the development and improvement of the Encircle service).

Who: Cared For

Purpose of the processing: If the Cared For presses the Help Button at any stage, we will need to use the Help Button Data to get in touch and ensure everything is ok. In the event that it is not ok, we will need to continue to use the Help Button Data in order to inform emergency services that there is a problem.

Lawful Basis: (a) Legitimate Interests (being the provision of the Encircle service and ensuring the wellbeing of the Cared For); and (b) Vital Interests.

Who: Carer; Care Circle member; Cared For

Purpose of the processing: We may be required to use any or all of the data sources available to us if required to by government, local authority or law enforcement agencies.

Lawful Basis: Compliance with a legal obligation.

Data Subject Rights: rights you have in relation to our use of your personal information

Because we store data in relation to Encircle separately to other BT plc customer personal information we manage and respond to Encircle data subject rights separately. For data subject rights requests relating to personal information processed by us for other BT services, please see the BT Privacy Policy on BT.com.

You can ask us to correct, complete, delete, port, share, limit or stop using certain personal information we hold about you. You can request this by contacting us at encircle.support@bt.com. Depending on how we have received the data, and the lawful basis we rely on for processing, we may not have to comply with the full request, but we will let you know if this is the case.

If you have any questions in relation to your rights please contact the email address above.

We’ll always try to help you with your request but we can refuse if we believe there is an exemption under UK law, for example if it infringe the privacy rights of others or the law prevents us. We have to complete your request free of charge, we are allowed to reject requests if:

  • they’re repetitive;

  • you don’t have the right to ask for the information; or

  • the requests made are manifestly excessive.

If that’s the case, we’ll explain why we believe we don’t have to fulfil the request.

Withdrawing consent

If we’ve asked for your consent to use certain information you can withdraw that permission at any time.

For the Cared For, this means you need to withdraw your consent to Medical Data processing by requesting that your Carer no longer includes medical data in the reminders they send you when using Encircle.

For the Carer - to withdraw your consent to us processing the special category personal data contained in the Early Access Sign Up form, please contact us at encircle.support@bt.com. For withdrawing consent to direct marketing, please see the section on direct marketing below.

Who do we share your personal information with, why and how?

When we use other service providers

We use other service providers to carry out services on our behalf or to help us provide services to you. Where we use another organisation, we still control your personal information and we have strict controls in place to make sure it’s properly protected. We use other service providers to assist us with the following:

  • providing customer-service, marketing (where you have said it is ok), infrastructure and information-technology services;

  • improving the service;

  • analysing and improving the information we hold (including about your interactions with our service); and

  • running surveys.

With government bodies and law-enforcement agencies

We may also share your personal information with government bodies and law-enforcement agencies if legally required to do so, without your consent.

The countries we share personal information to

We primarily store your personal information in the UK however we may also from time to time use service providers who will process your personal information overseas to assist us, for example we use Google (who process data in the US) to assist us with sending notifications. We’ve got measures in place to ensure that this is done safely.

How do we protect your information?

We have strict security measures to protect your personal information. We check your identity when you get in touch with us, and we follow our security procedures and apply suitable technical measures, such as encryption, to protect your information.

How long do we keep your personal information?

For Encircle we’ll keep:

  • your contact details on file while you’re one of our customers or user of our service, and for six years after;

  • Notification Data for 6 months;

  • Sensor Data for 6 months;

  • Reminder Data for 6 months; and

  • details relating to any complaint, correspondence or dispute for six years after it was closed.

In other cases we’ll store personal information for the periods needed for the purposes for which the information was collected or for which it is to be further processed (details of which are set out in our retention policies). And sometimes we’ll keep it for longer if we need to by law. Otherwise we delete it.

What happens if you don’t provide your personal information?

If you don’t provide us with your personal information when we ask for it we may not be able to continue providing Encircle to you. For example, as a Carer if we do not have your contact details we will no longer be able to grant you access to your account.

How to contact us

We’re always interested in hearing your questions and comments about our Privacy Policy. Here’s where you can find out how to contact us if you need to.

For any information on your data subject rights or other general queries please contact us at encircle.support@bt.com.

You can get in touch with BT’s data-protection officer by email cpo@bt.com or write to the address below at:

PO Box 2681

BT Centre

81 Newgate Street

London

EC1A 7AJ

If you want to make a complaint about how we have handled your personal information, please contact our data protection officer who will investigate the matter and report back to you. If you are still not satisfied after our response or believe we are not using your personal information in line with the law, you also have the right to complain to the data-protection regulator in the country where you live or work. For the UK, that’s the Information Commissioner. Please reference the Encircle service in your message so we can best manage and respond to your query or complaint.

How will we tell you about changes to this policy?

We will only use your personal information for the purposes we have set out in this Privacy Policy. We can only change the purpose we use it for without telling you if that reason is compatible with the purposes set out in this Privacy Policy. If for any reason this Privacy Policy is materially updated we will inform you if you are a Carer or member of the Care Circle. Once we have informed you, you to make sure your Cared For is also made aware of any updates.

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