Privacy Policy
Solcom Limited (trading as Whzan)
We know that you care how information about you is used and shared, and we appreciate your trust in us to handle it carefully and sensibly. This Privacy Notice describes how Solcom Limited (trading as Whzan) collects and processes personal information through the Whzan website, tablet devices and applications that reference this Privacy Notice (together, the “Whzan Services”).
Solcom acts in two different capacities depending on the information concerned, and your rights — and who you should contact — differ accordingly:
- Part A applies where Solcom is the data controller: visitors to our website, people who contact us or request information, business and marketing contacts, and individuals who hold a direct administrative or support account with us.
- Part B applies where Solcom is a data processor: personal and health information captured within the Whzan Services in the course of your care, where the organisation responsible for your care is the data controller.
A simple guide: information about your care is covered by Part B; information about your direct dealings with Solcom (visiting our website, contacting us, or receiving our communications) is covered by Part A.
Part A — Where Solcom Acts as the Data Controller
This Part applies to visitors to our website, people who contact us or request information, business and marketing contacts, and individuals who hold a direct administrative or support account with Solcom.
Information we collect
- Contact and identification details you provide, such as name, organisation, email address and telephone number.
- Records of your correspondence and enquiries with us.
- Limited technical information needed to operate and secure our website (see Cookies, below).
In line with our policy of data minimisation, we collect only the minimum information needed for the purposes described below.
Purposes and lawful bases
We process this information for the following purposes, relying on the lawful bases shown:
| Purpose | Lawful basis |
|---|---|
| Responding to enquiries and managing communications with you | Legitimate interests |
| Managing business, procurement and contractual relationships | Contract and/or legitimate interests |
| Sending marketing communications | Consent (or legitimate interests for existing customers, within the limits of PECR) |
| Operating, securing and improving our website and services | Legitimate interests (including, where applicable, the recognised legitimate interest of ensuring the security of our network and information systems) |
| Meeting our legal and regulatory obligations | Legal obligation |
Further use of your information
Where we later use your information for a new purpose, we will only do so where that purpose is compatible with the purpose for which it was originally collected, where you have consented, or where we are otherwise permitted or required by law. Where the original basis was consent and the new purpose is not compatible, we will ask for your consent again.
Cookies
To enable our website to function, we use cookies that maintain the system state as you navigate the site. These strictly necessary cookies do not track you and do not require your consent. If we introduce analytics or other non-essential cookies, we will provide a means for you to opt out, and we will update this Notice before doing so.
Sharing your information
We do not sell personal information. We share it only:
- with service providers who process it on our behalf under written contract — our hosting provider is Microsoft Azure, using UK data centres;
- where required to comply with the law, or to establish, exercise or defend legal claims; and
- in connection with a business sale or reorganisation, subject to the protections set out in this Notice.
International transfers
All information is stored on cloud servers within the United Kingdom. We do not routinely transfer personal information outside the UK. Any transfer that did take place would be subject to the safeguards required by UK data protection law.
How long we keep it
We keep information only for as long as necessary for the purpose for which it was collected, as required by law, or as otherwise notified to you. Retention periods are set out in our internal Record of Processing Activities. Backups are overwritten on a rolling cycle and may be retained for up to one year before being overwritten.
Your rights
Subject to applicable law, you have the right to request access to, rectification of, and erasure of your personal data; to data portability; and to object to or restrict our processing. To exercise any of these rights, please contact us using the details below.
When you make a request, we may ask you for information reasonably required to confirm your identity or to locate the information you have asked about. Where we reasonably need such clarification, the time limit for responding is paused until you provide it. Our searches in response to a request will be reasonable and proportionate.
Automated decision-making
We do not make decisions about you based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.
How to complain
If you have a concern about how Solcom handles your information in its capacity as data controller, please contact us first using the details below and we will try to resolve it. You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk.
Part B — Where Solcom Acts as a Data Processor
Our role
When you receive care supported by the Whzan Services, the health or care organisation responsible for your care decides what information is collected and why. That organisation is the data controller, and Solcom processes the information only on its documented instructions, as its data processor, under a written Data Processing Agreement.
This means that, for this information, Solcom does not decide how it is used. Solcom is not the right organisation to provide you with a privacy notice about your care, to action your individual rights, or to resolve complaints about that processing — those responsibilities rest with the organisation providing your care.
Information this covers
Information captured in the course of your care, which may include identification details (such as name, date of birth, telephone number, email address and NHS Number) and health information (such as medical readings, questionnaire responses and telecare sensor data). The exact information depends on the configuration in use.
Who your data controller is
Your data controller is the health or care organisation providing your care — for example, an NHS trust or integrated care board, a local authority, or a care home. That organisation is responsible for:
- giving you the privacy information that applies to your care;
- determining the lawful basis for processing your information;
- responding to your requests to access, correct, erase, restrict or object to processing of your information; and
- handling complaints about how your care information is used.
If you wish to exercise your rights or raise a concern about your care information, please contact the health or care organisation providing your care.
How we handle requests and complaints we receive
If you contact Solcom directly about information processed under this Part, we will, in line with our Data Processing Agreement, promptly notify the relevant controller, pass on the details of your request, and assist that controller in responding within the timescales required by law. We will not respond to you directly on the controller’s behalf unless the controller instructs us to.
Where your information is held
Information is hosted on Microsoft Azure in UK data centres. Microsoft acts as our sub-processor under contract. We do not transfer this information outside the UK in the ordinary course of providing the Whzan Services.
NHS Numbers
If you are receiving care from a health or care organisation, that organisation may share your NHS Number with other organisations involved in your care, so that everyone uses the same number to identify you and can coordinate your care more closely.
Your NHS Number is obtained through an NHS service called the Personal Demographics Service (PDS). The care organisation sends basic details, such as your name, address and date of birth, to the PDS to retrieve your NHS Number, which is then stored in the case management system. This information is retained in line with applicable record-retention requirements under the Data Protection Act 2018 and the UK GDPR.
You have the right to object to your NHS Number being used in this way. This will not stop you receiving care, but it may mean the coordination benefits described above are not realised. To discuss this, contact the organisation providing your care, or contact us on 01983 817000 or at support@whzan.com, and we will pass your request to the appropriate controller.
NHS Care Identity / NHS login
If you access the service using NHS Care Identity or NHS login credentials, those identity services are operated by NHS England (formerly NHS Digital), which is the controller for the information you provide to obtain and authenticate that digital identity and uses it solely for that purpose. For that information, Solcom acts only as a processor under NHS England’s instructions. NHS England’s own privacy information applies to that identity service.
Keeping Your Information Secure
We design our systems with your security and privacy in mind. We protect information in transit using encryption, and we maintain physical, electronic and procedural safeguards around the collection, storage and disclosure of personal information — including encryption of data at rest on both the device and in cloud storage. Our procedures mean we may request proof of identity before disclosing information to you. Please help protect your information by keeping your password secure and signing out when you finish using a shared device.
Changes to This Notice
Our practices and this Notice will change over time, and we will post updates on this page. Where a change materially affects how we use information collected previously and the basis for that use is consent, we will seek your consent before applying the change.
Contact Us
For privacy-related matters, including to exercise your rights or to report a data breach, please contact our Data Protection Officer at privacy@solcom.com. For all other matters, contact our helpdesk at support@solcom.com or on 01983 817000. General enquiries: enquiries@whzan.com.