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Knightingles Healthcare > Privacy Notice

Privacy Notice

Contact details

What information we collect, use, and why

Lawful bases and data protection rights

Where we get personal information from

How long we keep information

Who we share information with

How to complain

Contact details

Post

Knightingles Healthcare, 2A Letchmore Road, Old Town, STEVENAGE, Hertfordshire, SG1 3HU, GB

Telephone

01438 723209

Email

info@knightingleshealthcare.com

What information we collect, use, and why

We collect or use the following information to provide patient care , services, pharmaceutical products and other goods:

  • Name, address and contact details
  • Gender
  • Pronoun preferences
  • Date of birth
  • NHS/HSC/CHI number
  • National Insurance number
  • Next of Kin details including any support networks
  • Emergency contact details
  • Photographs
  • Health information (including medical conditions, allergies, medical requirements and medical history)
  • Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
  • Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
  • Payment details (including card or bank information for transfers and direct debits)
  • Records of meetings and decisions
  • Call recordings
  • Information about income and financial needs for funding or personal budget support

We also collect the following special category information to provide patient care, services, pharmaceutical products and other goods. This information is subject to additional protection due to its sensitive nature:

  • Racial or ethnic origin
  • Religious or philosophical beliefs
  • Health information
  • Sex life information
  • Sexual orientation information

We collect or use the following personal information to comply with legal requirements:

  • Name
  • Contact information
  • Identification documents
  • Health and safety information
  • Financial information
  • Any other personal information required to comply with legal obligations
  • Right to work
  • Insurance details
  • Tax information
  • Safeguarding information
  • Criminal offence data

We collect or use the following personal information for recruitment purposes:

  • Contact details (eg name, address, telephone number or personal email address)
  • Date of birth
  • National Insurance number
  • Copies of passports or other photo ID
  • Employment history (eg job application, employment references or secondary employment)
  • Education history (eg qualifications)
  • Right to work information
  • Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks )
  • Security clearance details (eg basic checks and higher security clearance)
  • Business insurance for drivers Bank account information Medical information (including medical history and vaccinations)

We also collect the following special category information for recruitment purposes. This information is subject to additional protection due to its sensitive nature:

  • Racial or ethnic origin
  • Religious or philosophical beliefs
  • Health information
  • Sexual orientation information

We collect or use the following personal information for dealing with queries, complaints or claims:

  • Names and contact details
  • Call recordings
  • Witness statements and contact details
  • Relevant information from previous investigations
  • Customer or client accounts and records
  • Financial transaction information
  • Information relating to health and safety (including incident investigation details and reports and accident book records)
  • Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

  • Your right of access

You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.

  • Your right to rectification

You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.

  • Your right to erasure

You have the right to ask us to delete your personal information.

  • Your right to restriction of processing

You have the right to ask us to limit how we can use your personal information.

  • Your right to object to processing

You have the right to object to the processing of your personal data.

  • Your right to data portability

You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.

  • Your right to withdraw consent

When we use consent as our lawful basis you have the right to withdraw your consent at any time.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:

  • Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests - we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
    We have a legitimate interest in processing personal information to deliver care, including assessing needs, planning and providing care, safeguarding individuals, and communicating with patients, families and relevant professionals; this processing also supports efficient service delivery, record-keeping, quality improvement and compliance with professional standards, and we ensure it is proportionate, secure and respects individuals’ rights by using only the minimum necessary information.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

  • Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life 19 June 2026 5 sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

  • Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time
  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
    We have a legitimate interest in processing personal information to ensure we meet our legal and regulatory obligations, including those relating to health and social care provision, safeguarding, record-keeping, and accountability; this processing enables us to demonstrate compliance with applicable laws and standards while maintaining safe and lawful operations, and we ensure it is proportionate, secure and limited to what is necessary.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

  • Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for recruitment purposes are:

  • Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time
  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
    We have a legitimate interest in processing personal information for recruitment purposes to ensure we recruit suitable, qualified and safe individuals to deliver care services, including assessing applications, verifying experience and qualifications, carrying out background and safeguarding checks, and communicating with candidates; this supports safe staffing, protects those in our care, and is conducted in a proportionate and secure manner that respects candidates’ rights.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
    We have a legitimate interest in processing personal information to effectively respond to and manage queries, complaints or claims, including investigating concerns, communicating with individuals and relevant parties, resolving issues, and improving our services; this processing supports accountability, service quality and user satisfaction, and is carried out in a proportionate, secure and respectful manner.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

  • Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Where we get personal information from

Directly from you

1

Family members or carers

2

Other health and care providers

3

Social services

4

Councils and other public sector organisations

5

Social workers Occupation Therapists Community Nursing Teams General Practitioners Pharmacists Advocates

5

How long we keep information

Record type Retention Trigger Disposal method
SERVICE USER RECORDS
Adult care records (care plans, assessments, MAR, daily notes) 8 years Last contact/discharge Secure destruction
Children's care records Until age 25 (26 if treatment ended at 17) Date of birth Secure destruction
Mental health records 20 years or as NHS guidance applies Last contact Review before destruction
Safeguarding records 8 years after closure (or longer if linked to care record) Case closure Secure destruction
Incident reports 8 years Incident closure Secure destruction
Accident books (RIDDOR) 3 years Date of incident Secure destruction
Capacity assessments 8 years Last contact Secure destruction
Best Interest Decisions 8 years Last contact Secure destruction
Last contact/discharge 8 years End of placement Secure destruction
Risk assessments 8 years Last review Secure destruction
Medication administration records (MAR) 8 years End of care Secure destruction
Body maps 8 years End of care Secure destruction
Clinical photographs Same as care record End of care Secure destruction

CALL RECORDINGS

Purpose Retention
General customer service calls 6 months
Quality monitoring 6 months
Recruitment calls 6 months
Complaint investigations 6 years after closure
Safeguarding investigations 8 years (or with care record)
Clinical advice calls Form part of care record (8 years)
Emergency escalation calls 8 years
Calls involving litigation Until litigation concludes + 6 years
Police investigations Until advised by Police/Legal

CCTV

Record Retention
CCTV routine 30 days
Serious incident Until investigation complete
Safeguarding footage 8 years if retained as evidence
Police evidence Until advised by Police

STAFF RECORDS

Record Retention
Personnel file 6 years after employment ends
Right to Work documents Employment + 2 years
Recruitment unsuccessful 6 months
Interview notes 6 months
DBS certificates 6 months
DBS reference number Employment + 6 years
Occupational health 6 years after employment
Disciplinary records 6 years
Grievances 6 years
Performance reviews Employment + 6 years
Supervisions Employment + 6 years
Training records Employment + 6 years
Appraisals Employment + 6 years
Sickness records Employment + 6 years
Annual leave 6 years
Visa sponsorship records Duration of sponsorship + 1 year (minimum Home Office requirement)
COS documents Sponsorship + 1 year
Sponsor licence documents Duration of licence + 6 years

PAYROLL & FINANCE

Record Retention
Payroll 6 years
Payslips 6 years
Pension records 6 years
HMRC submissions 6 years
VAT records 6 years
Bank statements 6 years
Purchase invoices 6 years
Sales invoices 6 years
Supplier records 6 years
Expense claims 6 years
Petty cash 6 years
Annual accounts Permanently
Budgets 6 years
Financial forecasts 6 years
Audit working papers 6 years

PROPERTY

Record Retention
Lease agreements 12 years after expiry (executed as deed)
Tenancy agreements 6 years after end
Property maintenance Life of property + 6 years
Fire risk assessments Current plus previous version
Gas Safety Certificates 2 years
EICR Until superseded
Legionella 5 years
PAT testing Until next test
Asbestos surveys Life of building
DFG documentation 12 years

HEALTH & SAFETY

Record Retention
Risk assessments Current + 3 years
COSHH 40 years where exposure records apply
Fire drills 3 years
Fire alarm servicing Life of equipment + 3 years
Fire training Employment + 6 years
RIDDOR 3 years
Health & Safety inspections 6 years

GOVERNANCE

Record Retention
Board minutes Permanently
Directors' resolutions Permanently
Policies (superseded) 6 years
Procedures 6 years
Internal audits 6 years
External audits 6 years
CQC inspections Permanently
PIR submissions Permanently
Business continuity plans Superseded + 6 years

COMPLAINTS

Record Retention
Complaint files 10 years
Compliments 2 years
Ombudsman cases 10 years
Litigation 6 years after closure

INFORMATION GOVERNANCE

Record Retention
Subject Access Requests 3 years
Freedom of Information requests 3 years
Data breach investigations 6 years
DPIAs Life of processing + 6 years
Records of Processing Activities Current + 6 years
Consent forms Duration of processing + 6 years

EMAILS

Record Retention
Routine correspondence 2 years
Operational emails 6 years
Care-related emails File into care record (8 years)
HR emails File into HR record
Finance emails 6 years
Contracts Life of contract + 6 years

CONTRACTS

Record Retention
Contracts under seal (deed) 12 years after expiry
Standard contracts 6 years after expiry
Service Level Agreements 6 years
Insurance policies 6 years after expiry
Public liability claims 40 years if injury related

INSURANCE

Record Retention
Mileage logs 6 years
Vehicle inspections Life of vehicle + 2 years
MOT Life of vehicle + 2 years
Fleet maintenance Life of vehicle + 6 years

VEHICLES

Record Retention
Employer Liability 40 years
Public Liability 6 years after expiry
Motor insurance 6 years
Claims 6 years after closure

IT

Record Retention
Mileage logs 6 years
Vehicle inspections Life of vehicle + 2 years
MOT Life of vehicle + 2 years
Fleet maintenance Life of vehicle + 6 years

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

Who we share information with

Joint data controllers

We have a joint controller relationship with Lily Comms. We process your personal information with that joint controller for the following reason: We work with Lily Comms to support the provision and management of our communication systems, including telephony and related technologies. This includes the processing of personal information necessary to operate these systems, such as call data (e.g. phone numbers, call logs, and timestamps), voicemail content where applicable, and contact details used within our communication platforms. This processing enables us to make and receive calls, manage internal and external communications, and maintain service functionality. The joint processing is necessary to ensure the effective delivery, maintenance, and security of our communication infrastructure, in line with our operational and service delivery needs..

Data processors

Lily Comms

This data processor does the following activities for us: This data processor manages our IT systems.

Nourish Better Care

This data processor does the following activities for us: This data processor provides us with electronic call monitoring services including rota management. They also process information about our clients as part of that service.

Others we share personal information with

  • Other health providers (eg GPs and consultants)
  • Insurance companies, brokers and other intermediaries
  • Care providers
  • Organisations we need to share information with for safeguarding reasons
  • Emergency services
  • Professional advisors
  • Local authorities or councils
  • External auditors or inspectors
  • Organisations we’re legally obliged to share personal information with

Duty of confidentiality

We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:

- you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);

- we have a legal requirement (including court orders) to collect, share or use the data;

on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);

If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or

- If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline Number

0303 123 1113

Website

https://www.ico.org.uk/make-a-complaint

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Mail any question ? info@knightingleshealthcare.com
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