Specialist Care Services customer privacy notice

Registered name: SCS Hotline Ltd.

This privacy notice tells you what to expect us to do with your personal information.

  • 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: Specialist Care Services, 45-49 High Street, Harefield, UXBRIDGE, Middlesex, UB9 6BY, GB

Telephone: 01895 824242

Email: office@specialistcareservices.co.uk

Managing Director: Michaela Green

Data Protection Officer and Caldicott Guardian: Stella Peat

Roles and Responsibilities of the Caldicott Guardian

Specialist Care Services follows the guidance on roles and responsibilities issued by the National Data Guardian. Supported by Specialist Care Services, the Caldicott Guardian will:

  • Ensure confidential information about Service Users is used ethically, legally, and appropriately.

  • Have Involvement with Service User complaints.

  • Involvement in data breach investigations.

  • Promote the Caldicott Principles and good information governance throughout Specialist Care Services, using the principles to encourage and facilitate decisions in the best interests of Service Users and their care and support.

  • Uphold the Caldicott Principles, ensuring at all times that Specialist Care Services uses and shares information in line with the common law duty of confidentiality, data protection law and human rights.

  • Ensure that information sharing is safe and effective, in line with the seventh Caldicott Principle.

  • In addition to the Caldicott Principles, the Caldicott Guardian must also take account of the codes of conduct provided by professional bodies.

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

·   Hospital 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

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

·   Racial or ethnic origin

·   Religious or philosophical beliefs

·   Trade union membership

·   Health information

·   Sexual orientation information

We collect or use the following personal information for the prevention, detection, investigation or prosecution of crimes:

·   Video recordings of private or staff only areas (including staff rooms, offices, surgical areas, consultation areas and outside spaces to which only staff or patients have access)

·   Witness statements and contact details

We also collect the following information for the prevention, detection, investigation or prosecution of crimes:

·   Racial or ethnic origin

·   Religious or philosophical beliefs

·   Trade union membership

·   Health information

·   Sexual orientation information

We collect or use the following information for safeguarding or public protection reasons:

·   Name, address and contact details

·   NHS/HSC/CHI number

·   Hospital number

·   Emergency contact details

·   Photographs

·   Health information (including medical conditions, allergies, medical requirements and medical history)

·   Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions)

·   Relevant information from previous investigations

·   Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)

·   Records of meetings and decisions

We also collect the following information for safeguarding or public protection reasons:

·   Racial or ethnic origin

·   Religious or philosophical beliefs

·   Trade union membership

·   Health information

·   Sexual orientation information

We collect or use the following personal information for patient app or portal functionality:

·   Names and contact details

·   Addresses

·   Medical history

·   Account information, including registration details

·   Information used for security purposes

We also collect the following information for patient app or portal functionality:

·   Racial or ethnic origin

·   Religious or philosophical beliefs

·   Trade union membership

·   Health 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

·   Insurance details

·   Safeguarding information

·   Criminal offence data

We also collect the following information to comply with legal requirements:

·   Racial or ethnic origin

·   Religious or philosophical beliefs

·   Trade union membership

·   Health information

·   Sexual orientation information

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)

We also collect the following information for recruitment purposes:

·   Racial or ethnic origin

·   Religious or philosophical beliefs

·   Trade union membership

·   Health information

·   Sexual orientation information

We collect or use the following personal information for information updates, marketing or market research purposes:

·   Names and contact details

·   Address

·   Marketing preferences

·   Website and app user journey information

·   Personal information used for administration of the research

·   Personal information used for medical investigations

·   Records of consent, where appropriate

·   Information relating to the national data opt-out

We also collect the following information for information updates, marketing or market research purposes:

·   Racial or ethnic origin

·   Religious or philosophical beliefs

·   Trade union membership

·   Health information

·   Sexual orientation information

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

·   Names and contact details

·   Address

·   Account information

·   Purchase or service history

·   Video recordings of public areas

·   Audio recordings of public areas

·   Video recordings of private or staff only areas

·   Audio recordings of private or staff only areas

·   Call recordings

·   Dashcam footage - outside vehicle

·   Dashcam footage - inside vehicle

·   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

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

·   Racial or ethnic origin

·   Religious or philosophical beliefs

·   Trade union membership

·   Health information

·   Sexual orientation information

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.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below.

 

  • 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.

  • 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 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 give 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.

·   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 the prevention, detection, investigation or prosecution of crimes are:

·   Consent - we have permission from you after we give 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.

·   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 safeguarding or public protection reasons are:

·   Consent - we have permission from you after we give 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.

·   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 patient app or portal functionality are:

·   Consent - we have permission from you after we give 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.

·   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 to comply with legal requirements are:

·   Consent - we have permission from you after we give 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.

·   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 give 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.

·   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 base for collecting or using personal information for information updates, marketing or market research purposes are:

·   Consent - we have permission from you after we give 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.

·   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 dealing with queries, complaints or claims are:

·   Consent - we have permission from you after we give 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.

·   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

·   Regulatory authorities

·   Family members or carers

·   Other health and care providers

·   Social services

·   Charities or voluntary sector organisations

·   Councils and other public sector organisations

·   Relevant regulatory authorities

·   Medical Professionals

Data Security

Specialist Care Services will take steps to ensure that the personal data it processes is secure, including by protecting the personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage.

Specialist Care Services understands that all health and care organisations, as detailed below, are required to comply with the Data Security and Protection Toolkit. Compliance with the Data Security and Protection Toolkit facilitates compliance with UK GDPR.

Specialist Care Services understands that all organisations that have access to NHS patient data and systems must use the Data Security and Protection Toolkit to provide assurance that they are practising good data security, and that personal information is handled correctly.

Specialist Care Services will implement and embed the use of policies and procedures to ensure that personal data is kept secure. The suggestions below apply in addition to the steps Specialist Care Services is required to take pursuant to the Data Security and Protection Toolkit, if the toolkit applies to Specialist Care Services.

Specialist Care Services will bear in mind the following principles when deciding how to ensure that personal data is kept secure:

  • Confidentiality - ensuring that personal data is accessible only on a need-to-know basis

  • Integrity - ensuring that there are processes and controls in place to make sure personal data is accurate and complete

  • Availability - ensuring that personal data is accessible when it is needed for business purposes of Specialist Care Services

  • Resilience - ensuring that personal data is able to withstand and recover from threats.

For paper documents, these will include where possible:

  • Keeping the personal data in a locked filing cabinet or locked drawer when it is not in use

  • Adopting a "clear desk" policy to ensure that personal data is not visible or easily retrieved

  • Ensuring that documents containing personal data are accessible only by those who need to know/review the documents, and the personal data contained within them

  • Redacting personal data from documents where possible

  • Ensuring that documents containing personal data are placed in confidential waste bins or shredded at the end of the relevant retention period

  • Minimising the transfer of personal data from outside of business premises and, where such transfer cannot be avoided, ensuring that the paper documents continue to be kept confidential and secure.

 

For electronic documents, the measures taken by Specialist Care Services will include where possible:

  • Password protection or, where possible, encryption

  • Adopting a 'clear screen' policy where users lock screens when they are away from their computers

  • Ensuring that documents containing personal data are accessible only by those who need to know/review the documents, and the personal data contained within them

  • Ensuring ongoing confidentiality, integrity and reliability of systems used online to process personal data (this may require a review of IT systems and software currently used by Specialist Care Services)

  • The ability to quickly restore the availability of and access to personal data in the event of a technical incident (this may require a review of IT systems and software currently used by Specialist Care Services)

  • Taking care when transferring documents to a third party, ensuring that the transfer is secure, and the documents are sent to the correct recipient

Specialist Care Services will ensure that all business phones, computers, laptops and tablets are password protected.

Specialist Care Services will encourage staff to avoid storing personal data on portable media such as USB devices. If the use of portable media cannot be avoided, Specialist Care Services will ensure that the devices it uses are encrypted or password protected and that each document on the device is encrypted or password protected.

How long we keep information

The Data Protection Officer at Specialist Care Services is Stella Peat

Archiving

  • Records will be archived throughout the year as they become inactive and reviewed on an annual basis.

  • For all health records (except those relating to children) the archive year is the calendar year in which the last entry was made. For example, a record with the last entry during April 2017 with an 8-year retention period will be due for review in January 2025.

  • For financial and some administrative records, it is more appropriate to archive by financial year (FY)

  • i.e. 1st April to 31st March. Boxes of such records will be marked with the financial year (e.g. FY 2006- 7).

  • Miss Michaela Green will keep a detailed log of the information that has been archived with commercial storage, including identifying retention periods. When records stored commercially have met their retention period, Miss Michaela Green must review the information that has met the retention period. If it is deemed that it is no longer required and can be destroyed, Miss Michaela Green will contact the storage company and request that they securely destroy the records and issue a certificate of destruction. A copy of the certificate will be sent to Specialist Care Services.

Retention Schedules

  • Employment, administration and Service User records will be retained in line with the Records Management Code of Practice 2021 and the ICO Employment Practices Code of Practice. Specialist Care Services will ensure that, where there are deviations from this schedule because of local, contractual or insurance requirements, the Data Subject is made aware of how their data will be processed and fair processing notices will be issued in line with UK GDPR requirements

  • Records in relation to financial administration, insurance, tax and payroll will be stored in line with HM Revenue and Customs (HMRC) Requirements and the Companies at Specialist Care Services will seek advice on retention schedules to reflect the requirements of the business.

Retention End Dates

·       All documents archived will be checked for retention and dates by an authorized individual and destroyed in a secure and confidential manner.

  • Destruction Certificates, Electronic Metadata destruction stubs, or records of clinical information that had previously been held on destroyed physical media, will be kept for 20 years.

  • If any record is retained beyond the minimum retention period designated in the Retention Schedule, the reason for retention must be documented, including a date for review of this decision. On review, the retention decision must either be re-applied with a further review date set, or the record destroyed as appropriate.

  • Records stored on the premises of Specialist Care Services must be reviewed at least annually (usually in January or April) to identify those records whose retention period has expired. Stella Peat will authorise disposal.

Disposal of Documents

  • Any document which may identify or allow the identification of any person and/or contains personal information must be shredded before disposal.

  • Where Specialist Care Services does not use an external organisation to confidentially destroy documents, a cross-cut shredder method of disposal or a fine cut single pass shredder must be used.

  • A shredder must be supplied at all locations within Specialist Care.

  • Services where documentation is separated out for disposal, in order to reduce the risk of whole stored documents being incorrectly disposed of whilst in transit.

  • Any third-party undertaking document archiving and disposal must be briefed in writing as to the requirements for disposal and Specialist Care Services must follow a due diligent process, to ensure that confidential information is transported and disposed of correctly.

  • Destruction certificates will be retained to provide legal proof of destruction, in case the records are subsequently requested for disclosure, litigation purposes or under Freedom of Information or Data Protection legislation.

The following will be recorded:

  • A list of the records destroyed

  • When this took place

  • The name of the person who authorised the destruction

  • Who carried out the process, and

  • The reason for the destruction

Disposal of Electronically Stored Data

  • Computer hard drives, which may contain personal information, must be wiped clean before being disposed of or sold, using appropriate “shredding” software. Deleting files or routine formatting will not safeguard sufficiently from the retrieval of data.

  • Other data storage media which may contain personal information (such as memory sticks) must have the data overwritten in a manner that fills the drive before disposal or sale, preferably using specialist software.

  • Optical storage media which may contain personal information, such as CDs and DVDs, must be physically destroyed before disposal.

  • Magnetic storage media which may contain personal information, such as tapes, must be physically destroyed before disposal.

Who we share information with

Specialist Care Services is the data controller of the personal data you provide. We have appointed Stella Peat as Data Protection Officer, and they will have day-to-day responsibility for ensuring that we comply with the Data Protection Legislation and for dealing with any requests we receive from individuals exercising their rights under the Data Protection Legislation.

The data processor processes personal data on behalf of Specialist Care Services (the controller). The data processor is a third-party external to Specialist Care Services and shall not process data except on instructions from the controller, unless required by domestic law.

This data processor does the following activities for us:

Vivo IT - Manages IT systems.

Payroll company

Carebeans – Software company based in the UK. Supports SCS with care planning, management software and mobile applications.

Others we share personal information with:

·   Other health providers (eg GPs and consultants)

·   Care providers

·   Organisations we need to share information with for safeguarding reasons

·   Emergency services

·   Legal bodies or authorities

·   Local authorities or councils

·   Relevant regulatory authorities

·   External auditors or inspectors

·   Organisations we’re legally obliged to share personal information with

·   Current employees

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.

National data opt-out

We comply with England’s national data opt-out because we’re using confidential patient information for purposes beyond individual care. To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters

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

Last updated

25th June 2025.