Privacy policy

Scope and overview

A privacy notice is a document which outlines how we will use information about you when we provide healthcare to you. This information is often called “personal data”. Personal data is any information about you that we may use, for example, your name, address, telephone number, details about your health or any information that may identify you. When we use the term “information” throughout this privacy notice we are talking about your personal data.

This privacy notice is issued on behalf of the ICS Group and our Group Companies. You can click on this link  to see which companies are part of our group. When we talk about “we”, “us” or “our” in this privacy notice we are referring to the ICS Group and any of our companies.

When we use your information, the organisation who is responsible for ensuring that we look after your information and only use it as you would expect is Independent Clinical Services Limited. If you have any issues or queries that you would like to raise with us, please send them to our data protection officer via:

     •   Email to: dpo@ukics.com; or
     •   writing to us at Data Protection Officer, ICSG Ltd, 223 Pentonville Road, London N1 9NG.

Our data protection officer’s job it is to make sure that we are only using your information in the way you would expect. Our data protection officer is responsible for making sure that we also look after your information. If you, your parents and/or guardian have any questions about this privacy notice, you can get in touch with them using the details above.

You also have additional rights in relation to your information.  One of these is the right to contact our regulator, the Information Commissioner’s Office (ICO), who is responsible for making sure that organisations like us comply with laws and regulations regarding the use of your information.  The ICO can be contacted via their website, www.ico.org.uk or by telephone on 0303 123 1113. If you are concerned or have any questions about how we use your information, we would really appreciate it if you would contact us in the first instance.

We regularly review this privacy notice and we will update it where necessary to give you any further information about how we are using your personal data. This version of the privacy notice was prepared on 27/08/2019.

 



  • This privacy notice covers the use of information when we are providing a healthcare service to you. For example, if you are unable to leave your house and we need to send nurses to look after you at home, we will have to use your information to make sure we look after you properly. Additionally, we may have to visit you at your place of work or your school. Again, this privacy notice will set out the rules that we have in place to make sure that we are only using your information as you would expect.


  • In 2018, a new piece of legislation, which you have probably heard about, called the General data Protection Regulation came into force.  This sets out a number of rules that we have to follow to make sure that we are complying with the law when we use your information.

    The law also says that we are only allowed to use your information if the purposes for using your information meets certain conditions. So we can provide our healthcare services to you, we process your information based on the following conditions:

       •  For the Performance of a Contract – this means that if you have asked us to provide healthcare services to you, we will need to enter into a written contract which tells you how we will provide those services to you and what information we may need from you.

       •  For our Legitimate Interests – this means that where we have to use your information, or a third party needs to use your information, then we can use the information in order to provide services to you. However, we will always ensure that this does not cause you any damage and/or distress.For example, we will always carry out an assessment to ascertain if the way in which we are using your information is in a manner which is not likely to be intrusive or unexpected.

       •  For Compliance with a Legal Obligation – this means that we can use your information because the law tells us that we must do this. Additionally, where we are using your medical data, we also have to comply with even more regulations (these are like laws but not as strict).

    These are the conditions that we rely on when we are using your information. On occasions, we may need to use your information for other purposes, but we will only do this where our use of the information is similar to the original purpose. The table below sets out what information we will use and why we use this.

    Who does this apply to? Personal data we obtain Always required? Purpose for processing Lawful basis
    Person receiving care Basic personal details: full name and what you like to be called; telephone number; email address; and address* yes      •   To care for you
         •  To let you to tell us how we can contact you
         •  To find local nurses or carers for you
         •  To confirm your identity when we speak with other relevant teams about the care we provide for you
    Performance of a Contract
    Person receiving care Next of kin contact details No      •  To contact someone in the event of an emergency
    Legitimate Interests
    Person receiving care Details of what you like to do every day and any special routines* Yes      •  To make sure that the care we offer you fits in with how you like to spend your day and we don’t miss anything that is really important to you
         •  To allow you choice in your daily routine
    Legal Obligation
    Person receiving care Details of what you can and can’t eat and what foods and drinks you like and dislike* Yes      •  To make sure you have the right food and drink to keep you healthy and to provide your care
         •  To allow you choice in your daily routine
    Legal Obligation
    Person receiving care Satisfaction Survey 
    No      •  To makes sure you are happy with the care you are receiving and to put things right if you aren’t Legitimate Interests
    Person receiving care from us or the parent or guardian Car insurance information* Yes      •  To ensure that if our workers are required to drive you or your parent/guardian’s car they are safe to do so Legal Obligation
    Person acting on behalf of the individual receiving care Basic contact details: full legal name; telephone number; email address; and postal address* Yes      •  To let you to tell us how we can contact you
         •  To communicate and manage our relationship with you
    Performance of a Contract
    Person acting on behalf of the individual receiving care Names of people living with you, including your pets* No      •  So we know who else is living in your home and may help with your care Legitimate Interests
    Private patients - person receiving care Financial information No      •   So we can be paid for the care we provide Performance of Contract

  • When you provide us with information, on most occasions you have a choice as to whether or not you provide this information to us. However, because we are providing healthcare services to you, we may need to have that information to provide those services. Without it, we will not be able to provide the care and services you required. Where this is the case the answer in the always required section above will be “yes”.


  • When we provide healthcare services to you, we will need to process information relating to your health. This is often referred to as “special data”. This information requires a higher level of protection and the law says that we must comply with additional requirements when using special data.
    We will always tell you when we need to process special data and if you are providing it to us on any forms or documents, we will always tell you how we will use it at the time it is collected. If you have any questions when you are filling out these forms or providing any special data to us, please feel free to ask us any questions.


  • When we are providing healthcare services to you, it may be necessary for us to obtain further information about you to make sure that you are being treated properly. We have set out below, details of the sources that we will use to obtain this information:

         •  Our workers that care for you – we will need to ask our workers for information relating to the care that they have provided to you and about any issues or concerns that have relating to your health and wellbeing.
         •  Other healthcare professionals – we will need to obtain information that will assist us to deliver the best care for you, for example, information about accessibility requirements and/or your preference in relation to treatments.
         •  Regulatory bodies – we may need to get information from regulatory bodies for example, social services, to ensure that we can legally provide care to you.
         •  Law enforcement agencies – in some instances we may have to get additional information from the police to ensure that we are complying with any requirements laid down by them.


  • In certain instances, we are required to share information across our Group of companies, as are listed here. The purposes for sharing the information are as follows:

         •  To make sure that we can provide a full care service to you by finding suitable carers and to ensure we meet any legal requirements.


  • When we provide healthcare to you, we may be required to share information with other people or organisations. This is to ensure that you receive adequate care and that your best interests are met. We share your information with the people and organisations below:

    People or organisations Purpose for sharing your information
    Other healthcare professional that provide care for you This lets everyone involved in your care work together and allows us all to respond to any changes in your health/care as best we can
    Department of Education (if you go to school) To allow you to go school
    Local authorities helping with your care This allows everyone involved in your care to work together and allow us all to respond to any changes in your care
    Commissioners who may be in charge of your care This lets everyone involved in your care work together and allows us all to respond to any changes in your health/care as best we can
    People who will offer us advice on our services, including accountants and/or solicitors To ensure that we are acting in your best interest and within the law
    Other recruitment agencies that help us find carers and nurses for you To make sure you always have someone who can care for you, even in emergencies
    Companies who help us run our business or service to you To help make sure we have all the support and equipment we need to provide your care
    Regulatory or law enforcement agencies to make sure we are doing the right things To ensure that we are acting in your best interest and within the law

    When we share your information with any of the people or organisations above and they are processing it because we have asked them to, we always make sure we tell them what to do with your information and that we have an adequate contract in place.


  • We will only use and keep your information for as long as we need to so that we can provide our healthcare services to you. This does not mean that we will keep your information forever. We are required to keep some information for longer than the time during which we provide healthcare services to you. This is to ensure that we can demonstrate that when we provided healthcare services, we were complying with the law. For further information about how long we keep your information, please contact our data protection officer at dpo@ukics.com


  • As your healthcare care is based in the UK, we will generally keep your information within the UK. If for any reason we are required to send your information outside of the EEA, for example to our group companies in America and/or Australia etc., or we use a third party who is based outside of the EEA, we will always ensure that we have adequate safeguards in place. This means we will ensure that:

         •   We only send your information to countries that will look after your information in a similar way to how we do so within the EEA; and/or
         •  We will put in place an appropriate contract which includes rules that require the organisation to look after your information.

    If you would like more information about how we look after your information when we transfer this outside of the UK, please contact us at dpo@ukics.com


  • We have a number of different measures in place to safeguard your information. This means that, for example, we ensure that only those individuals who need to have access to your information are allowed to view or use this. Additionally, we only allow people to view or use your information if they have had relevant data protection training.


  • You have a number of rights in relation to how we use your information. These are as follows:

        a)   Your right to request access to your personal information – you have the right to know if we are using your information, a right to see a copy of the information we hold for you and a right to be provided with additional information, for example, about how and why we are using your information and who it is being shared with.
       b)   You have the right to request that any inaccurate data is amended – if you think that any of the information that we hold about you is wrong or incomplete then you have the right to tell us and we have to ensure that the information we have is reviewed and if necessary, amended to ensure it is correct.
        c)   You have the right to ask for your information to be deleted – in certain circumstances, you can ask us to delete your information where there is no good reason for us to hold or use this anymore, where:
         •  we are using your information because you provided us with your consent to use it in this way; or
         •   where you have challenged our use of your information and there are no good reasons for us process your information.
    This does not apply to all of your information, as we may need to still keep your information, for example, to comply with laws.
        d)   You have the right to request restriction of processing your information – this right allows you to ask us to put processing on hold so:
         •   we can establish if the information that we have about you is correct;
         •   to investigate any objection you have made about the use of your information;
         •   or if we have no justification for keeping it any longer you may ask us to put the processing on hold, but retain the information in case you need this, for example, for legal reasons.
        e)  You have the right to have your information sent to another organisation – in certain circumstances, you have the right to get your information from us in a way that is accessible and machine-readable, and you also have the right to ask us to transfer your information to another organisation. This does not apply to all of your information, only information that you have provided to us and which is held electronically. We only have to comply with this right if it is technically feasible to provide this information in a commonly used format, for example, a cvs file.
        f)  You have the right to object to the processing of your information – you have the right to tell us about any concerns regarding the processing of your information and to ask us to stop using your personal data. We may have to still process your information if we have to in order to provide healthcare to you during this period, however if we are using your information for marketing purposes, we will stop doing this if you object.
        g)   You have rights in relation to automated decision making and profiling – if we make decisions about you without people being involved, this is called ‘automated processing’. You have a right:
         •   not to be subject to automated processing;
         •   to understand any reasons or decisions behind automated processing; and
         •   the right to object to profiling.


    When we provide care to you, we do not use automated decision-making processes or use your information for profiling purposes.


  • If you are under the age of 13, all of the above rights will apply to you.

    Parents and/or guardians who have parental rights for you can exercise your rights on your behalf if you are not able to do so. This may occur when you do not fully understand your rights. If you are able to exercise your rights, we will deal directly with you unless you tell us you would like us to speak to your parent and/or guardian.

    If you would like to exercise any of these rights, or want somebody to do so on your behalf, please email us at dpo@ukics.com. In most cases we will deal with your request as soon as possible and at the latest, within one calendar month of the request. If we need to extend the time period for responding to your request, we will let you know within the one-month period.

    Please note that we do not charge a fee for any such requests, unless there are really exceptional circumstances.




If you would like to exercise any of these rights, please email dpo@ukics.com. In most cases we will deal with your request as soon as possible and at the latest within one calendar month of the request. If we need to extend the time period for responding to your request, we will let you know within the one-month period. We do not charge a fee for any such requests, unless there are exceptional circumstances.