Privacy Notice

1. Introduction

This Privacy Policy applies to individuals who engage with Crossroads Caring for Life Ltd in a non-employee capacity. This includes:

  • Individuals we support and their carers or representatives

  • Suppliers and contractors

  • Job applicants and candidates

We are committed to protecting your personal data and handling it with transparency and care. This policy explains what personal data we collect, why and how we use it, and your rights under the UK GDPR and the Data Protection Act 2018 (“Data Protection Legislation”).

2. Who We Are

Crossroads Caring for Life Ltd is the data controller for the purposes of data protection legislation.

Registered Manager & Privacy Contact:

Josephine Paice

Email: info@crossroadshn.org.uk

3. What Personal Data

We Collect We collect and process different types of personal data depending on our relationship with you.

A. Individuals We Support and Their Carers

We may process:

  • Identity Data: Name, title, date of birth, gender, marital status

  • Contact Data: Address, phone number, email

  • Health and Social Care Data (special category): Medical records, care plans, disability details

  • Equality & Diversity Data: Ethnicity, religion, sexual orientation (where necessary)

  • Financial Data: Bank details (if private payments apply)

Lawful bases:

  • Article 6(1)(b) – performance of a contract

  • Article 6(1)(c) – legal obligation

  • Article 6(1)(f) – legitimate interests (e.g., care coordination)

  • Article 9(2)(h) – provision of health or social care services

B. Suppliers / Contractors

We may process:

  • Identity and contact data

  • Financial and transaction details (if an individual/sole trader)

Lawful bases:

  • Article 6(1)(b) – contract performance

  • Article 6(1)(f) – legitimate interest in maintaining business relationships

C. Job Applicants

We may process:

  • Identity and contact data

  • Work experience, CVs, references, qualifications

  • Sensitive data (e.g., DBS disclosures, health info) if required for safeguarding

Lawful bases:

  • Article 6(1)(b) – contract performance

  • Article 6(1)(f) – legitimate interest in recruitment

  • Article 9(2)(b) or 9(2)(g) – employment and safeguarding obligations

4. How We Collect Personal Data

We may collect your data:

  • Directly from you (forms, calls, visits)

  • From other professionals (GPs, social workers)

  • From job applications or recruitment agencies

  • Via our care planning software (see below)

5. Electronic Care Planning Systems

We use secure, cloud-based systems to manage your care:

  • Nourish Care – Data stored on AWS servers in Ireland (EEA)

  • PASS for Care – Data stored predominantly in the UK (adequate under GDPR)

Access is limited to authorised personnel only. All systems are encrypted, audited regularly, and comply with data security standards.

6. Data Sharing

We only share your personal data when necessary and with trusted recipients, such as:

  • Adult Social Care teams, NHS professionals

  • Care Quality Commission (CQC) and safeguarding authorities

  • Subcontractors and IT providers (e.g., care planning platforms)

  • Regulatory and legal bodies where required by law Data is not sold or used for marketing purposes.

7. International Transfers

Your data is mainly stored in the UK or EEA.

When transfers are made:

  • To the UK: The EU has confirmed adequacy

  • Outside the UK/EEA (if required): We use EU Standard Contractual Clauses (SCCs) or other safeguards

8. How Long We Keep Your Data

We retain your personal data only as long as necessary.

For example:

  • Client records: Are retained for 15 years after support ends, as per required period on Crossroads Caring for Life Insurance Policy, (or longer if required by NHS or local authority standards)

  • Job applicants: Up to 12 months unless you become an employee

  • Supplier details: For the duration of the contract + up to 6 years for legal/accounting purposes Your data will then be securely deleted or anonymised.

9. Your Rights

You have the following rights under the UK GDPR:

  1. Access – Request a copy of your personal data

  2. Rectification – Correct inaccurate or incomplete data

  3. Erasure – Ask for your data to be deleted in certain circumstances

  4. Restriction – Ask us to stop processing but retain your data

  5. Portability – Transfer your data to another provider (where applicable)

  6. Objection – Object to processing based on legitimate interests or direct marketing

  7. Withdraw Consent – Where we rely on consent, you can withdraw it at any time

You can exercise these rights by contacting info@crossroadshn.org.uk.

We aim to respond within one month.

10. Automated Decision-Making

We do not make decisions about you based solely on automated processing (i.e., without human input).

11. How to Complain

If you are unhappy with how we process your personal data, you can complain to the Information Commissioner’s Office (ICO):

https://ico.org.uk/concerns

0303 123 1113

12. Contact Us

If you have questions about this policy or how we handle your data:

If you have questions about this policy or how we handle your data:

Email: info@crossroadshn.org.uk

Post:

Crossroads Caring for Life Ltd
Suite 20
Intech House
Wilbury Way
Hitchin
Herts
SG4 0TW