Privacy Policy
Privacy Notices
1. Introduction
This is Comfy Connect Ltd’s Privacy Notice.
1.1 Data Controller
Comfy Connect Ltd is the Data Controller for the personal data described in this Privacy Notice. Comfy Connect Ltd is registered with the Information Commissioner’s Office (ICO) as a Data Controller under Registration Number ZB847684. This registration confirms our compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Registered Office: Unit 1 iLux Parade, Palmerston Road, London, E7 8FA.
1.2 Data Protection Officer (DPO)
Our Data Protection Officer (DPO) oversees compliance with data protection law and can be contacted at:
Email: compliance@comfyconnect.co.uk
As part of the services we offer, we are required to process personal data about our staff, our service users and, in some instances, the friends or relatives of our service users and staff. “Processing” can mean collecting, recording, organising, storing, sharing or destroying data.
We are committed to being transparent about why we need your personal data and what we do with it. This information is set out in this privacy notice. It also explains your rights when it comes to your data.
If you have any concerns or questions, please contact us: compliance@comfyconnect.co.uk.
2. Service Users
2.1 What data do we have?
So that we can provide a safe and professional service, we need to keep certain records about you. We may process the following types of data:
- Your basic details and contact information e.g. your name, address, date of birth and next of kin.
- Your financial details e.g. details of how you pay us for your transport or your funding arrangements.
We also record the following data which is classified as “special category”:
- Health and social care data about you, which might include both your physical and mental health data.
- We may also record data about your race, ethnic origin, sexual orientation or religion.
2.2 Why do we have this data?
We need this data so that we can provide high-quality care and support. By law, we need to have a lawful basis for processing your personal data.
We process your data because:
- We have a legal obligation to do so – generally under the Health and Social Care Act 2012 or Mental Capacity Act 2005.
We process your special category data because:
- It is necessary due to social security and social protection law (generally this would be in safeguarding instances).
- It is necessary for us to provide and manage social care services.
- Where we rely on legitimate interests as our lawful basis for processing, we have completed a Legitimate Interests Assessment (LIA) to ensure that our interests do not override your rights and freedoms.
- We may also process your data with your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent at any time.
2.3 In-Vehicle Cameras (Where Used)
Where in-vehicle cameras or CCTV are in operation, footage is used solely for safety, safeguarding, incident investigation and service assurance purposes. Cameras are positioned to minimise intrusion, audio is not routinely recorded, access to footage is restricted to authorised personnel only, and recordings are retained for a short, defined period. Data Protection Impact Assessments are completed prior to deployment.
2.4 Biometric Data
Comfy Connect does not routinely use biometric identification systems. If biometric data were ever proposed for use, we would carry out a Data Protection Impact Assessment, identify a clear lawful basis, and ensure appropriate safeguards are in place before any processing takes place.
3. Common Law Duty of Confidentiality
You need to satisfy the common law duty of confidentiality when using health and care information.
In our use of health and care information, we satisfy the common law duty of confidentiality because:
- You have provided us with your consent (either implicitly to provide you with care, or explicitly for other uses).
- We have a legal requirement to collect, share and use the data.
- 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).
4. Where do we process your data?
So that we can provide you with high quality care and support we need specific data. This is collected from or shared with:
- You or your legal representative(s);
- Third parties.
We do this face to face, via phone, via email, via our website, via post, via application forms, via apps.
Third parties are organisations we might lawfully share your data with. These include:
- Other parts of the health and care system such as local hospitals, the GP, the pharmacy, social workers, clinical commissioning groups, and other health and care professionals.
- The Local Authority.
- Your family or friends – with your permission.
- Organisations we have a legal obligation to share information with i.e. for safeguarding, Local authorities.
- The police or other law enforcement agencies if we have to by law or court order.
5. National Data Opt-Out
We review our data processing on an annual basis to assess if the national data opt-out applies. This is recorded in our Record of Processing Activities. All new processing is assessed to see if the national data opt-out applies. If any data processing falls within scope of the National Data Opt-Out we use MESH to check if any of our service users have opted out of their data being used for this purpose.
At this time, we do not share any data for planning or research purposes for which the national data opt-out would apply. We review all of the confidential patient information we process on an annual basis to see if this is used for research and planning purposes. If it is, then individuals can decide to stop their information being shared for this purpose. You can find out more information at:
https://www.nhs.uk/your-nhs-data-matters/
6. Staff
6.1 What staff data do we have?
So that we can provide a safe and professional service, we need to keep certain records about you. We may record the following types of data:
- Your basic details and contact information e.g. your name, address, date of birth, National Insurance number and next of kin.
- Your financial details e.g. details so that we can pay you, insurance, pension and tax details.
- Your training records.
We also record the following data which is classified as “special category”:
- Health and social care data about you, which might include both your physical and mental health data – we will only collect this if it is necessary for us to know as your employer, e.g. fit notes or in order for you to claim statutory maternity/paternity pay.
- We may also, with your permission, record data about your race, ethnic origin, sexual orientation or religion.
As part of your application, you may – depending on your job role – be required to undergo a Disclosure and Barring Service (DBS) check (Criminal Record Check). We do not keep this data once we’ve seen it.
6.2 Why do we have this data?
We require this data so that we can contact you, pay you and make sure you receive the training and support you need to perform your job. By law, we need to have a lawful basis for processing your personal data.
We process your data because:
- We have a legal obligation under UK employment law.
- We are required to do so in our performance of a public task.
We process your special category data because:
- It is necessary for us to process requests for sick pay or maternity pay.
If we request your criminal records data, it is because we have a legal obligation to do this due to the type of work you do. This is set out in the Data Protection Act 2018 and the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975. We do not keep a record of your criminal records information (if any). We do record that we have checked this.
We may also process your data with your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent.
Where we rely on legitimate interests as our lawful basis for processing, we have completed a Legitimate Interests Assessment (LIA) to ensure that our interests do not override your rights and freedoms.
6.3 Where do we process staff data?
As your employer we need specific data. This is collected from or shared with:
- You or your legal representative(s);
- Third parties.
We do this face to face, via phone, via email, via our website, via post, via application forms, via apps.
Third parties are organisations we have a legal reason to share your data with. These include:
- Her Majesty’s Revenue and Customs (HMRC).
- Organisations we have a legal obligation to share information with i.e. for safeguarding, the CQC.
- The police or other law enforcement agencies if we have to by law or court order.
- The DBS Service.
7. Friends / Relatives
7.1 What data do we have?
As part of our work providing high-quality care and support, it might be necessary that we hold the following information on you:
- Your basic details and contact information e.g. your name and address.
7.2 Why do we have this data?
By law, we need to have a lawful basis for processing your personal data.
We process your data because we have a legitimate business interest in holding next of kin and lasting power of attorney information about the individuals who use our service and keeping emergency contact details for our staff.
We may also process your data with your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent.
Where we rely on legitimate interests as our lawful basis for processing, we have completed a Legitimate Interests Assessment (LIA) to ensure that our interests do not override your rights and freedoms.
7.3 Where do we process friends/relatives’ data?
So that we can provide high quality care and support we need specific data. This is collected from or shared with:
- You or your legal representative(s);
We do this face to face, via phone, via email, via our website, via post, via application forms, via apps.
Third parties are organisations we have a legal reason to share your data with. These may include:
- Other parts of the health and care system such as local hospitals, the GP, the pharmacy, social workers, and other health and care professionals;
- The Local Authority.
- The police or other law enforcement agencies if we have to by law or court order.
8. International Data Transfers
Comfy Connect Ltd does not transfer personal data outside of the United Kingdom.
Where this position changes in the future, we will ensure that any international transfers of personal data are carried out in full compliance with UK GDPR, using appropriate safeguards, such as:
- International data transfer agreements
- UK Addendum to EU Standard Contractual Clauses (SCCs)
- Adequacy regulations issued by the UK Government
Individuals will be informed of any such changes through an updated Privacy Notice.
Where international transfers of personal data become necessary, Comfy Connect Ltd will ensure appropriate safeguards are in place in accordance with UK GDPR. These may include UK adequacy regulations, International Data Transfer Agreements (IDTAs), or the UK Addendum to the EU Standard Contractual Clauses.
9. How do we store your personal information?
Your information is securely stored for the time periods specified in the Records Management Code of Practice. We will then dispose of the information as recommended by the Records Management Code as follows:
- Paper Records: Securely shredded using cross-cut shredding.
- Electronic Records: Securely erased and wiped to recognised UK data destruction standards.
- Archived Records: Encrypted and stored securely within Microsoft 365 SharePoint with role-based access controls and multi-factor authentication.
10. Data Protection Impact Assessments
Where processing activities are likely to result in a high risk to individuals’ rights and freedoms, Comfy Connect carries out Data Protection Impact Assessments (DPIAs) to identify, assess and mitigate risks before processing begins. This includes the introduction of new systems, applications, monitoring tools or changes to existing processing activities.
11. Website, Online Enquiries & Job Applications
If you submit an enquiry, service request or job application through our website, we collect only the information required to respond to your request.
If your enquiry or job application does not proceed, your personal data is securely deleted after six (6) months.
12. Cookies & Website Analytics
Our website uses essential cookies and basic analytics cookies only. These help us ensure the website functions correctly and allow us to understand how visitors interact with the website.
We do not use advertising or marketing cookies.
You may control or disable cookies at any time through your browser settings.
13. Explicit Data Retention Schedule
- Service User Records: 8 years after last contact
- Staff Employment Records: 6 years after employment ends
- Payroll, Financial & Accounting Records: 7 years in accordance with HMRC requirements
- Website Enquiries & Recruitment Applications: 6 months if not progressed.
14. Business Transfer Clause
In the unlikely event that Comfy Connect Ltd is sold, merged, restructured or transferred to another organisation, personal data may be transferred as part of that transaction. Any new organisation will be bound by the same data protection obligations contained within this Privacy Notice.
15. Your Rights
The data that we keep about you is your data and we ensure that we keep it confidential and that it is used appropriately. You have the following rights when it comes to your data:
- You have the right to request a copy of all of the data we keep about you. Generally, we will not charge for this service;
- You have the right to ask us to correct any data we have which you believe to be inaccurate or incomplete. You can also request that we restrict all processing of your data while we consider your rectification request;
- You have the right to ask that we erase any of your personal data which is no longer necessary for the purpose we originally collected it for. We retain our data in line with the Information Governance Alliance’s guidelines;
- You have the right to data portability, meaning you can request for your personal data to be transferred to another organisation in a commonly used electronic format where technically feasible;
- You may also request that we restrict processing if we no longer require your personal data for the purpose we originally collected it for, but you do not wish for it to be erased;
- You can ask for your data to be erased if we have asked for your consent to process your data. You can withdraw consent at any time – please contact us to do so;
- If we are processing your data as part of our legitimate interests as an organisation or in order to complete a task in the public interest, you have the right to object to that processing. We will restrict all processing of this data while we look into your objection.
You may need to provide adequate information for our staff to be able to identify you, for example, a passport or driver’s licence. This is to make sure that data is not shared with the wrong person inappropriately. We will always respond to your request as soon as possible and at the latest within one month.
16. Right to Object
Where we process your personal data based on our legitimate interests or the performance of a public task, you have the right to object to that processing. We will restrict processing while your objection is reviewed, unless we can demonstrate compelling legitimate grounds to continue processing which override your interests, rights and freedoms.
17. Withdrawal of Consent
Where we rely on your consent to process personal data, you have the right to withdraw that consent at any time by contacting compliance@comfyconnect.co.uk. Withdrawal of consent will not affect the lawfulness of processing carried out before consent was withdrawn.
18. Personal Data Breaches
If a personal data breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay and provide information about the nature of the breach, the likely consequences and the steps taken to mitigate its impact.
19. Automated Decision Making & AI Tools
- Comfy Connect does not make decisions about individuals using solely automated decision-making or profiling that produces legal or similarly significant effects. All decisions relating to service delivery, safeguarding, recruitment, employment and complaints involve meaningful human oversight.
- Where digital or AI-assisted tools are used to support operational activity, appropriate safeguards are in place and Data Protection Impact Assessments (DPIAs) are completed where required.
20. Complaints
If you would like to complain about how we have dealt with your request, please contact:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF