Privacy Policy
Last updated: 29 April 2026
1Data Controller Details
- Company name
- Tender Loving Care Ltd
- Registered address
- Rhos on Sea, North Wales, United Kingdom
- Company number
- 6344760
- Regulator
- Care Inspectorate Wales (CIW)
- ICO Registration Number
- [To be inserted]
- Data Protection Lead
- Cameron Darling
- Data protection email
- Cameron.darling@tenderlovingcare.org.uk
Where we are required to appoint a Data Protection Officer or nominated data protection lead, contact details are provided in Section 10.
2What Data We Collect
We collect and process personal data about our clients, staff and associated individuals as described below.
Client data
- ✦Full name, date of birth, address and contact details
- ✦NHS number and GP / healthcare professional details
- ✦Care and support needs assessments, care plans and risk assessments
- ✦Health and medical information (including diagnoses, medications, allergies and mental capacity assessments) — special category data under Article 9 UK GDPR
- ✦Daily care records, visit logs and outcomes
- ✦Financial information relevant to funding of care (e.g. local authority or NHS continuing healthcare status)
- ✦Next of kin / emergency contact names, relationships and contact details
- ✦Lasting power of attorney or deputyship details where applicable
Staff data
- ✦Full name, address, date of birth, national insurance number
- ✦Right-to-work documentation and DBS disclosure information
- ✦Employment history, references and training records
- ✦Bank details and payroll information
- ✦Absence, disciplinary and performance records
- ✦Health information relevant to occupational fitness (special category data)
- ✦Location and mileage data collected via electronic call monitoring (ECM) or care management software during working hours
- ✦CCTV footage where operated at our premises
Website visitors
- ✦Enquiry form submissions (name, email, telephone, message)
- ✦Technical data such as IP address, browser type and pages visited (collected via session cookies — see Section 8)
3Legal Basis for Processing
We rely on the following lawful bases under UK GDPR Article 6 for processing general personal data:
- ✦Article 6(1)(b) — Contract: Processing necessary to fulfil a care agreement or employment contract.
- ✦Article 6(1)(c) — Legal obligation: Processing required to comply with statutory duties, including those imposed by the Regulation and Inspection of Social Care (Wales) Act 2016, Health and Safety legislation, and employment law.
- ✦Article 6(1)(d) — Vital interests: Processing necessary to protect the life of a client or another person.
- ✦Article 6(1)(e) — Public task: Processing in connection with the exercise of official authority or a task carried out in the public interest (e.g. safeguarding referrals).
- ✦Article 6(1)(f) — Legitimate interests: Processing for fraud prevention, security monitoring and internal administration where these interests are not overridden by individual rights.
- ✦Article 6(1)(a) — Consent: Where none of the above applies, we will request your explicit consent, which you may withdraw at any time.
For special category data (health, biometric or other sensitive information), we additionally rely on UK GDPR Article 9 conditions, principally:
- ✦Article 9(2)(b) — Employment & social protection law
- ✦Article 9(2)(c) — Vital interests
- ✦Article 9(2)(h) — Health or social care purposes (and Schedule 1, Part 1 of the DPA 2018)
- ✦Article 9(2)(g) — Substantial public interest (e.g. safeguarding of adults)
- ✦Article 9(2)(a) — Explicit consent where no other condition applies
7Your Rights Under UK GDPR
Subject to certain conditions and exemptions, you have the following rights regarding your personal data:
Right of Access
Request a copy of the personal data we hold about you (Subject Access Request). We will respond within one calendar month.
Right to Rectification
Ask us to correct inaccurate or incomplete personal data without undue delay.
Right to Erasure
Request deletion of your data where there is no compelling reason to continue processing it. This right does not apply where we have a legal obligation to retain records.
Right to Restriction
Ask us to restrict processing of your data in certain circumstances, e.g. whilst accuracy is contested.
Right to Data Portability
Receive your data in a structured, machine-readable format and have it transferred to another controller, where technically feasible.
Right to Object
Object to processing based on legitimate interests or for direct marketing purposes. We will cease processing unless we can demonstrate compelling legitimate grounds.
Rights re: Automated Decisions
Not to be subject to solely automated decision-making that produces legal or significant effects, without human review.
Right to Withdraw Consent
Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us using the details in Section 10. We may need to verify your identity before processing your request. There is generally no fee; however, we may charge a reasonable fee or refuse manifestly unfounded or excessive requests.
9Data Breach Notification
Tender Loving Care Ltd maintains a written Data Breach Response Procedure. In the event of a personal data breach we will:
- 1Contain the breach and assess the risk to individuals as quickly as possible.
- 2Document all breaches in our internal breach register, regardless of whether notification is required.
- 3Notify the ICO within 72 hours of becoming aware of the breach where it is likely to result in a risk to the rights and freedoms of individuals, in accordance with Article 33 UK GDPR.
- 4Notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms, in accordance with Article 34 UK GDPR.
Our breach response procedure is reviewed annually and following any significant incident. All staff receive training on recognising and reporting suspected data breaches as part of their mandatory induction and annual refresher training.
10Contact Us
For any queries about this privacy policy, to exercise your data subject rights, or to raise a data protection concern, please contact us:
Tender Loving Care Ltd
Rhos on Sea, North Wales, United Kingdom
Data Protection Lead: Cameron Darling
Email: Cameron.darling@tenderlovingcare.org.uk
Telephone: 01492 592177
We aim to respond to all data protection enquiries within 5 working days, and to Subject Access Requests within one calendar month of receipt.
If you are not satisfied with our response, you have the right to escalate your complaint to the Information Commissioner's Office:
- ✦Website: ico.org.uk
- ✦Telephone: 0303 123 1113
- ✦Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
