Privacy Policy

Lamora Healthcare Ltd is committed to protecting and respecting your privacy. This policy explains what personal data we collect, why we collect it, how we use it, and your rights under UK data protection law.

Last reviewed: March 2025  |  Version: 2.0  |  Controller: Lamora Healthcare Ltd, The Gatehouse, Gatehouse Way, Aylesbury, Buckinghamshire, HP19 8DB  |  Contact: enquiries@lamorahealthcare.co.uk

Contents

  1. Who We Are
  2. Data We Collect and Why
  3. Legal Basis for Processing
  4. Special Category Data
  5. How We Use Your Data
  6. Who We Share Your Data With
  7. International Transfers
  8. How Long We Keep Your Data
  9. How We Keep Your Data Safe
  10. Cookies
  11. Your Rights
  12. Children’s Privacy
  13. Complaints
  14. Changes to This Policy

1. Who We Are

Lamora Healthcare Ltd (“Lamora Healthcare”, “we”, “us”, “our”) is a health and social care organisation registered in England and Wales. We are the data controller for the personal data we process in connection with our services, website, and employment activities.

We are registered with the Care Quality Commission (CQC) for the regulated activity of Personal Care. Our registered office address is The Gatehouse, Gatehouse Way, Aylesbury, Buckinghamshire, HP19 8DB.

If you have any questions about how we handle your personal data, or wish to exercise any of your rights, please contact us at:

Email: enquiries@lamorahealthcare.co.uk
Post: Data Protection, Lamora Healthcare Ltd, The Gatehouse, Gatehouse Way, Aylesbury, Buckinghamshire, HP19 8DB
Telephone: 0333 004 0177

2. Data We Collect and Why

We collect personal data across several distinct activities.

2.1 Website Visitors

When you visit our website we may collect: IP address, browser type and version, pages visited, time and date of visit, and time spent on pages. This data is collected automatically through server logs and is used solely to monitor the security and performance of our website. It is not linked to any personally identifiable information.

2.2 General Enquiries and Contact Forms

When you submit a general enquiry via our website or contact us by telephone or email, we collect your name, email address, telephone number, and the content of your message. We use this information solely to respond to your enquiry. We do not use it for marketing purposes without your explicit consent.

2.3 Professional Referrals

When a professional makes a referral on behalf of an individual requiring care, we collect the referrer’s name, job title, organisation, and contact details; and the referred individual’s name, date of birth, address, NHS number (where provided), care needs summary, relevant health and risk information, funding source, and next of kin details. This information is necessary to assess and arrange appropriate care. We process this data under Articles 6(1)(b), 6(1)(c), and 9(2)(h) UK GDPR.

2.4 Service User and Care Data

For individuals who receive care from Lamora Healthcare, we collect and process detailed personal and health data including: full name and contact details; date of birth and NHS number; medical history, diagnoses, medication, and clinical assessments; mental capacity assessments and deprivation of liberty documentation where relevant; care plans, risk assessments, and daily care records; incident reports and safeguarding documentation; next of kin and emergency contact details; financial information relating to care funding; and consent records. This data is necessary to provide safe, lawful, and effective care services.

2.5 Family Members and Next of Kin

Where family members or next of kin contact us or are involved in care planning, we collect their name, relationship to the service user, contact details, and any information they share during those interactions. We use this information to facilitate communication and involve families in care as appropriate and with the service user’s consent.

2.6 Job Applicants and Employees

During recruitment we collect: name and contact details; employment history and references; qualifications and training records; right to work documentation; Disclosure and Barring Service (DBS) application information and certificate details; health information relevant to the role where applicable; and equal opportunities monitoring data (optional). For successful applicants, this data forms the basis of an employment record. We process recruitment data under Article 6(1)(b) UK GDPR and, where special category data is involved, under Article 9(2)(b) and the Data Protection Act 2018 Schedule 1 conditions.

2.7 Commissioners, Contractors, and Business Contacts

We collect and retain contact details and relevant professional information for commissioners, NHS teams, local authority contacts, contractors, and other business partners. We process this data under Articles 6(1)(b) and 6(1)(f) UK GDPR.

3. Legal Basis for Processing

UK GDPR requires us to have a lawful basis for processing personal data. We rely on the following bases depending on context:

  • Consent (Article 6(1)(a)): Where you have given specific, informed consent — for example, agreeing to receive communications.
  • Contract (Article 6(1)(b)): Where processing is necessary to perform a contract or take pre-contractual steps — for example, arranging and delivering care services.
  • Legal obligation (Article 6(1)(c)): Where processing is necessary to comply with a legal obligation — for example, safeguarding duties, CQC regulatory requirements, and employment law.
  • Vital interests (Article 6(1)(d)): Where processing is necessary to protect someone’s life in an emergency situation.
  • Public task (Article 6(1)(e)): Where processing is necessary for a task carried out in the public interest, applicable to certain elements of our regulated care activities.
  • Legitimate interests (Article 6(1)(f)): Where processing is necessary for our legitimate interests and not overridden by your rights — for example, maintaining business contact records.

4. Special Category Data

Much of the personal data we process in connection with our care services is “special category data” under UK GDPR — specifically health data, data concerning disability, and in some cases data about criminal convictions in relation to DBS checks. We process special category data under the following conditions:

  • Article 9(2)(b): Processing health and criminal records data for employment and DBS purposes, under Schedule 1 paragraph 1 of the Data Protection Act 2018.
  • Article 9(2)(c): Processing necessary to protect vital interests where the data subject cannot give consent.
  • Article 9(2)(h): Processing health data for health and social care purposes — assessment, diagnosis, provision of care, and management of care systems.
  • Article 9(2)(i): In limited circumstances where processing is necessary for reasons of public health.

5. How We Use Your Data

We use personal data only for the purposes for which it was collected or purposes that are compatible with those original purposes. Specifically:

  • To provide, plan, and coordinate care and support services
  • To communicate with service users, families, commissioners, and referrers
  • To assess care needs and develop care plans and risk assessments
  • To manage medication safely and monitor clinical outcomes
  • To fulfil our safeguarding obligations under the Care Act 2014 and related legislation
  • To meet our CQC regulatory obligations and maintain required records
  • To invoice commissioners and process funding arrangements
  • To recruit, employ, and manage our workforce
  • To conduct internal audits, quality assurance, and service improvement activities
  • To investigate complaints, incidents, and safeguarding concerns
  • To comply with legal and regulatory obligations including mandatory reporting
  • To respond to enquiries from the public, families, and professionals

We do not use personal data for automated decision-making or profiling, and we do not sell personal data to any third party under any circumstances.

6. Who We Share Your Data With

We share personal data only where there is a lawful basis or legal duty to do so. Recipients may include:

  • NHS teams and ICBs: For coordination of NHS Continuing Healthcare and other health-funded packages, and for clinical handover and MDT participation.
  • Local authorities: For coordination of commissioned care, safeguarding processes, and statutory reporting obligations.
  • GPs and community health teams: For clinical coordination, medication management, and continuity of care.
  • The Care Quality Commission (CQC): In the course of inspections and in response to statutory information requests.
  • Safeguarding authorities: Where we have a duty to refer or report concerns about the welfare of an adult or child under the Care Act 2014 or Children Act 1989.
  • The Disclosure and Barring Service (DBS): For processing enhanced DBS checks for staff in regulated activity.
  • Our IT and communications providers: Who process data on our behalf as data processors under appropriate Data Processing Agreements, including our email and website hosting provider.
  • Legal advisers and insurers: Where necessary for legal proceedings, regulatory matters, or insurance claims.
  • HMRC and other statutory bodies: Where required by law for employment, tax, or regulatory compliance.

We do not share personal data with any third party for marketing or commercial purposes. Where we engage data processors, we ensure appropriate contractual protections are in place in accordance with Article 28 UK GDPR.

7. International Data Transfers

We do not routinely transfer personal data outside the United Kingdom. Where any transfer to a country outside the UK occurs — for example, through the use of cloud-based software services — we ensure appropriate safeguards are in place in accordance with UK GDPR Chapter V, such as use of the UK International Data Transfer Agreement (IDTA) or equivalent adequacy mechanisms.

8. How Long We Keep Your Data

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law or regulatory guidance.

Type of DataRetention Period
Care records (adult)Minimum 8 years from last contact, per NHS Records Management Code of Practice
Care records (young person under 18 at time of care)Until age 25, or 8 years from last contact, whichever is longer
Employee records (active)Duration of employment
Employee records (former)7 years from end of employment
Unsuccessful job applications6 months from date of decision
DBS certificate records6 months from date of check (date, level, and outcome only)
Safeguarding recordsMinimum 10 years, or until subject reaches age 25 if a child — whichever is longer
Incident and accident reportsMinimum 10 years from date of incident
Website enquiries and contact form submissions12 months from date of submission
Financial and invoicing records7 years from end of the relevant financial year (HMRC requirement)
Website server logs90 days

At the end of the applicable retention period, personal data is securely destroyed or anonymised in accordance with our Records Management Policy.

9. How We Keep Your Data Safe

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, alteration, or disclosure. Our security measures include:

  • Access controls — personal data is accessible only to staff who need it for their role
  • Password policies and multi-factor authentication where available
  • Encrypted communication channels for transmitting sensitive data
  • Secure storage of physical records with restricted access
  • Regular staff training on data protection and information security
  • An incident response procedure for detecting, reporting, and managing personal data breaches
  • Data processor due diligence — we only engage third-party processors who provide sufficient security guarantees

In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner’s Office (ICO) within 72 hours as required by Article 33 UK GDPR. Where the breach is likely to result in high risk to you personally, we will also notify you directly without undue delay.

10. Cookies

Our website uses cookies. A cookie is a small text file placed on your device when you visit a website. We use the following categories of cookies:

  • Strictly necessary cookies: Essential for the website to function. They do not store personally identifiable information. No consent is required for these cookies under the UK Privacy and Electronic Communications Regulations (PECR).
  • Analytics cookies: We may use anonymised analytics to understand how visitors use our website. No personally identifiable information is collected and data is aggregated. We will seek your consent before placing any non-essential cookies on your device.

We do not use advertising cookies, social media tracking cookies, or cookies that share your data with third parties for commercial purposes. You can control cookies through your browser settings at any time.

11. Your Rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights in relation to your personal data. These rights are not absolute and may be subject to exemptions, particularly where we process data in connection with regulated care activities or legal obligations.

  • Right of access (Article 15): You may request a copy of the personal data we hold about you (Subject Access Request). We will respond within one calendar month of a valid request.
  • Right to rectification (Article 16): You may request that we correct inaccurate or complete incomplete data.
  • Right to erasure (Article 17): You may request deletion of your personal data in certain circumstances. This right does not apply where we are required to retain data by law or for legal claims.
  • Right to restrict processing (Article 18): You may request restriction of processing in certain circumstances — for example, while you contest accuracy.
  • Right to data portability (Article 20): Where processing is based on consent or contract and carried out by automated means, you may receive your data in a structured, machine-readable format.
  • Right to object (Article 21): You may object to processing based on legitimate interests or public task. We will stop processing unless we can demonstrate compelling legitimate grounds.
  • Rights related to automated decision-making (Article 22): We do not use automated decision-making or profiling. Should this change, we will update this policy and provide appropriate safeguards.
  • Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of prior processing.

To exercise any of these rights, contact us at enquiries@lamorahealthcare.co.uk or by post. We may verify your identity before processing a request. We will respond within one calendar month, or notify you if an extension of up to two further months is required.

12. Children’s Privacy

Lamora Healthcare provides supported accommodation for young people aged 16 to 25, some of whom may be under 18 at the time of placement. Where we process personal data relating to individuals under the age of 18, we apply additional care and safeguards in line with our safeguarding obligations and the requirements of the Children Act 1989, Children and Families Act 2014, and relevant statutory guidance.

Our website is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16 through our website. If you believe a child under 16 has submitted personal data through our website without appropriate consent, please contact us immediately at enquiries@lamorahealthcare.co.uk.

13. Complaints

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the UK supervisory authority for data protection:

Information Commissioner’s Office (ICO)
Website: ico.org.uk
Telephone: 0303 123 1113
Post: ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

We would appreciate the opportunity to address your concerns before you approach the ICO. Please contact us in the first instance at enquiries@lamorahealthcare.co.uk.

14. Changes to This Policy

We review this Privacy Policy at least annually and whenever there is a material change to how we process personal data. The current version is always published on this page. Where changes are significant, we will take reasonable steps to notify affected individuals.

This policy was last reviewed and updated in March 2025 (Version 2.0).