โ Our database is hosted in West EU (Ireland) โ fully within the EU/EEA and covered by UK adequacy decisions. No international transfer concerns for your personal data.
Contents
- Who we are
- What personal data we collect
- How we use your data
- Our lawful basis for processing
- Special category (health) data
- Who we share your data with
- Data processors we use
- International data transfers
- How long we keep your data
- Your rights
- Cookies
- AI features on our website
- Children's data
- How to complain
- Changes to this policy
1. Who We Are
Ecohomes Care Ltd ("we", "us", "our") is a domiciliary care provider registered in England and Wales. We are a CQC Registered Provider and the Data Controller for all personal information we process.
| Detail | Information |
|---|---|
| Company name | Ecohomes Care Ltd |
| Company number | 15230160 |
| Registered address | Fort Dunlop, Unit 115-119, Fort Parkway, Birmingham B24 9FE |
| info@ecohomescare.com | |
| Phone | 0121 663 6618 |
| ICO Registration | Registered with the Information Commissioner's Office โ Registration number: ZC133741 |
| Data Controller | Maureen Ibelema Iwari-Pollyn (Director) |
2. What Personal Data We Collect
From website visitors
- Name and contact details when you submit an enquiry form
- Name, location and review text when you submit a testimonial
- Anonymous usage data via Google Analytics (pages visited, time on site, device type โ no personal identification)
- Cookie consent preferences stored in your browser
From prospective and existing clients
- Full name, date of birth, home address
- Health conditions, diagnoses and medical history
- Medication records
- Care needs assessment information
- Emergency contact details (next of kin / family members)
- Financial information only where relevant to care funding
From job applicants and staff
- Name, address, date of birth, National Insurance number
- CV, employment history and references
- DBS certificate and disclosure number
- Right to work documents
- Training records and qualifications
3. How We Use Your Data
| Purpose | Data used |
|---|---|
| Responding to website enquiries | Name, phone, email |
| Publishing approved testimonials | First name, general location, review text |
| Providing and managing care services | Client health data, care plans, medication records |
| Employing and managing staff | Staff personal and employment data |
| Meeting CQC regulatory requirements | Client and staff records |
| Improving our website | Anonymous analytics data |
| Legal compliance and record keeping | All relevant data as required by law |
We will never sell your personal data to third parties, use it for unsolicited marketing without your consent, or share it for purposes unrelated to our care services.
4. Our Lawful Basis for Processing
Under UK GDPR Article 6, we must have a lawful basis for every data processing activity. We use the following bases:
| Processing Activity | Lawful Basis |
|---|---|
| Providing care services | Legal obligation + Vital interests |
| Employment and staff management | Contract + Legal obligation |
| CQC compliance and reporting | Legal obligation |
| Website enquiry responses | Legitimate interests |
| Publishing testimonials | Consent |
| Analytics (anonymised) | Legitimate interests (with consent for cookies) |
5. Special Category (Health) Data
Health data, including care plans, medication records and medical history, is classified as special category data under UK GDPR Article 9 and receives the highest level of legal protection.
We process health data under Article 9(2)(h) โ processing necessary for the provision of health or social care โ and under the Health and Social Care Act 2008 (CQC Regulation 17).
Important: Client health data is never stored on our public website. It is held securely in access-controlled systems hosted in the EU (Ireland) with appropriate technical and organisational safeguards, including Row Level Security (RLS) and role-based access controls.
6. Who We Share Your Data With
We only share personal data where there is a lawful reason to do so. We may share data with:
- NHS and healthcare providers โ for continuity of care (e.g. hospital discharge)
- Local authority social services โ where care is funded or referred by the local authority
- CQC (Care Quality Commission) โ as required for regulatory compliance
- HMRC and legal authorities โ where required by law
- Emergency services โ in a medical emergency to protect vital interests
- Data processors listed below โ under strict data processing agreements
We never share personal data with third parties for marketing purposes without your explicit consent.
7. Data Processors We Use
We use the following third-party services that process data on our behalf. Each is required to handle data only on our instructions and in accordance with UK GDPR.
| Processor | Purpose | Data location | Privacy policy |
|---|---|---|---|
| Supabase Inc. | Website database โ stores approved testimonials, enquiries, vacancies and blog posts. No client health data stored here. | ๐ฎ๐ช EU โ West EU (Ireland, eu-west-1). Fully within EEA โ no international transfer. | supabase.com/privacy |
| GoDaddy Inc. | Web hosting โ public website files only. No personal data stored in hosting files. | UK / EU | godaddy.com |
| Vercel Inc. | Admin portal hosting (portal.ecohomescare.co.uk) โ login-protected. No client health data. | EU region | vercel.com/legal/privacy-policy |
| Google LLC | Analytics (anonymised), Google Business Profile, Search Console | EU (UK adequacy decision) | policies.google.com/privacy |
| OpenRouter / Anthropic PBC | AI chat assistant and care checker โ processes enquiry text only. No health data transmitted. Conversations not stored after session. | USA โ Standard Contractual Clauses (SCCs) per ICO guidance | openrouter.ai/privacy |
If we add new processors in future, this policy will be updated within 30 days.
8. International Data Transfers
Most of our data processing takes place within the EU/EEA, which is covered by UK adequacy decisions:
โ Our primary database (Supabase) is hosted in Ireland (EU West) โ this means your data stays within the EEA. No UK-to-non-adequate-country transfer applies. This is the strongest possible position for UK GDPR compliance.
Where processors are based outside the EEA, we ensure appropriate safeguards:
- Google โ covered by the EU-US Data Privacy Framework (UK adequacy decision)
- OpenRouter / Anthropic (USA) โ Standard Contractual Clauses (SCCs) as approved by the ICO under Article 46 UK GDPR. Only non-sensitive enquiry text is processed โ no health data is ever transmitted to US processors.
We never transfer client health or special category data outside the UK/EEA without explicit consent and full legal safeguards.
9. How Long We Keep Your Data
| Data Type | Retention Period |
|---|---|
| Client care records | Duration of care + 8 years (or until age 25 if a minor) |
| Staff employment records | 7 years after employment ends |
| DBS disclosure information | Maximum 6 months (DBS Code of Practice) |
| Website enquiry data | 12 months, then securely deleted |
| Approved testimonials | Until removal is requested |
| Financial / invoicing records | 7 years (HMRC requirement) |
| Accident / incident records | 10 years |
| Website analytics | 26 months (Google Analytics default, anonymised) |
10. Your Rights
Under UK GDPR you have the following rights. To exercise any of them, contact us at info@ecohomescare.com. We will respond within one calendar month.
- Right of access โ request a copy of all personal data we hold about you
- Right to rectification โ ask us to correct inaccurate or incomplete data
- Right to erasure โ ask us to delete your data (subject to legal retention requirements)
- Right to restrict processing โ ask us to pause using your data
- Right to data portability โ request your data in a machine-readable format
- Right to object โ object to processing based on legitimate interests or for direct marketing
- Rights related to automated decisions โ request human review of automated decisions affecting you
There is no charge to exercise any of these rights. We may ask for proof of identity before we can action your request.
11. Cookies
Our website uses cookies. When you first visit, a consent banner asks for your preferences. You can change your choices at any time using the Cookie Settings link in the footer.
| Cookie type | Purpose | Consent required |
|---|---|---|
| Essential | Keep the website working correctly (session, security, cookie preference memory) | No โ strictly necessary |
| Analytics | Google Analytics 4 โ anonymous usage statistics only | Yes โ optional |
We do not use advertising, tracking or profiling cookies. Analytics data is anonymised โ we cannot identify individual visitors from it.
12. AI Features on Our Website
Our website includes two AI-powered features:
AI Care Needs Checker
A 4-step questionnaire that asks general questions (who needs care, the main challenge, urgency, location area) and provides a recommendation to call us. No health data is collected and no data is stored โ responses are processed within your browser session only. The AI provides information only, not care decisions.
AI Chat Assistant
This processes the text of questions you type in the chat widget. No special category or health data should be entered into the chat. Conversation text is sent to our AI provider (OpenRouter / Anthropic) under Standard Contractual Clauses. Conversations are not stored after your session ends.
Important โ UK GDPR Article 22: Our AI features do not make automated decisions about care eligibility or suitability. All care decisions are made by qualified professionals following a proper face-to-face assessment. The AI provides information only.
13. Children's Data
Our website is not directed at children under 13. We do not knowingly collect personal data from children through our website. If care is provided to a minor, we follow applicable safeguarding requirements and extended data retention rules under the NHS Records Management Code of Practice.
14. How to Complain
If you have a concern about how we handle your personal data, please contact us first:
- Email: info@ecohomescare.com โ subject: "Data Protection Concern"
- Phone: 0121 663 6618
- Post: Ecohomes Care Ltd, Fort Dunlop, Unit 115-119, Fort Parkway, Birmingham B24 9FE
We will respond within 30 calendar days as required by UK GDPR Article 12.
For full details of our complaints process, visit our Data Protection Complaints page.
If you remain unsatisfied, you may complain to the Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint or call 0303 123 1113.
15. Changes to This Policy
We review and update this Privacy Policy at least annually, or sooner if there are changes to the law or how we process data. We will update the "Last updated" date at the top of this page when changes are made. For significant changes we will notify existing clients directly.
Privacy Policy version 1.1 | Last updated: July 2026 | Next review: July 2027
Ecohomes Care Ltd, Company No. 15230160, registered in England & Wales. CQC Registered Provider.
Drafted in accordance with UK GDPR, Data Protection Act 2018, and Data (Use and Access) Act 2025.