1. About this notice

This Privacy Notice explains how Kind Companions collects, uses, stores and shares personal information when someone enquires about our services, uses our companionship service, acts as an authorised contact, or otherwise deals with us.

Kind Companions is the data controller for the personal information covered by this notice. This notice should be read separately from our Terms of Service and Cookie Policy.

2. Information we may collect

We only collect information that is reasonably needed to arrange, provide and manage our service. Depending on the circumstances, this may include:

name, address, telephone number, email address and other contact details;
details of authorised contacts, relatives or emergency contacts;
enquiry, booking, service-plan and visit information;
records of communications, concerns, incidents or complaints;
payment, invoicing and transaction information;
information needed to manage safe transport or outings where these form part of the agreed service;
health-related or other special category information that is genuinely relevant to providing the service safely, such as allergies, mobility information, communication needs or relevant cognitive or medical information; and
technical information collected through our website, as explained in our Cookie Policy.

We aim to collect the minimum amount of health or sensitive information necessary for the agreed service.

3. Where we obtain information from

We usually obtain personal information directly from the service user or the person making an enquiry. We may also receive information from an authorised family member, representative or other person involved in arranging the service.

Where information about a service user is supplied by someone else, we will take reasonable steps to ensure the service user receives appropriate privacy information and that any authority or consent needed for the information supplied is properly addressed.

4. How we use personal information

responding to enquiries and taking steps requested before a service begins;
setting up, scheduling and delivering companionship services;
providing Companions with the information they reasonably need to complete an assignment safely;
communicating with the service user and, where authorised, managing communications with approved contacts through Kind Companions management;
managing payments, invoices and business records;
protecting the safety and welfare of service users, Companions and others;
recording and responding to accidents, incidents, safeguarding concerns or complaints;
meeting legal, regulatory, insurance, accounting and record-keeping requirements;
managing and improving our service, systems and administration; and
establishing, exercising or defending legal claims where necessary.

5. Our lawful bases

Under UK data protection law, we must have a lawful basis for using personal information. Depending on what we are doing, we may rely on:

Contract - where processing is necessary to take requested steps before entering into a service agreement or to provide and manage the agreed service;
Legal obligation - where we need to process information to comply with the law, including relevant financial, tax or regulatory obligations;
Legitimate interests - where necessary for the proper administration, protection and improvement of Kind Companions, provided those interests are not overridden by the individual’s rights and interests;
Consent - where we specifically ask someone to make a genuine choice about a particular use of their information; and
Vital interests - in limited circumstances where processing is necessary to protect someone’s life or prevent serious harm.

6. Health and other special category information

Some information we may need for safe service delivery can be classed as special category personal data under UK GDPR, particularly information concerning health.

Where we rely on explicit consent to process this information, we will ask for that consent separately. This may include relevant information about allergies, mobility, communication needs, cognitive or memory difficulties, or other health-related matters that are necessary for the agreed service.

In an emergency, there may be limited circumstances where we need to use or share relevant information without relying on consent in order to protect someone’s vital interests or where another lawful basis applies.

7. Who we may share information with

We do not sell personal information. We only share it where there is a legitimate reason to do so and only to the extent reasonably necessary.

Kind Companions management and authorised Companions, on a need-to-know basis;
service providers that support our scheduling, communications, file storage, website, payment and accounting systems;
our accountants, insurers, legal advisers or other professional advisers where necessary;
emergency services, local authorities, safeguarding bodies, regulators or law-enforcement agencies where necessary or required by law; and
authorised family members or other contacts where the service user has given the relevant permission or another lawful basis applies.

Routine service-user updates to family members or other contacts are handled by Kind Companions management, not directly by individual Companions.

8. International processing

Some of the technology providers we use may store or process personal information outside the United Kingdom. Where this happens, we take reasonable steps to ensure that an appropriate lawful transfer mechanism or safeguard is in place as required by UK data protection law.

9. How long we keep information

We keep personal information only for as long as it is reasonably needed for the purpose for which it was collected, to provide and manage the service, to deal with queries or disputes, and to meet legal, insurance, financial and record-keeping requirements.

Different types of records may therefore be kept for different periods. We periodically review the information we hold and securely delete or anonymise information when it is no longer required.

10. How we protect information

We use reasonable organisational and technical measures to protect personal information against accidental loss, misuse, unauthorised access or disclosure. Access is restricted to people who need the information for their role, and Companions are required to follow Kind Companions confidentiality and data-protection rules.

11. Your rights

Depending on the circumstances and the lawful basis we rely on, you may have rights including the right to:

ask for a copy of personal information we hold about you;
ask us to correct inaccurate or incomplete information;
ask us to erase information in certain circumstances;
ask us to restrict how information is used in certain circumstances;
object to certain uses of your information, particularly where we rely on legitimate interests;
receive certain information in a portable format where the right to data portability applies; and
withdraw consent at any time where we rely on consent.

Your right to object: where we rely on legitimate interests, you have the right to object to that processing. We will consider your objection and stop the processing unless we have a lawful reason to continue.

Withdrawing consent does not affect the lawfulness of processing that took place before consent was withdrawn. Some rights are subject to legal conditions and exemptions.

12. Automated decision-making

Kind Companions does not use personal information to make solely automated decisions that produce legal effects or similarly significant effects on service users.

13. Contacting us about your information

If you have a question about this notice, want to exercise a data-protection right, or have a concern about how your information has been handled, please contact:

Email: suzie@kindcompanions.co.uk
Telephone: 07947 391 632

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection. Information about how to make a complaint is available at ico.org.uk.

14. Changes to this notice

We may update this Privacy Notice where our services, systems or legal obligations change. The current version will be made available on our website and will show its effective date.

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