Infinity Trust Care ltd privacy notice
Company Name: Infinity Trust Care ltd
Post: We Work, 1 Fore Street Avenue, , LONDON, , EC2Y 9DT, GB
Telephone: 020 3957 5000
Email: info@infinitytrustcare.com
Infinity Trust Care ltd customer privacy notice
This privacy notice tells you what to expect us to do with your personal information.
· What information we collect, use, and why
· Lawful bases and data protection rights
· Where we get personal information from
· How long we keep information
· Who we share information with
What information we collect, use, and why
We collect or use the following information to provide patient care, services, pharmaceutical products and other goods:
· Name, address and contact details
· Date of birth
· Next of Kin details including any support networks
· Emergency contact details
· Photographs
· Health information (including medical conditions, allergies, medical requirements and medical history)
· Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
· Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
· Payment details (including card or bank information for transfers and direct debits)
· Records of meetings and decisions
· Call recordings
· Information about income and financial needs for funding or personal budget support
We also collect the following special category information to provide patient care, services, pharmaceutical products and other goods. This information is subject to additional protection due to its sensitive nature:
· Health information
We collect or use the following information for safeguarding or public protection reasons:
· Name, address and contact details
· Emergency contact details
· Photographs
· Health information (including medical conditions, allergies, medical requirements and medical history)
· Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions)
· Relevant information from previous investigations
· Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
· Records of meetings and decisions
We also collect the following special category information for safeguarding or public protection reasons. This information is subject to additional protection due to its sensitive nature:
· Health information
We collect or use the following personal information to comply with legal requirements:
· Name
· Contact information
· Identification documents
· Health and safety information
· Financial information
· Any other personal information required to comply with legal obligations
· Right to work
· Insurance details
· Tax information
· Safeguarding information
· Criminal offence data
We also collect the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Religious or philosophical beliefs
· Health information
We collect or use the following personal information for recruitment purposes:
· Contact details (eg name, address, telephone number or personal email address)
· Date of birth
· National Insurance number
· Copies of passports or other photo ID
· Employment history (eg job application, employment references or secondary employment)
· Education history (eg qualifications)
· Right to work information
· Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks )
· Security clearance details (eg basic checks and higher security clearance)
We also collect the following special category information for recruitment purposes. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Religious or philosophical beliefs
· Health information
We collect or use the following personal information for information updates, marketing or market research purposes:
· Names and contact details
· Addresses
· Marketing preferences
· Website and app user journey information
· Records of consent, where appropriate
We collect or use the following personal information for dealing with queries, complaints or claims:
· Names and contact details
· Addresses
· Payment details
· Account information
· Purchase or service history
· Video recordings of public areas
· Audio recordings of public areas
· Video recordings of private or staff only areas
· Audio recordings of private or staff only areas
· Call recordings
· Witness statements and contact details
· Customer or client accounts and records
· Financial transaction information
· Information relating to health and safety (including incident investigation details and reports and accident book records)
· Correspondence
We also collect the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:
· Health information
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
· Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
· Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests - we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· We process personal information because it is necessary to provide safe, effective, and personalised care to our clients. Collecting and using information such as contact details, health conditions, care needs, medication requirements, allergies, and medical history allows us to make informed decisions, tailor care plans, and respond promptly to health needs or emergencies. This processing benefits both the individual and our organisation by ensuring continuity of care, safeguarding client wellbeing, and maintaining high standards of service. The risks to individuals’ privacy are minimized through strict data protection policies, access controls, staff training, and secure storage. We have carefully considered the balance between our need to process this information and the potential impact on individuals, and we are confident that the benefits of providing safe and reliable care.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information for safeguarding or public protection reasons are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· We process personal information to safeguard the wellbeing of clients, staff, and the wider public. Collecting and using information such as health data, care needs, incident reports, and records of concerns or previous investigations enables us to identify, prevent, and respond to risks of harm, abuse, or neglect. This processing benefits the individuals involved by helping to protect them from potential harm and ensures a safe care environment. Risks to privacy are mitigated through secure storage, strict access controls, staff training, and compliance with legal and regulatory requirements. The benefits of protecting vulnerable individuals and maintaining a safe and to ensure accountable service
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information to comply with legal requirements are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· We process personal information, including identification documents, health and safety records, criminal offence data, financial and tax information, and right-to-work details, to ensure compliance with legal and regulatory obligations. This is necessary to meet statutory requirements, protect clients and staff, and maintain a lawful, safe, and accountable service. Collecting and using this information helps prevent legal breaches, supports investigations, and ensures appropriate reporting to regulatory authorities. The processing is proportionate, secure, and limited to the information required, so the benefits of legal compliance, safety, and to ensure accountability.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information for recruitment purposes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· We process personal information during recruitment to identify, assess, and appoint suitably qualified candidates who can provide safe and effective care. Collecting this information allows us to verify qualifications, right-to-work status, and suitability for roles, ensuring compliance with regulatory standards and the safety of our clients. All information is handled securely and with respect for candidates’ privacy.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information for information updates, marketing or market research purposes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· We process personal information for information updates, marketing, and market research to keep clients and stakeholders informed about our services, improvements, and relevant opportunities. Collecting this information allows us to provide useful updates, enhance services, and ensure communications are relevant and beneficial. All information is handled securely and with respect for individuals’ privacy
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· We process personal information to handle queries, complaints, or claims efficiently and fairly. Collecting this information allows us to investigate concerns, provide appropriate responses, and resolve issues promptly while ensuring the safety and well-being of all involved. All information is handled securely and with respect for individuals’ privacy.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Where we get personal information from
· Directly from you
· Regulatory authorities
· Family members or carers
· Other health and care providers
· Social services
· Insurance companies
· Councils and other public sector organisations
· Relevant regulatory authorities
· Previous employers
· Suppliers and service providers
· Hospitals, GP practices, community nursing teams, and other regulated health or social care services involved in the patient’s care.
How long we keep information
Infinity Trust Care Ltd retains personal information only for as long as necessary to fulfil the purposes for which it was collected, including to meet legal, regulatory, contractual, safeguarding and insurance requirements.
Retention periods are determined in line with UK GDPR, the Data Protection Act 2018, NHS Records Management Code of Practice, and other applicable legislation.
In general:
• Service user records, including care plans and health information, are retained in line with NHS retention guidance (typically up to 8 years after services end, unless a longer period is required).
• Staff and employment records are retained for up to 6 years after employment ends, or longer where legally required.
• Payroll, financial and tax records are retained for 6 years from the end of the relevant financial year.
• Right to work and recruitment records are retained in accordance with immigration and employment law.
Where retention periods expire, personal data is securely deleted or destroyed. Retention decisions and justifications are documented in the organisation’s internal data retention schedule.
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Who we share information with
Data processors
Sleek (accounting\/payroll software, UK)
This data processor does the following activities for us: Processor 1: Name \/ Category: Sleek (accounting\/payroll software, UK) What it does: Processes payroll, accounts, and staff salary records. Processor 2: Name \/ Category: Bright HR (HR software, UK) What it does: Manages employee HR records, leave, and absences. Processor 3: Name \/ Category: Wirehouse (HR\/employer services, UK) What it does: Provides HR, contracts, and health & safety support. Processor 4: Name \/ Category: Xero (financial software, UK) What it does: Processes payroll and financial transactions. Processor 5: Name \/ Category: Care Control (care management software, UK) What it does: Stores client care plans and manages rostering for carers and clients. Processor 6: Name \/ Category: Care Checks (compliance\/verification, UK) What it does: Conducts DBS, right-to-work, and compliance checks. Processor 7: Name \/ Category: QCS (compliance software, UK) What it does: Provides policies and procedures for regulatory compliance. Processor 8: Name \/ Category: Care Academy (training platform, UK) What it does: Manages staff training records and courses.
Others we share personal information with
· Other health providers (eg GPs and consultants)
· Insurance companies, brokers and other intermediaries
· Care providers
· Organisations we need to share information with for safeguarding reasons
· Emergency services
· Professional advisors
· External auditors or inspectors
· Organisations we’re legally obliged to share personal information with
· Suppliers and service providers
Duty of confidentiality
We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:
· you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
· we have a legal requirement (including court orders) to collect, share or use the data;
· on a case-by-case basis, 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);
· If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
· If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113