Thorough Homecare Services

Privacy Policy

How we use your information

Thorough Recruitment Limited trading as Thorough Homecare Services – East Riding of Yorkshire

Version 1.3 Last updated 12 October 2026

For website visitors, care enquiries, professional referrals, people receiving care and representatives.

01

Who we are

Thorough Recruitment Limited is the data controller for the personal information covered by this notice. Thorough Homecare Services – East Riding of Yorkshire is its homecare trading name. Our adult homecare service supports people aged 18 and over.

This notice explains how we collect, use, protect and share information when you visit our website, contact us, request a care assessment, make a professional referral or receive care.

Website: www.thoroughhomecareservices.co.uk

For privacy enquiries and rights requests, contact the Registered Manager, Jean Dela Abortta-Kuleke.

Email: admin@thoroughhomecareservices.co.uk
Telephone: 01482 421810
Post: Thorough Homecare Services – East Riding of Yorkshire, Grosvenor House, 100–102 Beverley Road, Hull, HU3 1YA.
Office hours: Monday to Friday, 09:00–17:00.

02

Information we collect and where it comes from

We collect names, contact details, addresses, age or date of birth where needed, relationship to the person seeking care, professional role and organisation, care preferences, funding arrangements, invoices and correspondence. When needed for assessment or care we also collect health conditions, disability, medication, support needs, risk assessments, safeguarding information, communication requirements and relevant care records. Religious or cultural preferences may be recorded where relevant to personalised care.

We receive information from you, your authorised representative, referring professionals, local authorities, NHS teams and other care professionals involved in your support. We check the authority of representatives and referrers where necessary. Website systems may collect IP addresses, device and browser information, security logs and cookie choices; our Cookie Policy explains storage and tracking technologies.

Only provide information needed for the enquiry. Do not put detailed medical records or unnecessary information about other people into a general contact form. We will explain any secure route needed for supporting records.

03

Why we use information and our legal grounds

We use the following legal grounds where their conditions are met. The basis depends on the purpose and our relationship with you.

Enquiries, quotations and steps requested before a care contract. Article 6(1)(b), where you are the contracting person; otherwise Article 6(1)(f), legitimate interests in responding to enquiries and assessing service suitability. We balance those interests against individuals' rights.

Care assessment, planning and delivery. Article 6(1)(b) where applicable to the individual's contract; Article 6(1)(c) for identified statutory obligations; or Article 6(1)(f) for necessary assessment and service administration where neither applies. Relevant health and social care information is additionally processed under Article 9(2)(h), with the Data Protection Act 2018 Schedule 1 paragraph 2 condition and applicable confidentiality safeguards. We limit sensitive information to what is necessary for the particular purpose.

Quality monitoring, complaint investigation and service management. Article 6(1)(f), and Article 6(1)(c) where a specific legal obligation applies. Article 9(2)(h) may apply to necessary management of health or social care systems and services; Article 9(2)(f) may apply to legal claims.

Safeguarding. The applicable Article 6 basis is documented for the circumstances. Sensitive-data processing may rely on Article 9(2)(g) with the relevant Schedule 1 safeguarding condition, or Article 9(2)(h) where applicable. We maintain an appropriate policy document where required. Emergency vital-interest grounds are used only where their specific conditions are met.

Website security and fraud prevention. Article 6(1)(f), legitimate interests in protecting systems and users. Optional direct marketing: consent where required, with a separate opt-in and easy withdrawal. We do not make marketing consent a condition of care or a referral.

Where consent is our basis, you can withdraw it. Withdrawal does not affect earlier lawful processing. Agreement to receive care is distinct from the legal grounds for processing information.

04

Sharing information

We share the minimum necessary information with authorised care staff and, where appropriate, involved health and care professionals, commissioners, safeguarding authorities, emergency services, regulators including CQC, insurers and professional advisers. Disclosure must have a lawful reason and appropriate confidentiality safeguards. Relatives do not automatically have access to care records.

Contracted website, hosting, email, care-record and IT providers may process information on our instructions under suitable contracts. We do not sell personal information. Referrals do not automatically authorise unrelated sharing with the Healthcare Recruitment & Staffing division or Thorough Healthcare Solutions Ltd.

05

Security and international processing

We use proportionate organisational and technical safeguards, including restricted access, staff confidentiality requirements, training and secure handling. No online system is entirely risk free. If information needs to be sent securely, contact us for the appropriate route.

If information is transferred outside the UK, we use a lawful transfer mechanism, such as applicable adequacy regulations or appropriate contractual safeguards and required assessments. Contact the privacy lead for information about safeguards relevant to your data.

06

How long we keep information

We keep information only for as long as necessary for the stated purpose, relevant obligations and the protection of legal rights. Retention is reviewed and information is securely deleted or anonymised when no longer needed. A legal hold or active safeguarding investigation may require longer retention.

We determine retention using the following criteria. Enquiries and referrals that do not lead to care are retained only while follow-up, a referral decision or a related concern remains reasonably necessary. Care and assessment records are retained after care ends for the period needed to support care continuity, safeguarding, applicable health and social care records guidance, commissioner requirements and legal claims. Complaint records are retained for investigation, remedies, review, external escalation and justified evidence requirements. Financial records are retained for the applicable accounting and tax requirements. Website logs and cookie choice records are kept for a proportionate period needed for security, troubleshooting and evidence of privacy choices.

We review continued need at the end of the relevant period, document any justified extension and securely delete or anonymise information that is no longer required. Contact the Registered Manager for the retention period applying to a specific record.

07

Your rights and choices

Depending on the circumstances, you may request access, correction, erasure, restriction or portability, object to processing based on legitimate interests and withdraw consent. These rights have limits; for example, information may need to be retained to meet legal obligations. We do not use solely automated decisions producing legal or similarly significant effects under this service model.

Contact the privacy lead to exercise your rights. We may need proportionate identity or representative-authority checks. We normally respond within one month under the applicable rules and explain any lawful extension, clarification requirement or refusal. A complaint about handling information does not replace or pause a rights request.

Where information is necessary for assessment or safe care, not providing it may prevent us proceeding; we explain this at the time. Marketing and optional cookies remain optional.

08

Privacy complaints and changes

You can complain about our use of information by email, telephone or post using the privacy contact above. We acknowledge privacy complaints within 30 calendar days, investigate without undue delay, keep you informed and explain the outcome and available action. Our service target is acknowledgement within three working days.

You may complain to the Information Commissioner's Office: ico.org.uk/make-a-complaint 0303 123 1113. Contacting us first may help resolve your concern, but this does not remove your right to approach the ICO.

This notice is reviewed annually and whenever relevant processing changes. Material changes will be communicated appropriately. Last updated: 12 October 2026.

Policy references and review

ICO: right to be informed — ICO guidance
ICO: handling data protection complaints — ICO guidance
UK GDPR and Data Protection Act 2018, as amended. References checked 12 October 2026.

Policy owner and privacy contact: Jean Dela Abortta-Kuleke, Registered Manager and Nominated Individual.
Responsible organisation: Thorough Recruitment Limited trading as Thorough Homecare Services – East Riding of Yorkshire.
Version: 1.3. Last updated: 12 October 2026.
Next scheduled review: 12 October 2027, or sooner if processing changes.