Draft — not yet reviewed or approved for live use
Every [bracketed] placeholder below needs a real answer, and the whole page needs sign-off from whoever handles legal/compliance, before this is shown to real clients or their employees.
Privacy notice
Last updated: [date]
Who we are
[Legal entity name], registered in [jurisdiction], registered address [address]. [ICO registration number, if applicable]. Contact for privacy matters: [privacy contact email].
What we collect
Depending on which portal you use: employer contact name and email; clinician account details; and, for the person being assessed, name, date of birth, email, health questionnaire answers, uploaded documents, and consent records. Employers only ever see a fitness outcome and recommendations — never the full clinical record.
Why we process it
[Legal basis per processing activity to be confirmed — likely a mix of contract with the employer (Art. 6(1)(b)), legal obligation, and explicit consent for health data specifically, which is "special category" data under Article 9 and needs its own lawful condition separate from the Article 6 basis for everything else.]
How long we keep it
[Retention period(s) not yet finalised — occupational health records vary significantly by record and exposure type, and a single fixed period isn't appropriate. This will be set per case rather than as one global rule.]
Who we share it with
Document storage is self-hosted alongside the application — no third party involved. Transactional email (account and referral notifications) is sent via Resend. Application hosting is provided by Hetzner Online GmbH. [Confirm Resend's data processing location/safeguards for UK transfers before relying on this.]
Your rights
You can withdraw consent at any time from the consent page if you have an employee account. For access, correction, deletion, or any other request, contact [privacy contact email].
Complaints
You can complain to the UK Information Commissioner's Office at ico.org.uk or on 0303 123 1113.