The UK Caldicott Guardian Council customer privacy notice
This privacy notice tells you what to expect us to do with your personal information.
Contact details
If you have a question about any aspect of this privacy notice, you can contact us by email at england.ukcgcsecretariat@nhs.net
What information we collect, use, and why
We collect or use the following information for service updates or marketing purposes:
Names and contact details
Marketing preferences
Records of consent, where appropriate
We collect or use the following information to comply with legal requirements:
Name
Contact information
Financial transaction information
We collect or use the following information for recruitment purposes:
Contact details (eg name, address, telephone number or personal email address)
Date of birth
National Insurance number
Photo for website
Employment history (eg job application, references or secondary employment)
Bank details
Conflict of interest or gift declarations, including Council members’ spouses or close family members
We collect or use the following personal information for dealing with queries, complaints or claims:
Names and contact details
Correspondence
We also collect the following special category information to deal with queries, complaints, or claims. This information is subject to additional protection due to its sensitive nature:
Racial or ethnic origin
Political opinions
Religious or philosophical beliefs
Trade union membership
Health information
Sex life information
Sexual orientation information
The UKCGC does not routinely request special category information, but individuals seeking advice may disclose it to us. Where it is not necessary for the UKCGC to hold this information to respond to the query, complaint, or claim, we will inform the individual disclosing it.
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. You can read more about this right here.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
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. You can read more about this right here.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
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 for service updates or marketing 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 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:
UKCGC relies on legitimate interest in using personal information to send newsletters to ensure that Caldicott Guardians receive important, relevant, and up-to-date guidance and resources to help them comply with legal and ethical obligations related to data security and confidentiality. Caldicott Guardian contact details are collected from a regular Data Security and Protection Toolkit (DSPT) extract from NHS England, and only include Caldicott Guardians registered by an organisation in its latest DSPT submission.
Recipients of this information may unsubscribe at any time by following the instructions provided on the email received. Former Caldicott Guardians who are no longer recorded on organisational DSPT submissions, or individuals interested in receiving information and training opportunities, are not included in the DSPT extract provided by NHS England. However, a sign-up form is provided on the UKCGC website, which permits individuals interested in receiving this information to join the mailing list with consent.
For more information on our use of legitimate interests as a lawful basis, you can contact us using the contact details above.
Our lawful bases for collecting or using personal information for legal requirements are:
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.
Our lawful bases for collecting or using personal information for recruitment purposes are:
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.
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.
Where we get personal information from
Directly from you
Health care providers
How long we keep information
| Record | Retention | Disposal |
|---|---|---|
| Board meetings | Up to 20 years | Review and transfer to Place of Deposit |
| Policies, strategies and operating procedures / business plans | Life of organisation + 6 years | Review and transfer to Place of Deposit |
| Press releases and important internal communications | 6 years | Review and transfer to Place of Deposit |
| Contracts and Tenders | 6 to 15 years | Review and destroy if no longer required |
| Complaints | 10 years | Review and destroy if no longer required |
| Freedom of Information and Subject Rights requests | 3 to 6 years | Review and destroy if no longer required |
| Accounts | 3 years | Review and destroy if no longer required |
| Expenses | 6 years | Review and destroy if no longer required |
| Financial transaction records | 6 years | Review and destroy if no longer required |
| Invoices | 6 years from end of the financial year they relate to | Review and destroy if no longer required |
| Council member record | Keep until 80th Birthday | Review and consider transfer to Place of Deposit |
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
Joint controllers
The Office of the National Data Guardian
We process your personal information with that joint controller for the following reason: The Office of the National Data Guardian (ONDG) acts as the UKCGC’s organisational sponsor, to which we are accountable in line with an agreed sponsorship framework which sets out the roles, duties and funding arrangements. The ONDG provides secretariat support to the UKCGC, facilitating payment of expenses as set by the Department of Health and Social Care, and providing IT support and storage as laid out within their hosting agreement with NHS England.
The UKCGC Chair is an NDG Panel member.
Others we share personal information with
Professional or legal advisors
Organisations we’re legally obliged to share personal information with
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
Website: https://www.ico.org.uk/make-a-complaint
Last updated: 28 April 2025