Privacy Policy

Plain English Summary

Spring Point Ltd takes your privacy seriously. This policy explains what personal data we collect, why we collect it, how we use it and your rights under UK law. We act as the data controller for your personal data. We will never sell your data or share it with third parties without a lawful basis for doing so. If anything here is unclear, please contact us — we are happy to explain in plain language.

Who We Are

Spring Point Ltd (referred to in this policy as "Spring Point", "we", "our" or "us") is a regulated introductory care agency registered in England and Wales under Company Number 00000000.

Our registered address is: 114 Blackheath Road, London SE10 8DA, United Kingdom.

Spring Point is the data controller for personal data collected through our website at springpoints.co.uk, our assessment and matching services, and all related communications.

We are registered with the Information Commissioner's Office (ICO) under registration number ZA000000. Our processing of personal data is governed by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

For all data protection queries, please contact us at: info@springpoints.co.uk or by post at the address above.

Data We Collect

Depending on your relationship with Spring Point (as a Client, a family member acting on behalf of a Client, or a Support Worker), we may collect the following categories of personal data:

2.1 Client & Family Member Data

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Identity data: Full name, date of birth, gender

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Contact data: Home address, telephone number, email address

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Care needs data: Health conditions relevant to support requirements, mobility limitations, cognitive status, dietary requirements, preferences and daily routines

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Financial data: Payment details, invoicing records and fee agreements (note: we do not store card details)

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Communication records: Records of emails, calls and correspondence with Spring Point

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Referral data: How you came to hear about Spring Point

2.2 Support Worker Data

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Identity data: Full name, date of birth, gender, photograph (if provided)

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Contact data: Home address, telephone number, email address

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Right to work: Documentation confirming the right to work in the United Kingdom

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DBS data: Enhanced DBS certificate reference, disclosure date and disclosure content (where relevant)

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Reference data: Names and contact details of referees and the content of references received

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Employment history: Previous experience, qualifications and skills relevant to support work

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Banking data: Bank account details for fee payment purposes

2.3 Website Visitor Data

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Technical data: IP address, browser type and version, time zone, operating system and platform

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Usage data: Pages visited, time spent, referral source and on-site behaviour

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Cookie data: Data collected via cookies as described in Section 11 of this policy

How We Collect Your Data

Spring Point collects personal data through the following channels:

Direct contact: When you call us, email us, complete a contact or assessment form on our website, or visit our office

Assessment process: During your initial assessment call or subsequent conversations with our team about care needs and preferences

Support Worker registration: When a Support Worker submits their details, references, DBS certificate and other information for registration

Third parties: Reference information from named referees; DBS disclosure information from the Disclosure and Barring Service; information from other professionals involved in a Client's care, where appropriate and consented

Our website: Through cookies, analytics tools and contact forms when you browse or interact with springpoints.co.uk

We Do Not Buy Data
Spring Point never purchases personal data from data brokers or third-party marketing lists. All personal data we hold is provided directly by the individual or collected in the course of delivering our services.

How We Use Your Data

Spring Point uses personal data for the following purposes:

Purpose	Description	Legal Basis
Client Assessment	Understanding your care needs and preferences to identify a suitable Support Worker introduction	Contract / Legitimate Interests
Matching & Introduction	Comparing Client needs with Support Worker profiles and facilitating formal introductions	Contract
Vetting & Safeguarding	Verifying DBS disclosures, checking references and maintaining safeguarding standards	Legal Obligation / Legitimate Interests
Communication	Responding to enquiries, providing updates, sending confirmation and administrative correspondence	Contract / Legitimate Interests
Fee Administration	Processing invoices, recording payments and managing financial relationships	Contract / Legal Obligation
Service Improvement	Analysing how our services are used to improve quality, outcomes and client experience	Legitimate Interests
Legal Compliance	Meeting obligations under applicable law, including data protection, tax and employment legislation	Legal Obligation
Marketing (opt-in only)	Sending service updates, news and relevant communications where you have consented to receive them	Consent
Complaints & Disputes	Investigating and resolving complaints, and defending legal claims where necessary	Legitimate Interests / Legal Obligation

Marketing Communications

We will only send you marketing communications if you have explicitly opted in to receive them. You may withdraw consent at any time by contacting us at info@springpoints.co.uk or by clicking the unsubscribe link in any marketing email.

Legal Bases for Processing

UK GDPR requires us to have a lawful basis for every type of processing we carry out. The main legal bases we rely on are:

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Performance of a contract: Processing necessary to fulfil our introductory service agreement with you, including assessment, matching and ongoing advisory support

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Legal obligation: Processing necessary to comply with our legal obligations, including safeguarding duties, tax reporting and data protection law

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Legitimate interests: Processing for the purposes of improving our services, preventing fraud, managing complaints and communicating important service updates — where these interests are not overridden by your rights

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Consent: Where we rely on your consent (for example, for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing

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Where we rely on legitimate interests, we have carefully assessed that our interests do not override your rights and freedoms. You have the right to object to processing based on legitimate interests at any time — please see Section 10.

Special Category Data

Some of the personal data we collect falls into the category of special category data under UK GDPR — this is data that is particularly sensitive and requires additional protection. For Spring Point, this includes:

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Health data: Information about a Client's medical conditions, physical or cognitive limitations, medication requirements or other health-related needs that are relevant to their care arrangement

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Criminal records data: Enhanced DBS disclosure information relating to Support Workers, which may include details of criminal convictions and cautions where relevant to their suitability for work with vulnerable adults

We process special category data only where:

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You have given explicit consent to the processing of your data for one or more specified purposes

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Processing is necessary for the provision of health or social care services and is carried out by a professional bound by professional secrecy

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Processing is necessary for reasons of substantial public interest relating to safeguarding vulnerable adults

We handle all special category data with the highest standards of care and confidentiality. Access is restricted to authorised Spring Point personnel only.

Sharing Your Data

Spring Point does not sell your personal data. We will only share your data in the following circumstances:

With Support Workers (and vice versa): Sharing Client care needs and preferences with prospective Support Workers — and Support Worker profiles with Clients — is fundamental to our introductory service. This sharing is done only where necessary and proportionate to enable a meaningful introduction

With the Disclosure & Barring Service: For DBS check processing and verification of Support Worker disclosure certificates

With payment processors: Sharing billing data with our trusted payment processing provider for the purpose of processing Spring Point' fees. We do not share payment data with Support Workers or Clients beyond what is necessary

With professional advisers: Accountants, solicitors and auditors where necessary for legal, financial or regulatory purposes, bound by obligations of confidentiality

With statutory bodies: HM Revenue & Customs, the Information Commissioner's Office, police, local authority safeguarding teams or other regulatory authorities where we are legally required or permitted to do so

With your consent: Where you have explicitly authorised us to share your data with a named third party for a specific purpose

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All third parties with whom we share data are required to process it in accordance with UK GDPR and our contractual instructions. We do not allow third parties to use your data for their own purposes.

International Transfers

Spring Point is a UK-based agency and processes all personal data within the United Kingdom. We do not routinely transfer personal data outside the UK.

In the unlikely event that any transfer to a third country or international organisation were necessary, we would ensure that such transfer is subject to adequate safeguards as required by UK GDPR, including adequacy decisions, standard contractual clauses or binding corporate rules as appropriate.

How Long We Keep Your Data

Spring Point retains personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Our standard retention periods are as follows:

Data Category	Retention Period	Reason
Client assessment records	6 years from end of service	Legal claims / regulatory compliance
Care arrangement records	6 years from end of arrangement	Legal claims / contractual obligations
Financial & invoicing records	6 years from financial year end	HMRC & Companies Act requirements
Support Worker registration	Duration of registration + 6 years	Safeguarding & legal liability
DBS disclosure data	6 months from date of check	ICO guidance on DBS data retention
Reference records	Duration of registration + 2 years	Legitimate interests in safeguarding
Website analytics data	Up to 26 months	Service improvement
Marketing consent records	Until withdrawal of consent + 1 year	Demonstrating lawful processing
Complaint records	6 years from resolution	Legal claims / regulatory compliance

Data may be retained beyond these periods where required by law, subject to ongoing legal proceedings, or where retention is necessary to protect the vital interests of an individual.

Requesting Early Deletion

You may request early deletion of your personal data at any time by contacting us at info@springpoints.co.uk. We will consider your request in accordance with our legal obligations and respond within one calendar month.

Your Rights in Detail

Under UK GDPR, you have the following rights in relation to your personal data. These rights are not absolute and may be subject to exemptions, but we will always respond to requests within the required timeframe.

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Right of Access (Subject Access Request)

You have the right to request a copy of the personal data we hold about you, free of charge, within one calendar month of your request. We may extend this period by a further two months for complex or numerous requests.

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Right to Rectification

If any personal data we hold about you is inaccurate or incomplete, you have the right to require us to correct it without undue delay. Please keep us informed of any changes to your personal information.

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Right to Erasure ('Right to Be Forgotten')

You may request that we delete your personal data where: it is no longer necessary for the purpose it was collected; you have withdrawn consent; you have objected to processing; or the data has been unlawfully processed. This right is subject to our legal retention obligations.

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Right to Restriction

You may ask us to suspend active processing of your data in certain circumstances — for example, while you contest its accuracy or while we are investigating an objection. The data is stored but not used during the restriction period.

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Right to Data Portability

Where processing is based on consent or contract and is carried out by automated means, you have the right to receive your data in a structured, commonly used, machine-readable format, and to have it transmitted to another controller.

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Right to Object

You have an absolute right to object to processing for direct marketing purposes. You may also object to processing based on legitimate interests — we will then cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

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To exercise any of these rights, please contact us at info@springpoints.co.uk or in writing to 114 Blackheath Road, London SE10 8DA. We will respond within one calendar month of receiving your request. There is no charge for making a request.

Cookies & Website Data

11.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They allow the website to recognise your device on subsequent visits and enable certain functionality.

11.2 Cookies We Use

Cookie Type	Purpose	Duration
Essential	Required for the website to function correctly — cannot be disabled	Session
Analytics	Anonymous data about how visitors use our site, used to improve performance	Up to 26 months
Functional	Remembering your preferences and settings to improve your experience	Up to 12 months
Marketing	Used to serve relevant advertisements (only with your explicit consent)	Up to 12 months

11.3 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our website. You can also opt out of analytics tracking by adjusting your browser settings or using browser add-ons such as Google Analytics Opt-out Browser Add-on.

Our website will display a cookie consent notice on your first visit, giving you the option to accept or decline non-essential cookies.

Data Security

Spring Point takes the security of your personal data seriously and has implemented appropriate technical and organisational measures to protect it against unauthorised access, loss, alteration or disclosure.

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Access controls: Personal data is accessible only to authorised Spring Point personnel who need it to perform their role

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Secure storage: Digital records are stored on password-protected, access-controlled systems. Physical documents are stored securely

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Website security: Our website uses HTTPS encryption to protect data transmitted between your device and our servers

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Staff training: All Spring Point personnel are trained in data protection obligations and our internal security procedures

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Vendor management: Third-party processors are subject to data processing agreements ensuring they meet our security standards

Data Breaches
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and inform affected individuals without undue delay, in accordance with our legal obligations.

Children's Privacy

Spring Point' services are intended for adults aged 18 and over. Our website is not directed at children and we do not knowingly collect personal data from individuals under the age of 16.

Where Spring Point provides support services involving or in the vicinity of children — for example, where a Client has dependent children living in the household — any incidental data relating to those children will be handled with additional care and used only for the purposes of safely delivering the care arrangement.

If you believe we have inadvertently collected data relating to a child under 16, please contact us immediately at info@springpoints.co.uk and we will take steps to delete that data.

Links to Other Websites

Our website may contain links to third-party websites, resources and services. These links are provided for your convenience and information only.

Spring Point has no control over the content or privacy practices of third-party websites and is not responsible for their privacy policies. We encourage you to read the privacy policy of every website you visit before submitting any personal data.

Our Privacy Policy applies only to data collected by Spring Point through our website, services and communications.

Changes to This Policy

Spring Point may update this Privacy Policy from time to time to reflect changes in our practices, the services we offer, or applicable law. We will notify registered Clients and Support Workers of material changes by email.

The updated Policy will be published on our website at springpoints.co.uk/privacy-policy with a revised effective date. We encourage you to review this page periodically to stay informed about how we protect your data.

Your continued use of our services after the effective date of any update constitutes your acknowledgement of the revised Policy.

Contact & Complaints

16.1 Contact Spring Point

For any questions, concerns or requests relating to this Privacy Policy or our processing of your personal data, please contact us:

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Email: info@springpoints.co.uk — we aim to respond within one calendar month

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Telephone: +44 788 273 2203 — Monday to Saturday, 8am to 7pm

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Post: 114 Blackheath Road, London SE10 8DA, United Kingdom — for written subject access requests or formal complaints

16.2 Complaints to the ICO

If you are not satisfied with our response to a data protection concern, or if you believe we are processing your personal data unlawfully, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

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Website: ico.org.uk

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ICO Helpline: 0303 123 1113

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ICO Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

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We always recommend contacting us in the first instance — we take all privacy concerns seriously and are committed to resolving them fairly, promptly and without the need for formal regulatory intervention wherever possible.

Spring Point Ltd — Registered in England & Wales. Company No. 00000000. ICO Registration: ZA000000. This policy is effective as of 1 January 2026.