Privacy notice
How PlaceWell collects, uses, shares and protects personal data submitted through the placement referral platform.
- Effective date
- [Effective Date]
- Last updated
- [Last Updated]
This notice explains how PlaceWell handles personal data when you visit our website or use the PlaceWell placement platform. It is written for the professionals who use the platform, and for the people whose information is shared with us through a referral. Where this page shows a detail in square brackets, that detail has not yet been confirmed for publication.
1. Who we are
PlaceWell provides a secure online platform that local authority and ICB commissioning teams use to make, track and agree placements for adults with complex needs.
- Trading name
- PlaceWell
- Registered legal name
- [Company Name]
- Company number
- [company registration number]
- Registered address
- [registered address]
- Website
- [website URL]
- Privacy contact
- [privacy contact email]
- Data protection lead
- [data protection lead name or role]
- ICO registration number
- [ICO registration number]
Our role in the data
For most information about a person being referred, the referring local authority or ICB decides why and how the information is used, and PlaceWell processes it on their behalf under a written agreement. For information about the professionals who hold PlaceWell accounts, and for the running of our own website, PlaceWell decides how that information is used. Our data processing agreement sets out the terms that apply when we act on a commissioning organisation's behalf.
2. What personal data we collect
Account and professional contact data
- Name, job title, work email address and work telephone number
- The organisation and team you work for
- Your role and permissions on the platform
- Sign-in records, two-factor authentication status and activity logs
Referral and placement data
When a referral is submitted, the referring organisation shares information about the person being placed. Depending on the referral, this can include:
- Identifying details such as name, date of birth, reference numbers and current address
- Details of care and support needs, diagnoses, communication needs and daily living needs
- Risk, safeguarding and mental capacity information
- Funding, placement history and commissioning information
- Documents uploaded to support the referral, such as assessments and care plans
- Messages, notes and decisions recorded on the case by professionals
Special category and criminal offence data
Referral information usually includes special category data — in particular data about health, and sometimes about ethnicity, religion or sexual orientation where that is relevant to a placement. It can also include criminal offence data where that is relevant to risk. We treat this information as highly sensitive and restrict access to it.
Technical and usage data
- IP address, browser type and device information
- Pages visited and actions taken on the platform
- Security, error and audit logs
3. How we collect personal data
- Directly from you, when you create or use an account, complete a referral form, upload a document or send us a message
- From your employing organisation, when it asks us to set up or change an account
- Automatically, through our servers and cookies when you use the website and platform
- From service providers who help us run the platform, such as our hosting and email providers
We do not buy personal data from data brokers, and we do not collect information about people being referred from anyone other than the referring organisation and the professionals it authorises.
4. Why we use personal data
- To create and manage accounts, and to authenticate the people who sign in
- To receive, process, track and progress placement referrals
- To share placement options and supporting documents with the referring team
- To send service notifications about cases, messages and decisions
- To keep an audit trail of what happened on a case and who did it
- To keep the platform secure, prevent misuse and investigate incidents
- To provide support, respond to enquiries and improve the service
- To meet our legal, regulatory and contractual obligations
We do not use personal data held in referrals for marketing, and we do not sell personal data.
5. Legal bases for processing under UK GDPR
We must have a legal basis for every use of personal data. Where PlaceWell acts on behalf of a commissioning organisation, that organisation identifies the legal basis and instructs us. The bases below apply to the processing PlaceWell determines.
| What we do | Legal basis | Notes |
|---|---|---|
| Provide accounts and platform access to professional users | Contract — Article 6(1)(b) | Necessary to provide the service to the user's organisation. |
| Operate, secure and support the platform | Legitimate interests — Article 6(1)(f) | Our interest in running a secure, reliable service. [Legitimate interests assessment reference] |
| Process referral information on behalf of a commissioning organisation | [Legal basis identified by the referring organisation] | The referring organisation is the controller and sets the basis. |
| Handle special category data within referrals | [Article 9 condition identified by the referring organisation] | Typically linked to health or social care purposes. Confirm with the controller. |
| Meet legal and regulatory obligations | Legal obligation — Article 6(1)(c) | For example, responding to lawful requests and retaining records we must keep. |
| Set non-essential cookies | Consent — Article 6(1)(a) | You can change your choice at any time on the cookie policy page. |
7. International data transfers
Our intention is that personal data processed through the platform is stored in the United Kingdom or the European Economic Area. Where any transfer outside the UK is necessary, we put a lawful transfer mechanism in place before the transfer happens.
| Transfer | Destination | Safeguard |
|---|---|---|
| [Transfer description] | [Destination country] | [UK adequacy regulations / International Data Transfer Agreement / UK Addendum to the EU SCCs] |
The row above is a placeholder format. Complete or remove it once transfers have been confirmed.
8. How long we keep personal data
We keep personal data only for as long as we need it. Where we hold data on behalf of a commissioning organisation, we follow the retention period set out in our agreement with them, and we delete or return the data when the agreement ends.
| Information | Retention period |
|---|---|
| Referral and placement records | [Retention period] |
| Documents uploaded to a case | [Retention period] |
| Account records for professional users | [Retention period] |
| Security, sign-in and audit logs | [Retention period] |
| Enquiries sent through the website | [Retention period] |
| In-platform notifications | [Retention period] |
Retention periods are configured in the platform and applied automatically. Where a record must be kept longer — for example because of a legal claim or an ongoing investigation — we keep only what is necessary for that purpose.
9. How we keep personal data secure
- Access is restricted by role, so people only see the cases they need to see
- Data is encrypted in transit, and at rest by our hosting provider
- Two-factor authentication is required for PlaceWell staff accounts
- Sessions time out after a period of inactivity
- Actions on a case are recorded in an audit trail
- Uploads are restricted by file type and size
- Access rules are tested regularly using automated checks
No online service can be completely secure. If a personal data breach occurs, we follow our incident procedure, notify the affected commissioning organisation without undue delay, and support any notification they must make to the Information Commissioner's Office or to affected individuals.
10. Your data protection rights
Under UK data protection law you have the rights set out below. Some rights apply only in certain circumstances.
| Right | What it means |
|---|---|
| Access | Ask for a copy of the personal data we hold about you. |
| Rectification | Ask us to correct information that is wrong or incomplete. |
| Erasure | Ask us to delete your data where there is no good reason for us to keep it. |
| Restriction | Ask us to pause how we use your data while a concern is resolved. |
| Objection | Object to processing we carry out on the basis of legitimate interests. |
| Portability | Ask for data you gave us in a portable format, where the right applies. |
| Withdraw consent | Withdraw consent at any time where we rely on it, such as for cookies. |
| Automated decisions | Ask about automated decision-making. PlaceWell does not make placement decisions automatically — decisions are made by people. |
If your request relates to information held about a person who has been referred, the referring local authority or ICB is normally responsible for answering it. Contact them first; if you contact us instead, we will pass the request on and help them respond.
To exercise a right in relation to your own account, email [privacy contact email]. We will respond within one month, and will tell you if we need longer because the request is complex. We may ask you to confirm your identity first. There is normally no charge.
12. Children's privacy
The PlaceWell platform is for adult social care professionals. Accounts are not made available to children, and the website is not directed at children.
Referral information relates to adults. If information about a person under 18 is shared with us — for example as part of transition planning or because a family member is mentioned — we handle it with the same care and additional sensitivity, on the instructions of the referring organisation. If you believe a child's data has been shared with us in error, contact [privacy contact email].
13. Changes to this notice
We review this notice regularly and update it when our processing changes. The effective date and last updated date at the top of the page show when it last changed. Where a change is significant, we will tell account holders directly.
14. How to contact us
- Privacy enquiries
- [privacy contact email]
- Data protection lead
- [data protection lead name or role]
- Post
- [registered address]
- General enquiries
- Use the contact page on this website
15. How to complain
If you are unhappy with how we have handled your personal data, please contact us first so we can try to put it right. You also have the right to complain to the Information Commissioner's Office, the UK supervisory authority for data protection.
- Website
- ico.org.uk
- Helpline
- 0303 123 1113
- Post
- Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Complaining to the ICO does not affect any other legal rights or remedies you may have.
Need something that is not covered here? Contact PlaceWell.