1. Who We Are
Life Care Training is a specialist healthcare training provider delivering face-to-face statutory and mandatory training to care homes across South East England.
For the purposes of UK data protection law, the data controller is:
Nathan Kwabi, trading as Life Care Training
Email: info@lifecaretraining.uk
2. What Personal Data We Collect
We collect different types of personal data depending on how you interact with us:
Website visitors
Your IP address, browser type, device information, pages visited, and referring website. This data is collected through analytics cookies (see our Cookie Policy for details).
Enquiry form submissions
Your name, email address, phone number, job title, organisation name, and any details you include in your message.
Care home clients (managers and booking contacts)
Name, job title, email address, phone number, organisation name, billing address, and correspondence relating to training bookings.
Training delegates
Name, job title, employer name, attendance records, competency assessment results, engagement observations, and feedback form responses. This data is collected on-site during training sessions and through post-training follow-up assessments.
We do not intentionally collect special category personal data (such as health information, ethnicity, or religious beliefs) through our website or training registration process. If competency assessments reveal information about a delegate's physical capability (for example, during manual handling practical assessments), this data is treated with additional care and processed only for the purpose of evidencing training competency.
3. How and Why We Use Your Data
We only process personal data when we have a lawful basis to do so under UK GDPR Article 6. The information below explains what we do with your data, why, and the legal basis we rely on.
What we do
Respond to enquiries submitted through our website or by phone/email
Why
To provide you with the information or quotation you requested
Lawful basis
Article 6(1)(b) — necessary for pre-contractual steps taken at your request
What we do
Manage bookings, deliver training, and issue invoices
Why
To fulfil our contractual obligations to our care home clients
Lawful basis
Article 6(1)(b) — performance of a contract
What we do
Collect and process delegate training data (attendance, assessments, competency records, engagement observations)
Why
To deliver the training service, issue certificates, and provide your employer with CQC-ready evidence of staff competency
Lawful basis
Article 6(1)(f) — legitimate interests (see below)
What we do
Send post-training follow-up assessments to delegates
Why
To support spaced retrieval learning and generate competency evidence for CQC compliance
Lawful basis
Article 6(1)(f) — legitimate interests
What we do
Send information about our training courses to care home managers who have enquired or booked with us
Why
To keep existing and prospective clients informed about relevant training services
Lawful basis
Article 6(1)(f) — legitimate interests (with opt-out in every communication)
What we do
Collect website analytics data
Why
To understand how visitors use our website so we can improve it
Lawful basis
PECR statistical purposes exception (Schedule A1, Paragraph 5) — see our Cookie Policy
What we do
Retain financial and contractual records
Why
To meet our legal obligations for tax, accounting, and regulatory purposes
Lawful basis
Article 6(1)(c) — legal obligation
Legitimate interests explanation (delegate data)
Delegates attend our training sessions as employees of our care home clients. They are not party to our contract — their employer is. We rely on legitimate interests as the lawful basis for processing delegate data because: (1) our legitimate interest is delivering and evidencing the training service that their employer has contracted, (2) processing delegate names, attendance, and assessment results is necessary to fulfil this purpose, and (3) delegates reasonably expect their training provider to record their attendance and results, and this processing does not override their rights. We have conducted and documented a Legitimate Interests Assessment in accordance with ICO guidance.
4. Who We Share Your Data With
We do not sell your personal data to anyone. We do not share your data with third parties for their marketing purposes.
We may share your data with:
Your employer (for delegates)
Training attendance records, competency assessment results, engagement profiles, and certificates are shared with the care home that booked the training. This is the core purpose of the training service.
Service providers acting on our behalf
- Website hosting (Vercel Inc. — website served from European edge locations)
- Analytics (Google Analytics — acting as our data processor, not using data for its own purposes — see Cookie Policy)
- Email communications (Google Workspace)
- Automation tools (n8n, self-hosted in the UK)
Professional advisers
Accountants, legal advisers, and insurers where necessary for business operations.
Law enforcement or regulators
Where we are required to do so by law, or to protect our legal rights.
5. International Data Transfers
Our website is hosted by Vercel, which serves content from European edge locations. Google Analytics data is processed by Google LLC in the United States under the UK International Data Transfer Agreement and Google's Data Processing Amendment, which ensures an adequate level of protection for your data.
We do not otherwise transfer personal data outside the United Kingdom.
6. How Long We Keep Your Data
We retain personal data only as long as necessary for the purpose it was collected, or as required by law. Our retention periods are aligned with the NHS Records Management Code of Practice 2021 and relevant legal requirements:
Statutory and mandatory training records
(certificates, attendance, assessment results for safeguarding, infection prevention, fire safety, etc.)
Retention period
10 years after training delivered
Reason
NHS Records Management Code 2021; CQC Regulation 17 evidence requirements
Other training records and competency assessments
Retention period
6 years after training delivered
Reason
NHS Records Management Code 2021
Client contractual records
(bookings, invoices, correspondence)
Retention period
6 years after contract ends
Reason
Limitation Act 1980
Financial and tax records
Retention period
6 years plus current year
Reason
HMRC requirements
Website enquiry data
(where no booking follows)
Retention period
12 months after enquiry
Reason
Data minimisation — no ongoing purpose
Marketing contact data
Retention period
Until you opt out or 2 years of inactivity
Reason
Legitimate interests balanced against your right to object
Website analytics data
Retention period
2 months (GA4 setting)
Reason
DUAA statistical exception — minimum retention
Delegate feedback form responses
Retention period
10 years (retained with training records)
Reason
Evidence of training quality for CQC and quality assurance
Why our retention periods are longer than typical
Care homes rely on our training records as evidence during CQC inspections. A care home may be inspected at any point, and inspectors expect to see evidence of staff training. If we deleted records after a short period, care homes could fail inspections because they cannot evidence staff competency. Our retention periods reflect this sector-specific need.
7. Your Rights
Under UK data protection law, you have the right to:
Access your data
Request a copy of the personal data we hold about you.
Correct your data
Ask us to correct any inaccurate or incomplete personal data.
Delete your data
Ask us to delete your personal data. We will do so unless we have a legal obligation or legitimate reason to retain it (for example, training records required for CQC evidence — see retention schedule above).
Object to processing
Object to our processing of your data where we rely on legitimate interests. We will stop processing unless we can demonstrate compelling legitimate grounds.
Restrict processing
Ask us to restrict how we use your data in certain circumstances.
Data portability
Request your data in a structured, commonly used format.
Withdraw consent
Where we rely on consent (for example, marketing emails), you can withdraw it at any time by clicking the unsubscribe link or contacting us.
To exercise any of these rights, contact us at info@lifecaretraining.uk. We will respond within one calendar month. If we need to verify your identity before responding, the verification period does not count towards the one-month deadline (as amended by the Data (Use and Access) Act 2025).
If you are a delegate whose data we hold, please note that your training records are shared with your employer as part of the training service. If you request deletion of your training records, we will inform your employer, as this may affect their CQC compliance evidence.
8. Cookies and Analytics
Our website uses a small number of cookies for analytics purposes. We rely on the statistical purposes exception under the Privacy and Electronic Communications Regulations (as amended by the Data (Use and Access) Act 2025) for our use of analytics cookies. This means we do not require your consent to set these cookies, but you can opt out at any time.
For full details of the cookies we use and how to opt out, see our Cookie Policy.
9. How We Keep Your Data Safe
We take appropriate technical and organisational measures to protect your personal data, including:
- Secure, encrypted website (HTTPS)
- Access controls — only authorised individuals can access personal data
- Secure cloud-based tools with appropriate data processing agreements
- Regular review of data handling practices
No method of transmission or storage is completely secure. If you have concerns about data security, please contact us.
10. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in law, our services, or how we handle your data. Changes will be posted on this page with an updated "Last updated" date. We encourage you to review this page periodically.
11. Complaints
If you are unhappy with how we have handled your personal data, please contact us first so we can try to resolve the issue.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):
- Website: www.ico.org.uk
- Phone: 0303 123 1113
- Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
This Privacy Policy applies to Life Care Training and the lifecaretraining.uk website.
Have questions? Contact us at info@lifecaretraining.uk