Privacy Policy
This privacy notice tells you what to expect us to do with your personal information.
Contact details
CrossSense Ltd
113-115 Fonthill Road
London N4 3HH
Email: privacy@crosssense.com
What information we collect, use, and why
We collect or use the following information to provide patient care, services, pharmaceutical products and other goods:
- Name, address and contact details
- Gender
- Date of birth
- Next of Kin details including any support networks
- Emergency contact details
- Health information (including medical conditions, allergies, medical requirements and medical history)
- Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
- Payment details (including card or bank information for transfers and direct debits)
We also collect the following special category information to provide patient care, services, pharmaceutical products and other goods. This information is subject to additional protection due to its sensitive nature:
- Racial or ethnic origin
- Health information
We collect or use the following personal information for service user app or portal functionality:
- Names and contact details
- Addresses
- Payment details
- Account information, including registration details
We also collect the following special category information for patient app or portal functionality. This information is subject to additional protection due to its sensitive nature:
- Racial or ethnic origin
- Health information
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. Read more about the right of access.
- Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
- Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
- Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
- Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
- 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. Read more about the right to data portability.
- Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
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 to provide patient care, services, pharmaceutical products and other goods 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.
- 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 patient app or portal functionality 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.
- 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.
Where we get personal information from
- Directly from you
- Family members or carers
How long we keep information
We keep your personal information only for as long as is necessary for the purposes for which it was collected, in accordance with the UK GDPR.
Our retention schedule is based on legitimate business needs, statutory requirements, and the principles of data minimisation and storage limitation. We review this schedule annually and update it as necessary to ensure compliance and operational relevance.
Personal information is retained for the following periods:
- Account details, including name, contact information, and registration data, are retained for up to three years after the account is closed or the last interaction with the service, unless a longer period is required by law.
- Health and care-related information, including medical history, allergies, medication, and care needs, is retained for a maximum of seven years from the date of the last service interaction.
- Payment details, including card or bank information, are retained only for up to one year after the final transaction or account closure. These details are processed through secure, compliant third-party providers and are not stored in full by us.
- Usage data collected through the app, such as interaction logs or error reports, is anonymised and retained for up to 12 months to support service improvement and technical troubleshooting. After this period, such data is permanently deleted.
- Personal settings, preferences, or customisations within the app are retained for up to three years after account closure to support future re-engagement, if applicable. These are deleted thereafter.
- Communications and support records are retained for up to one year from the date of the last interaction, after which they are deleted.
All personal data is stored securely using encryption and access controls. Upon expiry of the retention period, data is permanently and irreversibly deleted using secure, automated methods.
We regularly review the data we hold to identify opportunities to delete, anonymise, or pseudonymise information where possible. Staff are trained on the retention schedule and are responsible for adhering to it. We maintain records of retention decisions and review processes to ensure accountability.
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.
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
Questions or Concerns?
If you have any questions about how we handle your personal data or would like to exercise your data protection rights, please don't hesitate to contact us.
Contact us about privacy