Privacy Policy
Last updated: 02 March 2026 Version 1.0
Contents
1. Who We Are (Data Controller)
Our Complex Child is a healthcare management platform designed to help families caring for children with complex medical needs.
| Data Controller: | Our Complex Child |
| Contact Email: | privacy@ourcomplexchild.com |
| Data Protection Contact: | dpo@ourcomplexchild.com |
| Registered in: | United Kingdom |
We are registered with the Information Commissioner's Office (ICO) as required under UK data protection law.
2. Data We Collect
2.1 Account Information
- Name (first and last name)
- Email address
- Password (encrypted)
- Date of birth
- Relationship to child (e.g., parent, guardian)
- Phone number (optional)
2.2 Child Profile Information
- Child's name and date of birth
- NHS number (optional)
- Gender and ethnicity
- Medical conditions and diagnoses
- Allergies and comorbidities
2.3 Medical and Care Information
- Medications and dosages
- Medication administration records
- Appointments and medical consultations
- Emergency contacts and protocols
- Care protocols and procedures
- Advanced Care Plans
- Healthcare professional contacts
- Daily care entries and notes
2.4 Technical Data
- IP address
- Browser type and version
- Device information
- Login timestamps
- Usage patterns and page views
3. Lawful Basis for Processing (Article 6)
We process your personal data under the following lawful bases:
| Processing Activity | Lawful Basis |
|---|---|
| Account creation and authentication | Contract - Necessary to provide our service |
| Storing medical/care records | Explicit Consent - You consent at registration |
| Security monitoring and audit logs | Legitimate Interest - Protecting your account |
| Newsletter communications | Consent - Optional opt-in at registration |
| Legal compliance | Legal Obligation - Required by law |
4. How We Use Your Data
We use your personal data to:
- Provide and maintain our healthcare management platform
- Enable you to record and manage your child's care information
- Generate care packets and reports for healthcare providers
- Send important service notifications (e.g., appointment reminders)
- Improve our platform and user experience
- Ensure security and prevent fraud
- Comply with legal obligations
- Sell your personal data to third parties
- Use your data for advertising purposes
- Make automated decisions that significantly affect you
- Process your data for purposes beyond those stated
5. Special Category Data (Article 9)
We process this special category data based on:
- Article 9(2)(a) - Explicit Consent: You provide explicit consent when you register and agree to our terms
- Article 9(2)(h) - Healthcare Purposes: Processing is necessary for the management of health care systems and services
Additional safeguards for health data:
- Encryption at rest and in transit
- Access controls and authentication
- Audit logging of all data access
- Regular security assessments
6. Data Sharing and Third Parties
6.1 Service Providers (Data Processors)
We use the following third-party services to operate our platform:
| Provider | Purpose | Location |
|---|---|---|
| Microsoft Azure | Cloud hosting and database | UK (UK South region) |
| SendGrid / Email Provider | Transactional emails | UK/EU |
All service providers have signed Data Processing Agreements (DPAs) and comply with UK GDPR requirements.
6.2 When We May Share Data
- With your consent: When you generate care packets to share with healthcare providers
- Legal requirements: If required by law, court order, or regulatory authority
- Vital interests: In emergencies to protect life
6.3 International Transfers
Your data is primarily stored in the UK. If data is transferred outside the UK, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or adequacy decisions.
7. Data Retention
We retain your personal data for as long as necessary to provide our services and comply with legal obligations:
| Data Type | Retention Period | Reason |
|---|---|---|
| Account data | Until account deletion | Service provision |
| Medical records | Until account deletion | Healthcare management |
| Audit logs | 2 years | Security and compliance |
| Deleted account data | 30 days in backup | Accidental deletion recovery |
When you delete your account, all personal data is permanently removed within 30 days, including from our backup systems.
8. Your Rights Under UK GDPR
You have the following rights regarding your personal data:
Right of Access (Article 15)
Request a copy of all personal data we hold about you.
Right to Rectification (Article 16)
Correct inaccurate or incomplete personal data.
Right to Erasure (Article 17)
Request deletion of your personal data ("right to be forgotten").
Right to Restrict Processing (Article 18)
Limit how we process your data in certain circumstances.
Right to Data Portability (Article 20)
Receive your data in a machine-readable format.
Right to Object (Article 21)
Object to processing based on legitimate interests.
Right to Withdraw Consent
You can withdraw your consent at any time. This won't affect the lawfulness of processing based on consent before withdrawal. To withdraw consent, contact us at privacy@ourcomplexchild.com or delete your account.
Right to Complain
If you're unhappy with how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):
- Website: ico.org.uk/make-a-complaint
- Phone: 0303 123 1113
9. Data Security (Article 32)
We implement appropriate technical and organisational measures to protect your personal data:
Technical Measures
- TLS 1.2+ encryption in transit
- AES-256 encryption at rest
- Secure password hashing (PBKDF2)
- Two-factor authentication available
- Account lockout after failed attempts
Organisational Measures
- Regular security assessments
- Comprehensive audit logging
- Role-based access controls
- Secure cloud infrastructure (Azure UK)
- Breach detection and response procedures
Breach Notification
In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will:
- Notify the ICO within 72 hours of becoming aware
- Notify affected individuals without undue delay if the breach is likely to result in high risk
- Document the breach and our response
10. Cookies
We use cookies to operate our service. Here's what we use:
| Cookie | Type | Purpose | Duration |
|---|---|---|---|
| .AspNetCore.Identity.Application | Essential | Authentication session | 24 hours |
| .AspNetCore.Antiforgery | Essential | Security (CSRF protection) | Session |
| CookieConsent | Essential | Remember cookie preferences | 1 year |
11. Children's Privacy
Our platform stores information about children as provided by their parents or legal guardians. We take extra care to protect children's data:
- Only parents/guardians can create accounts and enter child data
- We verify the user's relationship to the child during registration
- Child data receives the same (or greater) protection as adult data
- We do not knowingly collect data directly from children
The age of digital consent in the UK is 13. Our service is intended for use by adults managing care for children.
12. Contact Us
If you have questions about this privacy policy or how we handle your data:
General Privacy Enquiries
Data Protection Contact
We aim to respond to all privacy-related enquiries within 30 days.
13. Changes to This Policy
We may update this privacy policy from time to time. When we make significant changes, we will:
- Update the "Last updated" date at the top of this page
- Notify you via email if the changes significantly affect your rights
- Request renewed consent if required for new processing activities
We encourage you to review this policy periodically.