CompanionFirst provides warm, non-medical companionship for elderly people. To do that well, and safely, we handle personal information about the people we support, their families, and the companions who join us. This policy explains what we collect, why, how we protect it, and the rights you have. We take this responsibility seriously.
On this page
1. Who we are
Companion First Ltd, trading as CompanionFirst (“CompanionFirst”, “we”, “us”, “our”), is a private limited company registered in England and Wales. We provide non-medical companionship services across Kent, Essex and the surrounding areas. We are the data controller responsible for the personal data described in this policy.
- Company: Companion First Ltd, registered in England and Wales, company number 17151195.
- Registered office: 27 Old Gloucester Street, London, WC1N 3AX.
- Email: info@companionfirst.co.uk
- Phone: 0303 330 1600
- Data protection registration: We are registered with the Information Commissioner’s Office (ICO) as a data controller, registration reference ZC166177.
2. Information we collect
People we support (clients) and their families
- Name, home address and date of birth of the person receiving companionship.
- Contact details for the client and for family members or next of kin, including emergency contacts.
- A general overview of the person’s health, wellbeing and any relevant needs, and their GP surgery details, so we can match and support them safely (see section 5).
- Personality, interests, hobbies and preferences, so we can match the right companion.
- Visit schedules, visit logs, notes and feedback about how visits are going.
- Billing and payment records.
Companions (applicants and those we engage)
- Name, contact details and date of birth.
- Right to work documentation.
- Enhanced DBS certificate details (certificate number and issue date) and DBS Update Service status.
- References.
- Skills, experience, qualifications, availability, travel radius and vehicle access.
- Interests and hobbies, for matching.
- Visit logs submitted after visits, and payment records.
Website visitors and enquirers
- Information you provide through our enquiry and registration forms (such as your name, phone number, email, area and a description of the support you are looking for).
- Messages you send to our website chat assistant.
- Limited technical and usage data collected through cookies and similar technologies (see section 11).
3. How we collect it
We collect personal data directly from you, when you enquire, complete a form, speak with us, sign an agreement, or use our website. For clients, some information is provided by family members acting on their behalf. For companions, some information (such as references and DBS results) is obtained from third parties you have authorised, such as referees and our DBS checking provider.
4. Why we use it & our lawful bases
Under UK data protection law we must have a lawful basis for using your personal data. Depending on the situation, we rely on the following:
- To provide our service (contract): arranging and delivering companionship, matching clients with companions, managing visits, invoicing and payments, and engaging companions.
- Legitimate interests: running and improving our service, matching people well, keeping records, responding to enquiries, protecting the safety of clients and companions, preventing fraud, and letting existing contacts know about relevant updates. We balance these interests against your rights.
- Consent: where we ask for it, for example certain marketing communications and non-essential cookies. You can withdraw consent at any time.
- Legal obligation: meeting our safeguarding responsibilities, carrying out right-to-work and DBS checks, and keeping financial records required by law.
- Vital interests: in an emergency, to protect someone’s life or safety.
- Special category and criminal records data: health information and DBS (criminal records) information need an extra condition under UK data protection law. How we handle these is set out in section 5.
5. Health and criminal records data
Some of the information we handle needs extra protection under UK data protection law. This includes health information about the people we support, and criminal records (DBS) information about companions. We treat both with particular care.
Health information about the people we support
To match and support an older person safely, we hold a general, non-clinical overview of their health, wellbeing and needs (such as mobility, memory, or conditions a companion should be aware of). This is “special category” data. Our lawful basis for using it is that it is necessary for the provision of social care (Article 9(2)(h) of the UK GDPR, together with the health or social care condition in Schedule 1, Part 1 of the Data Protection Act 2018). We handle it only under a duty of confidentiality, and only the companion and the staff who genuinely need it can see it. Where appropriate, we may also ask for your explicit consent. We are not a medical or CQC-regulated service and we do not provide personal or clinical care.
Criminal records (DBS) information about companions
To keep the people we support safe, we carry out enhanced DBS checks on companions before they start, and monitor their status. DBS information is “criminal offence” data, which also receives extra protection. We process it for safeguarding and to assess a companion’s suitability, relying on the relevant conditions in Schedule 1 of the Data Protection Act 2018. We maintain an Appropriate Policy Document that sets out how we handle special category and criminal offence data; it is available on request.
In every case we collect only what we genuinely need, keep it securely, limit who can see it, and make sure the people who handle it understand their responsibilities.
6. Who we share it with
We never sell your personal data. We share it only where necessary, and only with people and organisations that are required to protect it:
- The matched companion: the relevant details they need to visit and support the client safely.
- Our DBS checking provider: to carry out companion background checks.
- Payment providers: to process invoices and payments.
- Trusted service providers (processors): such as our secure cloud storage, email and IT providers, who process data on our behalf under written agreements.
- Safeguarding and other authorities: such as local authority safeguarding teams, the police or regulators, where we are legally required to share information or need to in order to protect someone from harm.
- Professional advisers and insurers: where necessary to run the business or to establish or defend legal claims.
7. International transfers
Some of our providers may process data outside the United Kingdom. Where that happens, we make sure appropriate safeguards are in place, such as a UK ‘adequacy’ decision or the International Data Transfer Agreement / Standard Contractual Clauses, so your data receives an equivalent level of protection.
8. How long we keep it
We keep personal data only for as long as we need it for the purposes above. In general:
- Client and companion records are kept for the duration of the relationship and for a reasonable period afterwards.
- Financial and certain legal records are kept for up to six years, as required by law.
- Enquiries that do not proceed are kept for a shorter period and then deleted.
When we no longer need personal data, we delete or securely destroy it.
9. How we protect it
We use appropriate technical and organisational measures to keep personal data safe, including access controls, encryption in transit, careful vetting of the providers we use, and limiting access to those who need it. No system is perfectly secure, but we take our duty to protect your information seriously and review our measures regularly.
10. Your rights
Under UK data protection law you have the right to:
- Ask for a copy of the personal data we hold about you (access).
- Ask us to correct inaccurate or incomplete data (rectification).
- Ask us to delete data in certain circumstances (erasure).
- Ask us to restrict or object to how we use your data.
- Ask us to transfer certain data to another provider (portability).
- Withdraw consent at any time, where we rely on consent.
- Complain to the ICO (see section 14).
To exercise any of these rights, please email info@companionfirst.co.uk. We will respond within one month.
11. Cookies & the website
Our website uses cookies and similar technologies to make the site work, understand how it is used, and support our marketing. This includes essential cookies, analytics, and advertising tools such as the Meta (Facebook) Pixel. Our website chat assistant processes the messages you send it to answer your questions. You can control non-essential cookies through your browser settings, and you can choose not to use the chat assistant.
12. Children
Our service is for adults. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.
13. Changes to this policy
We may update this policy from time to time. When we do, we will change the ‘last updated’ date at the top of the page. Please check back occasionally to stay informed.
14. Contact & complaints
If you have any questions about this policy or how we handle your data, please contact us:
- Email: info@companionfirst.co.uk
- Phone: 0303 330 1600
- Post: Companion First Ltd, 27 Old Gloucester Street, London, WC1N 3AX
You also have the right to complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection, at ico.org.uk or on 0303 123 1113. We would appreciate the chance to resolve your concern first, so please do contact us.