Privacy notice — How we use your information

Last updated: 6 October 2026

This notice explains how we use personal information about people who enquire about visits, the older people we visit and their families, and visitors to this website. If you apply to work with us, we give you a separate notice at that point.

In short:

We only collect what we need to answer you and arrange visits.
We never sell your information.
We only record health details that matter for safe visits, and only with permission.
You can ask to see, correct or delete your information.

Who we are

The Companion Circle provides non-medical companionship for older people in London. In this notice, “we” and “us” mean THECOMPANIONCIRCLE LTD, trading as The Companion Circle.

We are the data controller for the personal information described here. That means we decide how it is used, and we are responsible for looking after it.

Registered office: 66 Paul Street, London, England, EC2A 4NA
Company number: 17412673
Email: info@thecompanioncircle.co

If you have any question about this notice or your information, please email us.

What we collect, and where it comes from

We only collect what we need. You do not have to give us anything, but without contact details we cannot reply, and without the details below we cannot arrange visits.

Enquiries through our website

Our enquiry form asks for your name and phone number, who the visits would be for, how often you would like them, and the area where they would take place. You can also give an email address and tell us anything else in your own words. If you reached the form from one of our adverts, we also record which advert it was.

Enquiries through Facebook and Instagram

Some of our adverts on Facebook and Instagram include a short form, called an Instant Form, which Meta runs. If you fill one in, we receive:

your name, phone number and email address
your borough or postcode
who the visits are for: “my mum”, “my dad”, “another relative” or “myself”
how often you would like a visit

Meta passes these details to us when you submit the form. Meta may fill in some answers from your Facebook or Instagram profile, and you can change them before you send it.

Meta decides how it uses information on its own platforms, including the fact that you saw or answered our advert. That is covered by Meta’s own privacy policy at facebook.com/privacy/policy, not by this notice.

Arranging visits

If visits go ahead, we collect what we need to arrange them and run them well. This can include:

the name, address and phone number of the person we visit
names and contact details of family members who arrange visits or receive our notes
practical details, such as how to get into the home and who to call in an emergency
interests, routines and preferences, so we can choose the right companion
a short note from each visit
who pays, their billing details, and a record of invoices and payments
details of anyone acting under a Lasting Power of Attorney

Sometimes this includes health information. There is more about that in health and other sensitive information.

If you tell us about someone else, such as a parent, please let them know and point them to this notice. We will also explain it to them when we first meet.

Emails and phone calls

If you email or phone us, we keep your message, or a note of the call, with your name and contact details. We use it to reply, and to keep track of what was agreed.

Why we use it, and our lawful basis

The law says we need a valid reason, called a lawful basis, for each way we use personal information. These are ours.

Answering your enquiry and arranging a first home visit, including enquiries from Facebook and Instagram. Lawful basis: steps you have asked us to take before entering a contract. If the enquiry is about someone else, we use their details on the basis of legitimate interests: we cannot answer it without them.
Arranging and providing visits, sending visit notes and invoicing. Lawful basis: contract, with the person who has the agreement with us. If the person we visit is not the person who signed, we use their details on the basis of legitimate interests, because visits cannot happen without them.
Keeping financial records. Lawful basis: legal obligation. Tax law requires us to keep records of what we charge and what we are paid.
Replying to emails and calls. Lawful basis: legitimate interests, in answering the people who contact us. If you are asking about visits, it is the same as for an enquiry above.
Handling complaints and legal claims, and running the business properly. Lawful basis: legitimate interests.
Keeping people safe. In an emergency, we may share what is needed to protect someone’s life. Lawful basis: vital interests. If we are worried that an adult is at risk of harm or neglect, we may share information with the local council. Lawful basis: recognised legitimate interest, for safeguarding.
News and offers. We only send these by email or text if you have said yes. Lawful basis: consent. You can change your mind at any time.

Where we rely on legitimate interests, we have weighed our reasons against your interests and rights. You can ask us about this, and you have the right to object.

Health and other sensitive information

When families tell us about a relative, they often mention health or mobility. For example, that they use a walking frame, are hard of hearing, or are living with memory loss. If you ask us to match on faith, culture or first language, we may also note someone’s religion or background.

The law calls this special category information, and it needs extra protection. We only record what a companion needs to know to keep visits safe and enjoyable. We are not a medical service, and we do not keep medical records.

The condition we rely on is explicit consent (UK GDPR, Article 9(2)(a)). We ask the person the information is about for their clear permission, usually at the first home visit. If they cannot decide for themselves, we ask someone with legal authority to act for them, such as an attorney under a health and welfare Lasting Power of Attorney.

Before then, please tell us only what you think we need. We use anything you share in an enquiry only to answer it and to prepare for the home visit.

Consent can be withdrawn at any time, and we will then stop using the information. That may limit what we can safely offer, such as outings. If so, we will explain.

There are two exceptions to asking first:

In an emergency, if someone’s life is at risk and they cannot give consent, we share what is needed with the emergency services (UK GDPR, Article 9(2)(c), vital interests).
If we believe an adult is at risk of abuse or neglect, we may tell the local council’s safeguarding team without consent, where the law allows it (Data Protection Act 2018, Schedule 1, paragraph 18).

We never sell your information. We share it only when we need to, with:

Your companion, who sees what they need for visits and nothing more.
Family members and others the client has asked us to keep informed, who receive our visit notes.
Service providers who help us run the business: the company that hosts our website, the service that receives our website form, and Namecheap, which provides our email through its Private Email service. They may only use your information to provide their service to us, and must keep it secure.
Professional advisers, such as our accountant or insurer, when we need to.
Public bodies, such as the emergency services, a council safeguarding team, the police or HMRC, where the law requires or allows it.

Meta is where our Facebook and Instagram enquiries come from. We do not send your information back to Meta, for example to build advertising audiences. If that changes, we will update this notice first, and ask for your consent where the law requires it.

Information sent outside the UK

Meta, and some of our service providers, store or process information in the United States and other countries outside the UK. When information leaves the UK, the law requires it to stay protected. We rely on one of these safeguards:

the UK Extension to the EU-US Data Privacy Framework, also called the UK-US data bridge, where the US company has signed up to it
the International Data Transfer Agreement, or the International Data Transfer Addendum to the EU standard contractual clauses, both issued by the ICO
for countries the UK recognises as giving adequate protection, such as those in the European Economic Area, the UK’s adequacy regulations

You can ask us which safeguard applies to a particular provider, and for a copy of it.

How long we keep it

We keep information only for as long as we need it.

Enquiries that do not go ahead, including Facebook and Instagram forms: 12 months after our last contact with you.
Client records, including the agreement and visit notes: 6 years after visits end, in case of questions or claims.
Health details we hold to plan visits: deleted 3 months after visits end, unless they are part of a safeguarding record or a claim.
Invoices and payment records: 6 years from the end of the financial year they relate to, to meet tax rules.
Other emails and call notes: 12 months, unless they belong with one of the records above.

If there is a complaint, a safeguarding concern or a legal claim, we may keep the records involved until it is resolved.

Your rights

You have these rights over your information:

Access. Ask for a copy of the information we hold about you.
Rectification. Ask us to correct anything that is wrong or incomplete.
Erasure. Ask us to delete your information.
Restriction. Ask us to pause using it, for example while we check that it is accurate.
Objection. Object to how we use it where we rely on legitimate interests. You can also tell us to stop any marketing at any time, and we will.
Portability. Where we use information you gave us under a contract or with your consent, and by automated means, ask for it in a common digital format, or ask us to send it to someone else.
Withdrawing consent. Where we rely on consent, you can withdraw it at any time. This does not affect what we did before.

Some rights have limits. For example, we may need to keep invoices to meet tax rules. If we cannot do what you ask, we will explain why. We do not make decisions about you by automated means alone.

How to use your rights

Email info@thecompanioncircle.co. You do not need a form or any special wording, and in most cases it is free. We may ask you to confirm who you are.

We will reply within one month. If a request is complex, or you have sent us several, we may need up to two more months. If so, we will tell you within the first month and explain why.

If you are asking on behalf of someone else, such as a parent, we will need their permission, or proof that you can act for them, such as a Lasting Power of Attorney.

Complaints

If you are unhappy with how we have handled your information, please tell us first by emailing info@thecompanioncircle.co. We will acknowledge your complaint within 30 days, look into it, and tell you the outcome.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection:

Website: ico.org.uk/make-a-complaint
Helpline: 0303 123 1113, Monday to Friday, 9am to 5pm

Cookies and our website

Our website does not use advertising or analytics cookies, and it does not track you across other websites.

To show our pages, your browser also collects fonts from Google Fonts. Each service receives your device’s IP address, which it needs in order to send the files. Our website host may also keep technical logs, such as IP addresses, to run and protect the site.

If we add advertising or analytics tools in future, such as the Meta Pixel, which measures how well our adverts work, we will only use them if you agree, through a cookie banner. You will be able to change your mind at any time, and we will update this notice before they go live.

Changes to this notice

We will update this notice when the way we use information changes. The date at the top shows when it last changed.

How we look after your information.