A data processing agreement
Every term UK GDPR Article 28 requires, plus archive escrow and at least 6 months' notice if the service ever closes.
Precinct Care
Data protection and GDPR in Precinct Care
Children's records are kept for decades and are some of the most sensitive data there is. Precinct Care gives every provider the paperwork and the controls to show the ICO, their regulator and a care leaver exactly what is held, who has seen it and when it will be destroyed.
The children's home provider is the controller of its records: it decides what is recorded, why and for how long. Precinct Software Ltd, part of the QLine IT group, is the processor: it runs Precinct Care only on the provider's written instructions, under a data processing agreement signed before any real record goes in. QLine IT Ltd supplies the engineers and support as its sub-processor.
Where we are: Precinct Care is in final development, shaped with registered managers, Responsible Individuals and Reg 44 visitors. Everything on this page is how the service is designed to run from the first pilot home. This page explains our approach and is not legal advice.
What every provider gets
A ready-made DPIA
Children's special-category data needs a DPIA. We supply one with the risks and controls filled in, for the provider to adopt and sign off.
A record of processing
Rows the provider can copy into its Article 30 record, with purposes, recipients and retention.
UK-only hosting
Live system in two London data centres, standby and backups with a second UK provider. No transfers abroad.
Breaches reported within 24 hours
So the provider has time to decide on reporting to the ICO within its 72-hour deadline.
Templates for young people
A plain-words privacy notice for young people, with a version for younger children, and an appropriate policy document template.
The legal basis is the law itself
Care records rest on legal obligation and health and social care, not consent. Consent can be withdrawn, and a home can't stop keeping the records the regulations require.
| Processing | Article 6 basis | Special-category condition |
|---|---|---|
| Young people's care records | Legal obligation (Children's Homes (England) Regulations 2015 and the Welsh and Scottish equivalents); public task for local authority homes | Health or social care, DPA 2018 Sch 1 para 2 |
| Safeguarding, missing from home, police involvement | Legal obligation | Safeguarding of children, Sch 1 para 18 |
| Staff records, rota, training, DBS checks | Contract and legal obligation | Employment, Sch 1 para 1 |
| Clock-in location check | Legitimate interests, with an assessment | None |
The provider confirms these bases in its own records. Where an appropriate policy document is needed, we supply a template.
Who processes the data, and where
Every copy of a provider's care records stays in the UK. Providers are told at least 30 days before a sub-processor is added or changed, and can object.
| Sub-processor | What it does | Location |
|---|---|---|
| QLine IT Ltd | Engineering and support for Precinct Software Ltd, by enhanced-DBS-checked staff with no default access to records | Leeds, UK |
| Amazon Web Services | Live system, database, backups and locked archive copy, encrypted with a separate key for each provider | London |
| A second UK hosting provider | Warm standby and a second backup and archive copy | UK |
| Email and SMS delivery | Alerts and one-time codes, with no care record content | UK |
The full list, with names, is Schedule 3 of the data processing agreement. Staff sign in through the provider's own Microsoft 365, which is the provider's own supplier. Client records are never used to train AI.
Records kept for the right time, then destroyed
Retention is set from each home's country. In England, case records are kept for 75 years from the young person's date of birth, or 15 years from death if before 18 (regulation 36). In Wales, 15 years from the last entry, with records passing to the placing authority when the young person leaves. Scotland sets no period for providers, so the default is agreed with each provider.
At the end of retention, a named person at the provider approves destruction and a certificate is kept. Records under a legal hold, such as a court case or a police investigation, are paused rather than destroyed.
Care leavers get their files properly
Adults who grew up in care often ask for their records years later. The provider has one month to respond. Precinct Care searches the live system and sealed archives by name, date of birth and dates of stay across every home in the group. A redaction tool flags other children, family members and staff for review, and every request and release is logged. The sealed original is never altered.
Built for the Children's Code
The young people's app follows the ICO's Age Appropriate Design Code. Highest privacy by default, no location tracking, no adverts, streaks or nudges, no profiling, and nothing shared outside the home. Young people see a short, illustrated notice of what is kept about them and how to ask for it.
Independent checks before real records
Cyber Essentials Plus and a passed CREST-accredited penetration test are gates for the pilot. Pen tests are repeated every year, backups are restored automatically every month, and the NHS Data Security and Protection Toolkit follows before wider rollout. Every provider gets a yearly report of the results.
Questions we're asked
Who is the data controller for Precinct Care records?
The children's home provider. It decides what is recorded and how long it is kept. Precinct Software Ltd is its processor and acts only on its written instructions.
I'm a young person or care leaver. How do I get my records?
Ask the company that ran your home, as they control your records. If you contact us instead, we will pass your request to them within 2 working days and tell you we have done so. Email privacy@qlineit.com.
Can we see the DPIA and data processing agreement before we sign?
Yes. We send the data processing agreement, the ready-made DPIA, the sub-processor list and our security measures to any provider considering Precinct Care. Ask for the data protection pack.
Does Precinct Care hold staff fingerprints or face scans?
No. Face ID, fingerprint and Windows Hello checks happen inside the device's secure chip. Precinct Care only receives a yes or no and never holds biometric data.
Can Precinct or QLine IT staff read our records?
No, not by default. In an emergency, access is granted for a limited time, recorded in the audit trail, and the provider is told.
Ask for the data protection pack
We'll send the data processing agreement, the ready-made DPIA and our security measures, or walk your data protection lead through them on a call.
Precinct Care
More of Precinct Care
Security and data protection in Precinct Care
How Precinct Care protects children's records: registered devices only, Face ID instead of passwords, read-only inspector access and an audi
An app for the young people themselves
Each young person gets their own app: goals and points, their placement plan in plain words to read and sign, a memory book of their time in
Children's home software for Scotland and Wales
Precinct Care follows the Care Inspectorate in Scotland and Care Inspectorate Wales: Children's Hearings, The Promise, eForms, CIW reg 60, 7