Privacy Policy

EntryComply
Operated by Spur Support Ltd
Last updated: [Insert Date]

1. Introduction

This Privacy Policy explains how EntryComply, a trading name of Spur Support Ltd ("we", "us", "our"), collects, uses, stores, and protects personal data when you:

  • Visit our website (www.entrycomply.com)
  • Enquire about our services
  • Enter into a contract with us
  • Use our managed workforce compliance tracking services

EntryComply provides structured workforce compliance tracking and evidence management services to care and support providers operating in England.

We are committed to protecting personal data and complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Our Role Under Data Protection Law

2.1 When We Act as Data Controller

We act as a Data Controller when processing personal data relating to:

  • Website visitors
  • Enquiries and prospective clients
  • Client contacts
  • Billing and account management

In these cases, we determine the purpose and means of processing.

2.2 When We Act as Data Processor

We act as a Data Processor when providing our managed workforce compliance tracking services to care and support providers.

In this context:

  • The care provider is the Data Controller
  • We process workforce compliance data only on documented instructions from the provider

We do not determine the lawful basis for processing workforce data — this remains the responsibility of the provider.

3. Personal Data We Collect

3.1 Information You Provide Directly

We may collect:

  • Name
  • Job title
  • Organisation name
  • Email address
  • Phone number
  • Billing details
  • Enquiry details

3.2 Workforce Compliance Data (Processed on Behalf of Clients)

When delivering our services, we may process:

  • Worker name
  • Role / job title
  • DBS certificate number
  • DBS issue date
  • DBS Update Service registration status
  • DBS Update Service check dates
  • DBS Update Service results ("No change" / "Status changed")
  • Date of birth (used solely for identity verification during DBS Update checks)
  • Training expiry dates
  • ID verification status (recorded as confirmed/not confirmed)
  • Provider authorisation status (recorded only)

We do not store:

  • DBS certificate copies
  • Criminal conviction details
  • Sensitive narrative HR notes
  • Passport or identity document scans

We store status indicators and reference data only.

3.3 Payment Information

Payments are processed securely by third-party payment providers, including:

  • Stripe
  • PayPal

We do not store full debit or credit card details on our systems.

3.4 Automatically Collected Information

When you visit our website, we may collect:

  • IP address
  • Browser type
  • Device information
  • Usage data
  • Pages visited

This information is collected via cookies and analytics tools.

4. Lawful Bases for Processing

Where we act as Data Controller, we rely on:

  • Performance of a contract – to deliver services
  • Legitimate interests – to operate and improve our services
  • Legal obligation – where required by law
  • Consent – where required (e.g., marketing communications)

Where we act as Data Processor, we process data based on the lawful basis determined by the care provider (Data Controller).

5. How We Use Personal Data

We use personal data to:

  • Deliver managed workforce compliance tracking services
  • Conduct scheduled DBS Update Service status checks (with documented worker consent)
  • Record and report workforce compliance status
  • Provide monthly compliance summaries
  • Send administrative communications
  • Manage billing and contracts
  • Maintain service security
  • Improve our services using aggregated, non-identifiable data

We do not sell personal data.

6. DBS Update Service Processing

Where clients subscribe to DBS Update Service monitoring:

  • Checks are conducted at agreed intervals (6 or 12 months)
  • Worker consent is obtained and documented before checks occur
  • Results are recorded as status only ("No change" / "Status changed")
  • We do not interpret or assess DBS results
  • The provider remains responsible for all safeguarding and suitability decisions

7. Data Sharing

We may share personal data with:

  • Cloud hosting providers
  • Secure data storage providers
  • Communication platforms
  • Payment processors
  • Analytics providers
  • Professional advisers (legal, accounting)

All third-party providers are subject to appropriate contractual safeguards.

We do not share workforce compliance data with unrelated third parties.

8. International Transfers

Some of our service providers may store or process data outside the UK.

Where this occurs, we ensure appropriate safeguards are in place, such as:

  • Standard Contractual Clauses
  • Data Processing Agreements

9. Data Retention

Website and Enquiry Data: Retained as long as necessary for business and legal purposes.

Workforce Compliance Data: Retained for the duration of the client contract.

Upon termination:

  • Workforce compliance data is deleted within 30 days
  • Unless a longer retention period is required by law or by written client instruction

10. Security Measures

We implement appropriate technical and organisational measures, including:

  • Workforce data held securely and in line with UK data protection standards
  • Access controls
  • Role-based permissions
  • Secure password management
  • Restricted file access

While we take security seriously, no online system can guarantee absolute security.

11. Your Rights

Under UK GDPR, individuals may have the right to:

  • Access personal data
  • Correct inaccurate data
  • Request erasure
  • Restrict processing
  • Object to processing
  • Data portability (where applicable)

For workforce data, requests should be directed to the care provider (Data Controller) in the first instance.

You may also contact us at: hello@entrycomply.com

12. Children

Our services are intended for care providers and business users.

We do not knowingly collect data from individuals under 18 via our website.

13. Cookies

We use cookies and similar technologies to:

  • Maintain website functionality
  • Analyse website performance
  • Improve user experience

For full details, please see our Cookie Policy.

14. Changes to This Policy

We may update this Privacy Policy from time to time.

The latest version will always be available on our website.

15. Contact Details

Spur Support Ltd
Trading as EntryComply
27 Old Gloucester Street
London
WC1N 3AX
United Kingdom

Email: hello@entrycomply.com

If you are not satisfied with how we handle your data, you may contact the Information Commissioner's Office (ICO): www.ico.org.uk

Questions About This Policy?

If you have any questions about how we handle your personal data, please contact us: