Privacy

 

1. Important information and who we are

The Frontline Site has been developed and is operated by Frontline Referrals Limited (Company number: 13459209), which is the controller and responsible for your personal data (collectively referred to as "FRL", "we", "us" or "our" in this privacy policy).
References in this document to the “Frontline Site” or the “Site” refer to:

• https://essexfrontline.org.uk/
• https://hertsfrontline.org.uk/
• https://northumberlandfrontline.org.uk/
• https://www.frontlinereferrals.org.uk
• Associated sub-domains
• The “Frontline Referrals” mobile application

The Frontline Site enables Service Providers to promote services and provides a secure platform for workers in statutory and voluntary organisations to send, receive and monitor referrals. Members of the public may also search for services and submit call-back requests.

Please also read our Public Access Terms and Conditions, Registered User Terms and Conditions (via the Help tab), and Cookies Policy.

This privacy policy gives you information about how FRL collects and uses your personal data through your use of this website, including any data you may provide when you register with us or sign up to our newsletter.

Where a referral relating to a child or young person is submitted by a registered organisation, that organisation acts as the Data Controller and is responsible for determining the appropriate lawful basis, any applicable special category condition, and for meeting its safeguarding and statutory duties. Frontline processes referral data solely on behalf of the referring organisation and does not independently assess capacity, consent, or safeguarding requirements.

Frontline may be used by children and young people under the age of 18 to search for services and, where available, submit self-referrals or call-back requests.

Where a child or young person provides personal data directly, we process that information as the Data Controller for the limited purpose of operating the platform. Frontline does not assess mental capacity or make safeguarding decisions. Responsibility for determining the appropriate lawful basis, consent (where required), and any necessary parental or professional involvement rests with the relevant referring or receiving organisation in line with their statutory duties.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Registered User Information

• First and last name
• Organisation details
• Contact information
• Service configuration data
• Platform usage activity
• Marketing and communications data (namely, newsletter preferences)

Service Information

• Referral activity
• Signpost activity
• Service details
• Usage statistics

Referred Person Information

(a) Mandatory fields:

• Name
• Pronoun
• Address and postcode
• Date of birth
• Phone number
• Reason for referral

(b) Optional fields:

• Email address
• Additional phone numbers
• Contact preferences
• NHS number

Where appropriate and authorised, special category data (Article 9 UK GDPR) may be processed. Referrals to certain specialist services may indirectly reveal special category data.

Processing of special category data will only occur where a valid Article 9 condition applies and in accordance with safeguarding and confidentiality requirements.

Technical Data

• Internet protocol (IP) address
• login data
• browser type and version
• time zone setting and location
• browser plug-in types and versions
• operating system and platform
• device ID and other technology on the devices you use to access this website

Self-Referral / Call-Back Requests

• Name
• Pronoun
• Contact details
• Postcode
• Date of birth
• Reason for referral

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How is your personal data collected?

(a) Information you give us:

Registered Users
We collect information when you register or interact with the platform. This may include:

• Name
• Organisation or Service Provider details
• Contact information
• Service information and opening times
• Referral form requirements
• Personal details of individuals being referred

Members of the Public

We collect information when you:

• Submit a call-back request
• Contact us by phone or email

(b) Information We Collect Automatically

We use Google Analytics (subject to cookie consent) to understand website performance and improve user experience. This includes:

• Pages visited
• Time spent on the site
• Browser and device information
• Anonymised IP data

We use Third Party Software to ensure we maintain the quality and accuracy of information on our Sites and improve user experience of our communications. This includes:

• Email open rates
• Click responses

We also record:

• Aggregated search behaviour
• Aggregated public access to service pages
• Registered User activity linked to their service

Search data is reported in aggregated form and not linked to identifiable public users.

4. How we use your personal data

Service Providers using Frontline act as Data Controllers for referrals they submit.

FRL acts as:

• A Data Processor when processing referral data on behalf of Registered Users
• A Data Controller when members of the public submit data directly to us

When FRL acts as a data controller:

We use your personal data to:

• Maintain and promote service listings
• Enable secure referrals and self-referrals
• Monitor referral progress
• Provide system updates
• Produce anonymised statistical reporting (limited to Lower Super Output Area)
• Send service-related newsletters (with unsubscribe options available)

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

1. Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

2. Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

3. Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

4. Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of data	Legal basis
To register you as a new user	(a) Identity (b) Contact	(d) Consent Frontline operates as a consent-based referral platform. A referral cannot be submitted unless confirmation of consent has been recorded via the consent box. Consent may be withdrawn at any time.
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(b) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you (c) Necessary to comply with a legal obligation (d) Consent
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

Responsibility of Referring Organisations

Where referrals are submitted by registered users or partner organisations, the referring organisation remains the Data Controller and is responsible for:

• Determining its lawful basis
• Obtaining appropriate consent where required
• Providing privacy information to individuals
• Ensuring lawful data sharing

Our Terms and Conditions require referring organisations to confirm that appropriate consent or another lawful basis applies before submitting a referral.

Referrals from NHS, Social Care and Other Statutory Bodies

Some NHS bodies, local authorities and statutory organisations may have a legal basis to share personal data under public task, health and social care, or safeguarding provisions.

However, Frontline operates as a consent-based referral platform. We require referring organisations, including NHS and social care services, to confirm that the individual has given informed consent (including verbal consent where appropriate) before submitting a referral through the system.

If consent cannot be obtained, alternative routes should be considered, such as:

• Direct signposting
• Internal safeguarding procedures
• Other statutory information-sharing mechanisms outside of Frontline

The referring organisation remains responsible for determining and documenting its lawful basis.

NHS System Integrations

Some NHS organisations may use secure NHS infrastructure and interoperability standards (for example NHS Spine services, FHIR-based integrations or secure messaging services) to populate referral information and to record referral requests and reported outcomes within their own electronic patient record systems.

In these circumstances, the NHS organisation remains the Data Controller and is responsible for determining its lawful basis and meeting its clinical record-keeping obligations. Frontline does not access or control NHS electronic patient record systems and processes only the personal data submitted to the Frontline platform.

5. Disclosures of your personal data

We may share your personal data in accordance with the legal bases detailed in section 4.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. International transfers

We do not transfer your personal data outside the UK.

7. Data security

FRL has been designed as a secure multi-agency referral system.

Security measures include:

• UK-based hosting
• SSL encryption
• Two-factor authentication
• Role-based access controls
• Mandatory consent confirmation before referral submission
• Organisational-level activity restrictions
• Annual Information Assurance training
• Safeguarding-aligned processes

FRL holds the following accreditations:

• ISO27001: 2022 accreditation
• NHS DSPT registration

Where we act as a Data Processor, we notify the relevant Data Controller without undue delay if we become aware of a personal data breach affecting referral data.

System Integrations and APIs

Where third-party organisations integrate with Frontline using application programming interfaces (APIs), access is strictly controlled and limited to defined purposes.

Partner systems may be permitted to:

• View the Frontline service library
• Submit referrals
• Receive referrals

They do not have unrestricted access to personal data held within the platform.

All integrations use secure connections and appropriate technical and organisational safeguards.

The Frontline Referrals mobile application uses a controlled API that is read-only for service information and write-only for referral submission.

8. Data retention

Identifiable referral data is held on the Frontline platform for a maximum of 90 days. After this period, personal data is deleted and rendered unrecoverable. Receiving services remain responsible for their own retention policies.

We use point-in-time backup processes.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Telephone: 01799 618855 (Mon–Fri, 9.30am–3.30pm)
• Email: info@frontlinereferrals.org.uk

11. Changes to the privacy policy

We keep our privacy policy under regular review. Updates will be published on this page.

12. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

This statement was last updated in March 2026