Privacy policy

1. About this policy

This policy explains what personal data the Fairer Practice Tracker (the “Tracker”) collects, why, where it is kept, who can see it, and your rights. It follows UK data protection law: the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

The Tracker is an independent companion to the RCGP Fairer Practice Toolkit. It is not an RCGP website. It is created and maintained by Dr Dominic Patterson, who decides how your data is used and is responsible for it (the “data controller”).

2. Changes from 14 October 2026

• The Tracker moved to a new system on 14 October 2026, run by the providers listed in section 7. Your account and your practice's records were copied across.
• The previous system is kept, unchanged and unused, for one month in case anything needs checking, and is then deleted.
• A Primary Care Network (PCN), Integrated Care Board (ICB) or equivalent can now be linked to your practice and see its progress. What each can see is set out in section 6.

3. What we collect

Information you give us:

• your name and email address
• your password, stored only in a scrambled form that cannot be turned back into the password, so nobody, including us, can read it
• which practice or organisation you belong to
• your practice's details: name, address, postcode and NHS organisation (ODS) code
• your practice's progress on each action: not started, in progress or completed, and when it changed
• notes you add, and files you upload, as evidence of that progress
• a record of who changed what and when (the activity log)
• messages you send us through the contact form or “suggest a resource”, with the name and email address you give

Information collected automatically:

• login cookies that keep you signed in (see section 11)
• technical logs kept by our providers to run and secure the service, which include IP addresses and, for sign-in events, email addresses

What we do not collect: payment details (the Tracker is free); analytics or tracking data; advertising data.

4. No patient-identifiable information

You must not enter any information that could identify a patient. That means no names, NHS numbers, dates of birth, addresses, or clinical details that could point to an individual, in notes, file names or files. If you want to describe an example, remove everything that could identify the person first.

The Tracker is for recording what your practice is doing, not about whom.

5. Why we use your data, and our legal basis

Where we rely on legitimate interests, you have the right to object (section 10).

We do not use your data for marketing, sell it or share it for anyone else's purposes, and we make no automated decisions about you.

6. Who can see your information

Practices are linked to a PCN, ICB or equivalent by the Tracker's administrators. In some cases the administrators may give an ICB or equivalent the more detailed level of access, or limit a PCN or equivalent to the less detailed one. Contact us to find out which organisations can see your practice's information.

If we ever share information with anyone else, for example a partner evaluating the Toolkit's impact, we will update this policy and tell you first.

Join codes. Anyone who has your practice's join code can join your practice on the Tracker and see its notes and files. Share it only with colleagues. If you think it has got out, contact us and we will issue a new one.

We may also disclose information if the law requires us to, for example under a court order.

7. Our technology providers

These companies process data on our behalf, under contracts (data processing agreements) that require them to protect it and use it only to provide their service to us:

8. Where your data is kept

Everything you record, including your account and your practice's progress, notes and files, is stored in the UK, in London. The website's server also runs in London.

Like almost every online service, our providers keep short-term operational logs to run and secure their systems, and some of these are held in the United States. These logs can include IP addresses and, for sign-in events, email addresses. They do not include your notes or files.

These transfers are protected by the UK–US data bridge, the UK Government's decision that personal data can flow to US organisations certified under the Data Privacy Framework. Our providers' contracts also include the UK's approved safeguards for international transfers.

When you use the Tracker from abroad, your connection passes through the provider's nearest network location, as with any website. Nothing is stored there.

9. How long we keep it

• Your account: for as long as you use it. If an account has not been used for three years, we will email you, and delete it if you do not reply.
• Your practice's progress, notes and files: for as long as the practice has at least one member on the Tracker, or until the practice asks us to delete them.
• When you delete your account: we delete your personal details within 30 days. Your practice's progress, notes and files stay with the practice, but your name is removed from them.
• Messages to us: two years, then deleted.
• Backups: the database is backed up daily, and each backup is kept for seven days. Anything deleted disappears from backups within seven days.
• The previous system: deleted one month after the move on 14 October 2026.
• Providers' technical logs: kept by each provider for short periods under its own retention rules, then deleted.

10. Your rights

You have the right to:

• see the personal data we hold about you
• correct it (you can change your name and email address yourself on your Account page)
• have it deleted
• restrict how we use it
• object to how we use it
• receive it in a format you can take elsewhere

To use any of these rights, or to delete your account, use the contact form. We will check it is really you, and reply within one month.

11. Cookies

The Tracker uses only strictly necessary cookies:

• login cookies, which keep you signed in securely
• a cookie remembering which organisation you are working in, if you belong to more than one

We do not use analytics, advertising or tracking cookies, and load nothing from third-party sites (no external fonts, scripts or trackers). Because these cookies are essential, the law does not require us to ask for your consent; you can block them in your browser, but you will not then be able to sign in.

12. Security

• All connections to the Tracker are encrypted.
• Data is encrypted where it is stored.
• Files are private; links to them work only for signed-in members and expire after a short time.
• Access rules are enforced by the database itself, not only by the website.
• Only the administrators can see everything.

Please use a strong password that you do not use anywhere else.

13. Data breaches

If a breach puts your rights at risk, we will report it to the Information Commissioner's Office within 72 hours of becoming aware of it, and tell you directly if the risk to you is high.

14. Who the Tracker is for

The Tracker is for people aged 18 or over working in or with UK general practice, including practice teams, PCNs, ICBs and their equivalents across the four nations. We do not knowingly collect data about anyone under 18.

15. Changes to this policy

When we change this policy we will update the date at the top. If a change is significant, we will email active users before it takes effect.

16. Contact and complaints

For anything about your data, use the contact form. Our terms and conditions explain the rules for using the Tracker.

If you are unhappy with how we have handled your data, please contact us first. You also have the right to complain to the Information Commissioner's Office:

• Website: ico.org.uk/make-a-complaint
• Phone: 0303 123 1113
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF