Last Updated: 26^th March 2026

 

Please read this privacy notice (‘Notice’) carefully to understand how Millbrook Healthcare looks after your Personal Data.

We have set this Notice out in a layered format so you can click quickly navigate to the specific areas set out below.

 

1. WHO WE ARE AND WHAT THIS PRIVACY NOTICE COVERS

What This Privacy Notice Covers

This Notice covers how we look after and handle your Personal Data as a user of our Wheelchair and Approved Repairer Service.

 

Who We Are

Millbrook healthcare Ltd (Millbrook Healthcare) is a provider of wheelchair and approved repairer services across England (collectively referred to as “MHC”, “we”, “us” or “our” in this privacy policy). We process your data on behalf of your Local Authority or NHS Trust as their Data Processor.

MHC’s registered office is at Nutsey Lane, Calmore Industrial Estate, Totton, Southampton, Hampshire, SO40 3XJ.

 

Data Protection Officer

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 rights, please email dpo@millbrookhealthcare.co.uk.

 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). It’s our priority to ensure you are satisfied with our data processing practices. If you do find you have a complaint, we would appreciate the chance to try and resolve any issues you have before you approach the ICO.

 

Changes to the privacy policy and your duty to inform us of changes

 

We keep this Notice under regular review. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

 

2. PERSONAL DATA WE COLLECT ABOUT YOU

As our service user we process the following types of personal data about you:

• Identity Data: includes your title (optional), full name, date of birth, NHS number, GP registration and home address.
• Contact Data: includes your telephone number, mobile number, email address, and alternative addresses (e.g., school, day centre, respite setting).
• Equipment Data: includes details of NHS‑owned equipment issued to you, upgrades or accessories, maintenance history, repairs, servicing activity, and orders. Photographs of wheelchairs may be stored.
• Carer Data: includes the full name, phone number, email address, and relationship of your carers or authorised representatives.
• Communication Data: includes notes of all interactions with you, telephone calls, emails, face‑to‑face contacts, clinical and repair appointments.
• Health Data: includes medical conditions, diagnoses, medications, functional needs, mobility, posture, clinical observations, and relevant social or environmental factors. It will also include your goals of treatment, physical measurements, clinical history and support needs, details of equipment use and functional capacity.
• Safeguarding Data: includes information relating to formally identified safeguarding concerns which reflect confirmed risks such as neglect, harm, or abuse and are recorded prominently to support safe clinical decision.
• Gender and Ethnicity Data: includes information about your gender and ethnicity.
• Feedback Data: includes compliments, concerns, complaints and general feedback recorded in the clinical record.

 

3. HOW WE COLLECT YOUR PERSONAL DATA

We receive your person data both directly from you and from other sources as follows:

• When you are referred to our service by your GP or a healthcare professional from your NHS Trust.
• When we become the new service provider of a contract with the Commissioners in your catchment area.
• Through any contact we have with you when you contact us, visit us for an appointment, or we visit you at home.

 

4. HOW WE USE YOUR PERSONAL DATA

The table below explains how we use your data and the lawful basis relied on to use your data.

 

How we use your Personal Data	Types of data	Lawful basis
To accurately identify you, confirm your eligibility, and ensure your records are matched correctly. Also required for statutory and commissioner reporting requirements (e.g., adult/child status).	(a) Identity (b) Contact (c) Health	(a) Carrying out a public task on behalf of the Controller (b) Processing of health data is necessary for reasons of public interests in the area of public health carried out on behalf of the Controller
To deliver, install, repair or collect your equipment. To assess your home environment to install your equipment by our trusted assessor (when required).	(a) Identity (b) Contact (d) Equipment	(a) Carrying out a public task on behalf of the Controller
To arrange assessments, appointments, repairs, and follow‑up activity. Holding your alternative addresses (e.g., school or respite settings) helps us provide you with flexible and appropriate appointment options for you.	(a) Identity   (b) Contact (c) Communication	(a) Carrying out a public task on behalf of the Controller
To communicate with authorised individuals when you cannot be contacted directly or do not have capacity to engage independently. Enables safe coordination of care, particularly for users who rely on carers for communication or decision‑making.	(a) Identity (b) Carer	(a) Carrying out a public task on behalf of the Controller
To support equality monitoring and ensure services are accessible to all communities.	(a) Gender and Ethnicity	(a) Carrying out a public task on behalf of the Controller (b) Processing Gender and Ethnicity data is necessary for reasons of substantial public interests carried out on behalf of the Controller
To share your information with partner charities who may be able to assist you when you don’t meet our eligibility criteria or require financial support.	(a) Identity (b) Contact (c) Health	(a) Consent (b) Explicit Consent for any transfer of health data
To manage NHS‑owned equipment, track repairs, servicing and funding contributions, and ensure accurate responsibility for third‑party equipment. Photographs of you sitting in the wheelchair are useful to support clinical decision‑making and help resolve potential queries about posture management, complex equipment configuration or seating (where required).	(a) Identity  (b) Equipment (c) Health	(a) Carrying out a public task on behalf of the Controller (b) Processing health data is necessary for reasons of public interests in the area of public health carried out on behalf of the Controller.
To investigate any concerns or complaints you have made about the service.	(a) Identity (b) Contact (c) Feedback	(a) Legitimate interests (to ensure we provide high quality care that meets service users’ expectations and our contractual obligations)
To highlight formally identified safeguarding concerns for clinical decision‑making. Ensures our staff are aware of risks such as harm, neglect or abuse during all interactions.	(a) Identify (b) Safeguarding	(a) Necessary for compliance with our legal obligations (b) Necessary in order to protect the vital interests of a service user
We record all inbound and outbound calls made to service centres to ensure we maintain quality customer service, to resolve customer complaints promptly, and to train staff.	(a) Contact (b) Call	(a) Necessary for our legitimate interests (to meet our contractual and quality compliance obligations)
To administer and protect our business assets which includes troubleshooting, analysis, testing, system maintenance, support, reporting and hosting of data.	(a) All data categories	(a) Necessary for our legitimate interests (to maintain the running of our service, and network security) (b) Processing is necessary for the management of healthcare systems or services
In the event Millbrook Healthcare or its assets are acquired by or merged with another company including through bankruptcy, we will share your Personal Data with any of our legal successors. We will also disclose your Personal Data to third parties: (a) when required by applicable law; (b) in response to legal proceedings; (c) in response to a request from a competent law enforcement agency; (d) to protect our rights, privacy, safety or property, or the public; or (e) to enforce the terms of any agreement or the terms of our Website.	(a) All data categories	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to protect our assets and staff)

 

5. DISCLOSURES OF YOUR PERSONAL DATA

We only share your Personal Data that is necessary with the below external service providers to deliver our services. All providers and their selected staff are required to keep your Personal Data confidential and secure at all times.

 

Business Asset Service Providers:

These are external companies that we use to help us provide our day-to-day service such as IT software providers, website operation, cloud hosting providers.

 

Professional Service Advisers:

These are professional service advisers who help us meet our legal and regulatory compliance requirements which includes auditors (financial and cyber security), legal practitioners, banks and insurers.

 

Partner Charities:

We partner with specific charities who may be able to assist you with your wheelchair needs where you don’t meet our eligibility criteria or need financial support. SSAFA and Royal British Legion are examples of charities who we may refer you to where we have your express consent to share your data.

 

Referrers (Health and Social Care Partners):

We receive and share relevant information with your referrer to support your healthcare needs, including informing them of outcomes, providing specific instructions, or seeking additional guidance where necessary.

 

Supply Partners:

We also share limited information with our Supply Partners who support the assessment and recommendation of equipment when required.

 

You have the right to withdraw consent at any time. You can do this by speaking with your service centre or by emailing us at dpo@millbrookhealthcare.co.uk.

 

Please be aware, withdrawing your consent may impact the services you receive from us, the NHS or your local authority. We will inform you of possible impacts to your service at the time of your request.

 

6. INTERNATIONAL TRANSFERS

We do not transfer any of your data outside of the UK. All your data is stored securely on our private cloud hosted in the UK.

 

7. DATA SECURITY

Our security measures are in-line with NHS Digital and Government standards, and we are certified by the Cyber Essentials accreditation scheme. In addition, we limit access to your Personal Data to those employees, contractors and other third parties on a need-to-know basis only. They will only process your Personal Data under our instructions and are subject to a duty of confidentiality.

 

8. DATA RETENTION

We retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

Our retention periods are maintained in-line with the NHS Records Management Code of Practice 2021 and any applicable legal, regulatory, tax, accounting or other statutory requirements we are required to meet.

 

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have the following rights in relation to your Personal Data:

 

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. 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 legitimate interests (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in 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.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

 

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. 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 you our services and may need to end the service between us. We will advise you if this is the case at the time you withdraw your consent.

 

If you wish to exercise any of the rights set out above, please contact us at: dpo@millbrookhealthcare.co.uk

 

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 if you have made a multiple requests. In this case, we will notify you and keep you updated.

 

If you would like to action any of your requests, please email dpo@millbrookhealthcare.co.uk

 

10. COMPLAINTS

Our team are available to assist you with any comments, concerns or complaints. If you wish to make a complaint or provide feedback, please contact us at: feedback@millbrookhealthcare.co.uk