Privacy policy

Effective date: 8 October 2026.
Last updated: 15 October 2026.

Version: 1.2.

1. Who we are

“Watt Helps®”, “WHG”, “we”, “us” and “our” mean Watt Helps Group Ltd.,
Company number: 17067341,
Registered office: Suite Ra01, 195-197 Wood Street, London, Greater London, United Kingdom, E17 3NU.
Watt Helps Group Ltd. decides how the personal information covered by this policy is used and is the data controller.

Contact the director of WHG for privacy questions, requests, complaints, or withdrawal of consent:
email: info@watthelps.co.uk, phone: +44(0)7342204556.

2. What information we collect

We collect only information relevant to your enquiry, agreed support or chosen service pilot or evaluation activities. We explain which information is needed and which is optional. We may collect:

• Your name or preferred name, contact details, safe contact preferences, confirmation that you are 18 or over, age or age band, and town or postcode where needed to check local service eligibility. We request a full date of birth or full address only where a specific purpose requires it.
• Your goals, current situation, barriers, expectations, strengths, support preferences, previous services and what has or has not helped. Relevant circumstances may concern work, education, housing, money, caring responsibilities, or social connection.
• Appointment and communication records, proportionate session notes, agreed actions, referral details, progress, feedback, complaints, and your consent choices.
• Relevant health, mental health, disability, or access needs you choose to tell us. These are sensitive information and receive additional protection. You do not have to provide a full medical history or proof of a diagnosis for support.
• Pilot and evaluation feedback, and, only with separate permission, voice recordings. A voice recording can identify you and may contain sensitive information.
• If you buy a service, we collect booking, invoicing, and payment status information.

We do not routinely ask for NHS numbers, identity documents, criminal records, medication lists, ethnicity, religion, or sexuality. Any future need for additional sensitive information requires a specific purpose, suitable lawful basis, and updated privacy information first.

3. Where information comes from and why we use it

Most information comes directly from you. With an appropriate lawful arrangement, it may also come from a referring service, a service you ask us to contact, or a representative authorised by you. We tell you the actual source and categories received at first contact, before onward disclosure if sooner, and normally no later than one month after receipt. A referral does not authorise unrestricted access to your records.

We use information to respond to enquiries, assess whether our non-clinical service can help, understand your goals and barriers, agree practical steps, make requested referrals, review progress, make access adjustments, manage bookings or concerns. Where you choose to take part in a service pilot or evaluation, we use the information you agree to provide to understand unmet needs, service preferences and barriers to support, and to help us improve Watt Helps® services.

4. How long we keep your information

We keep personal information only for as long as we need it for the purposes explained in this policy. The periods below are our usual maximum retention periods. We delete information sooner where it is no longer needed.

• Enquiries: If you contact us but do not go on to use our service, we will keep your enquiry details for up to six months after our last contact, to handle any follow-up questions. We then securely delete them.
• Routine support and referral records: We review at closure and delete or anonymise within 24 months after the last substantive contact between you and us.
• Pilot/evaluation audio: We permanently delete audio within 30 days of the recorded session, including working copies and copies held in Voice Memos Recently Deleted.
• Identifiable pilot/evaluation feedback and notes: We delete or genuinely anonymise within 6 months of the session.
• Minimal consent evidence and complaint outcomes: We retain for 3 years after the relevant activity or complaint closes, excluding unnecessary sensitive narratives.
• Financial records: We retain for the applicable statutory period, normally 6 years from the end of the relevant company financial year.
• Records required for a specific safeguarding matter, legal claim, or legal hold: We restrict access, retain them only as long as necessary under a documented lawful basis, and set a review date. We may retain genuinely anonymous statistics because they cannot identify you.

5. Our lawful grounds

The UK GDPR requires a lawful basis for personal information and an additional condition for sensitive information. Our lawful grounds are:

• Enquiries and preliminary contact: legitimate interests under Article 6(1)(f), to respond and manage requests without using more information than needed. Where necessary to take steps at your request towards a service contract, Article 6(1)(b) applies instead.
• Agreed support and booking administration: Article 6(1)(b), where necessary to provide the service agreement you request. Optional sensitive support information uses consent under Article 6(1)(a) and explicit consent under Article 9(2)(a).
• Service pilots and evaluations, recordings, and routine referral sharing rely on consent under Article 6(1)(a). We obtain separate explicit consent under Article 9(2)(a) whenever health or other special category information is used. Consent for one purpose does not permit use for another.
• We rely on Article 6(1)(f) for limited complaint handling, security, and consent records where necessary for accountability and to protect individuals and the service, after balancing these interests against your rights. We retain financial records where required by law under Article 6(1)(c). We exclude sensitive information unless its retention is also permitted by an applicable Article 9 condition.
• Serious safety situations or legal requirements: we identify and record the specific applicable grounds before acting, as explained in section 7. These are exceptions, not a general permission to share.
• Website operation and security: we rely on legitimate interests under Article 6(1)(f) where limited technical information is processed as necessary to operate, maintain and secure the Watt Helps® website, including technical access information processed by our hosting provider.

We do not claim council or NHS public-task powers merely because we help with referrals. We do not rely on scientific-research exemptions for our service pilots and evaluations.

6. Your choices, service pilots and evaluations

You can decline participation in service pilots or evaluations, recording or optional sensitive questions and still access support. You can stop a session, skip a question, or withdraw any consent verbally to your WHG contact or using the contact details above. If the necessary information is unavailable, we explain which support or referral may be incomplete and discuss alternatives, such as self-referral.

Withdrawal does not make earlier lawful use unlawful. We stop further consent-based use and delete or anonymise the relevant information unless a separate lawful reason requires limited retention. Genuinely anonymous findings cannot be traced back and removed. Replacing your name with a code alone does not make information anonymous.

7. Who can receive information

Access within WHG is limited to people who need it for their role and are bound by confidentiality. Routine referral permissions identify the organisation, information, purpose, direction of sharing and end date. We do not send full session notes, pilot/evaluation recordings, or medical histories as a standard referral.

Depending on the referral you choose, recipients may include a GP or other health service, social prescriber, mental health or disability support service, housing or homelessness service, benefits or debt adviser, employment or training provider, charity, or community group. These are categories of possible recipients, not confirmed partnerships.

We may send agreed information to a service receiving your referral, receive agreed information from the service that referred you to us, or send that original referrer an agreed update. Each direction must be specifically explained and authorised where we rely on consent. A service’s original referral is not permission for us to send progress reports back.

Independent referral services usually make their own decisions about information they receive and have their own privacy policies. We give you the relevant policy or contact route before a routine referral. If you withdraw permission after information has been sent, we stop future sharing and help you contact the recipient about information it already holds.

We use providers of business tools, such as email, electronic storage, cloud services and website hosting, to help run our service. This includes iCloud, where permitted voice recordings are stored and synchronised, and Namecheap, which hosts our website and may process limited technical information, such as IP addresses and server access information, as part of providing and securing the hosting service.

Where providers handle personal information on our behalf, we require appropriate security, confidentiality and data protection arrangements. We only make information available where needed for their role. You can contact us for details of the providers handling your information. We do not sell your personal information.

Exceptionally, necessary information may go to emergency services, safeguarding authorities, courts, or other legally authorised recipients. We use a specific legal basis and, for sensitive data, an additional lawful condition. Examples include protecting life where the person cannot consent, a qualifying safeguarding situation, or establishing or defending legal claims. A request from an organisation is not itself a legal duty to disclose. We share only what is necessary, record the reasons, and tell you unless doing so would be unsafe or legally prohibited.

8. Pilot feedback and recordings

We may run pilots with clients to test and improve the Watt Helps® service. With your permission, we use your feedback and relevant session information to understand what worked, what did not and how we can improve our support framework.

With separate permission, we may record conversations using the Voice Memos app on our business phone. Voice Memos is synchronised with iCloud, meaning recordings may also be stored and synchronised through iCloud while they are retained by WHG. We listen back to help with this review and may make written notes; we do not create full written transcripts.

You can decline recording, ask us to pause or stop, and skip questions without affecting your support.

Recordings and identifiable evaluation notes are used internally for this purpose. We do not publish your recordings or identifiable personal stories. Any findings shared outside WHG will be presented so that you cannot reasonably be identified.

Voice recordings are permanently deleted within 30 days of the recorded session, including any copies held in the Voice Memos Recently Deleted folder and synchronised through iCloud. How long we keep other evaluation information and how to withdraw permission are explained elsewhere in this policy.

9. Keeping information secure and limiting retention

We take reasonable technical and organisational measures to protect the personal information we hold.

We restrict access to authorised people who need information for their role and use protected accounts and devices, access controls and the security features provided by the systems and service providers we use.

Voice recordings made using the WHG business phone are synchronised through iCloud while they are retained. Recordings are permanently deleted in accordance with the retention period in section 4, including removal from the Voice Memos Recently Deleted folder.

We review information periodically and securely delete or anonymise it when it is no longer required. Paper records, where used, are stored securely and disposed of securely when their retention period ends.

We cannot guarantee absolute security, but we are responsible for taking appropriate steps to protect personal information and for responding appropriately if a personal data breach occurs.

Some of the providers we use may process personal information outside the UK. Where this happens, we require an appropriate lawful transfer mechanism and safeguards in accordance with UK data protection law. You can contact us for further information about relevant safeguards.

10. Your rights and complaints

Depending on the circumstances, you can request access to your personal information, correction, deletion, restriction, or a portable copy of information processed automatically on consent or contract grounds. You can object to legitimate-interest processing and withdraw consent at any time. Rights have legal limits; we explain any refusal and your options. We normally respond to rights requests within one month, subject to lawful extensions or adjustments, and may need proportionate identity checks.

Raise a privacy concern using the contact details in section 1. We acknowledge data protection complaints within 30 days, investigate without undue delay, and keep you informed. You can also complain to the Information Commissioner’s Office at ico.org.uk/make-a-complaint or on 0303 123 1113.

11. Website, cookies and technical information

Website enquiries fall within this Privacy Policy.

Watt Helps® does not currently deploy its own cookies, analytics or tracking technologies to monitor visitors to the website.

The website is hosted by a third-party hosting provider, Namecheap. As part of providing and securing the hosting service, limited technical information may be processed automatically when you access the website. This may include information such as your IP address, browser or device information, the pages or files requested, the date and time of the request, and referral information.

This technical information is used for purposes such as operating, securing and maintaining the website and hosting service. Watt Helps® does not use this information to create profiles of website visitors or for advertising purposes.

If Watt Helps® introduces cookies, analytics or other tracking technologies in the future, this Privacy Policy will be updated, and appropriate information and choices will be provided where required by law.

If we materially change how we use your personal information, we will explain the change before using your information for a new purpose and seek fresh consent where required.

The Client Terms describe the service provided by Watt Helps Group Ltd. The Permission Form and Client Referral Consent Form record relevant choices and permissions. These documents work alongside this Privacy Policy and do not override your data protection rights.