CURAM GOVERNANCE, PRIVACY & COMPLIANCE FRAMEWORK
Effective Date: 18 February 2026
1. Introduction
This Governance, Privacy & Compliance Framework sets out Curam’s legal, regulatory and ethical standards across:
- Platform operations
- Care delivery models
- Data protection
- Safeguarding
- AI oversight
- Equality and human rights
- Modern slavery prevention
This document applies to:
- Ecare Group Ltd
- Curamcare Ltd
- Curam Managed Care Services Ltd
- Curam PAYE Ltd
- Curam CQC Ltd
PART A – MASTER PRIVACY POLICY
1. Data Controller Position
For regulated care packages, Curam Managed Care Services Ltd acts as the provider of record and data controller in respect of care delivery.
For introductory arrangements, Curam acts as data controller in respect of:
- Platform operations
- Communications
- Monitoring systems
- Safeguarding review
- Payment systems
Carers and clients may act as independent data controllers for records held outside the Curam platform.
2. Categories of Data Collected
We may process:
- Identity and contact details
- Payment and invoicing data
- Care documentation and care notes
- Health information
- DBS/PVG data
- Platform activity logs
- Emails (inbound and outbound)
- Telephone recordings
- In-platform audio and video recordings
- Safeguarding records
3. Monitoring, Recording & AI Systems
Curam uses artificial intelligence, automated monitoring tools and human oversight to support:
- Safeguarding
- Fraud prevention
- Risk detection
- Regulatory compliance
- Quality assurance
- Operational efficiency
The following may be recorded and analysed:
- All in-platform audio/video calls
- All inbound and outbound telephone calls
- All inbound and outbound emails
- Platform messaging
- Care notes
- Activity logs
AI systems may flag potential risks for human review.
AI does not replace human judgment and does not guarantee detection of misconduct.
Users may request human review of significant automated decisions.
4. Lawful Bases
Processing relies on:
- Contract
- Legitimate interests
- Legal obligations
- Health and social care provision
- Safeguarding duties
- Vital interests
- Explicit consent (where required)
5. Data Sharing
Information may be shared with:
- Other users where necessary
- Local Authorities
- CQC
- Law enforcement
- Approved service providers
- Professional advisers
All processors operate under contractual data protection safeguards.
6. Retention
Indicative retention periods:
- Financial records: 7 years
- Account data: 6 years after closure
- Call recordings: up to 12 months unless safeguarding requires longer
- Identity documentation: retained per legal requirement
- Safeguarding records: retained according to regulatory necessity
Anonymised data may be retained indefinitely.
7. Your Rights
You have rights under UK GDPR including:
- Access
- Rectification
- Erasure
- Restriction
- Objection
- Data portability
- Rights relating to automated decision-making
Complaints may be made to the ICO.
Contact: client@curamcare.com
PART B – CARER PRIVACY NOTICE
Applies to carers using the Curam platform.
Curam processes carer data to:
- Verify eligibility
- Maintain profiles
- Facilitate bookings
- Process payments
- Monitor safeguarding
- Prevent fraud
- Ensure compliance
Carer communications may be recorded and analysed using AI-assisted tools with human oversight.
Self-employed carers remain independent data controllers for any care records maintained outside the Curam platform.
PART C – CLIENT PRIVACY NOTICE
Applies to clients and care recipients.
Curam processes client data to:
- Provide platform access
- Match carers
- Facilitate payments
- Maintain safeguarding
- Comply with legal duties
Health information is processed under health and safeguarding lawful bases.
Communications may be recorded and analysed using AI-assisted systems.
PART D – SAFEGUARDING POLICY
Curam operates in accordance with:
- Care Act 2014
- Making Safeguarding Personal
- Mental Capacity Act 2005
- CQC regulations (where applicable)
AI-assisted systems support safeguarding review.
All safeguarding concerns must be reported immediately.
Emergency: 999
Non-emergency police: 101
Local Authority: www.gov.uk/find-local-council
Senior Safeguarding Lead: Gemma Stokes
Deputy Safeguarding Lead: Jessica Huntley
PART E – MODERN SLAVERY STATEMENT
Curam operates a zero-tolerance approach to modern slavery.
Risk areas include:
- Recruitment
- Supply chain
- International contractors
Mitigation measures:
- Right-to-work checks
- Ethical recruitment
- Supplier due diligence
- Training
- Whistleblowing protections
This statement is issued under the Modern Slavery Act 2015.
PART F – EQUALITY, DIVERSITY & INCLUSION
Curam operates in accordance with the Equality Act 2010.
We prohibit discrimination based on protected characteristics.
Harassment, victimisation or discriminatory behaviour may result in disciplinary action or removal from the platform.
PART G – AI ETHICS & OVERSIGHT
Curam uses AI responsibly and proportionately.
AI systems:
- Support safeguarding
- Support fraud detection
- Support compliance
- Operate with human oversight
- Are reviewed periodically
Curam remains accountable for all operational decisions.
Approval
This Governance, Privacy & Compliance Framework is approved by the Board of Directors of Ecare Group Ltd.
Signed:
Patrick Wallace
Director
Ecare Group Ltd
Date: 18 February 20226
