1. Who is responsible
The controller responsible for processing your personal data under the General Data Protection Regulation (GDPR, in German DSGVO) is:
[Company name][Street and number]
[Postcode] [City]
Germany
Email: info@example.com
Phone: +49 000 0000000
Data protection officer: [name and contact, or remove this line if you are not required to appoint one]
2. In short
- We only collect what we need to run CareShift: to answer your questions, check health professionals, match them with home care offers and pay them.
- We don't use analytics, advertising or tracking tools, and we don't sell data.
- Our website loads its fonts and scripts from our own server. It doesn't connect to Google or other third parties when you visit it.
- We only set cookies that are needed for logging in and for remembering your language.
- You can download your data and ask us to delete it at any time.
3. Visiting our website
When you open our website, your browser sends technical information to our server, such as your IP address, the date and time, the page requested, your browser and operating system. Our hosting provider [hosting provider, name and location] stores this in server log files.
Purpose and legal basis: showing the website and keeping it secure, for example to detect attacks (Art. 6 (1) (f) GDPR, our legitimate interest in a secure, working website). Log files are deleted after [7–14] days unless they're needed to investigate an incident.
Our fonts (Bricolage Grotesque, DM Sans) and scripts are stored on our own server, so no data is sent to font or script providers.
5. Contact form and email
If you write to us using the contact form, we process your name, email address, your message and your IP address. We use the IP address only to stop spam (limiting how many messages can be sent).
Purpose and legal basis: answering your request (Art. 6 (1) (b) GDPR if it relates to a contract or a planned contract, otherwise Art. 6 (1) (f) GDPR, our legitimate interest in answering enquiries).
Your message is stored in our system and forwarded by email to our team. We delete it 12 months after your request has been dealt with, unless we must keep it for legal reasons.
6. Signing up as a health professional
When you register, we process:
- Account and contact details: name, email address, mobile phone number, password (stored only as an irreversible hash).
- Professional details: profession, years of experience, languages, registration or licence number, the states and cities you work in, and your maximum travel distance.
- Documents: ID card or passport, qualification certificate, CV, criminal record certificate (Führungszeugnis) and, if you choose to upload it, your vaccination record.
- Payment details: IBAN, account holder, tax number, VAT status.
- Your consent to these terms and the date you gave it.
Purpose and legal basis: checking that you're qualified and suitable to care for patients at home, matching you with offers and paying you (Art. 6 (1) (b) GDPR). We keep tax and billing data because the law requires it (Art. 6 (1) (c) GDPR).
Criminal record certificate: we check it because you'll work alone with vulnerable people in their homes (Art. 10 GDPR in connection with [legal basis to be confirmed by your lawyer, e.g. § 26 BDSG / sector rules]). Only our approval team can see it.
Vaccination record: this is health data (Art. 9 GDPR). Uploading it is optional, and we only process it with your consent (Art. 9 (2) (a) GDPR), which you can withdraw at any time by deleting it or contacting us.
Email confirmation: we send you a link to confirm that the email address is yours.
Our team reviews every application by hand. We don't make automated decisions about you.
7. Using the portal
- Offers: we show you offers that match your profession and work area. We record which offers you've viewed, when you claim or accept an offer (to the millisecond, so we can tell who was first), and any cancel or swap requests.
- Patient information: once you hold an offer, you see the patient's name, address, care instructions and emergency contact, only while the assignment is active. Every time this information is opened, it's logged. You must keep it confidential and use it only for the assignment.
- Clock in and out: when you clock in, your browser asks once for your location so it can be compared with the patient's address. We don't track your location continuously. At the moment, clock entries are kept only on your phone. When timesheets are introduced, we'll update this policy before your clock times and the result of the location check are stored on our server.
- Security log: we log logins, failed logins (with IP address), password changes and important actions in the portal. This protects your account and lets us trace changes (Art. 6 (1) (f) GDPR). We keep these entries for [e.g. 2 years].
Legal basis: Art. 6 (1) (b) GDPR (our contract with you) and Art. 6 (1) (f) GDPR (security and accountability).
8. Patients
To organise home care, we process patients' names, addresses, dates of birth, care needs and instructions, and emergency contacts. This includes health data (Art. 9 GDPR), which we process to provide and organise care (Art. 9 (2) (h) GDPR) under strict confidentiality. Patients and their representatives are informed about this separately. Only our coordinators and the professional currently holding an assignment can see these details, and every access is logged.
9. Who receives data
- Hosting: [hosting provider] runs our servers for us, under a data processing agreement (Art. 28 GDPR).
- Email: we send emails through [email provider (SMTP)], under a data processing agreement.
- Banks and authorities: your bank details go to our bank to pay you, and billing data to our tax advisor and the tax authorities where the law requires it.
- Map links: addresses in your assignments have a "map" link. If you tap it, Google Maps opens and Google LLC (USA) receives the address and your device's data. This only happens when you choose to open the link.
- Address look-up (staff only): when our coordinators add a patient, they can look up the GPS coordinates of the address. Only the street, postcode and city are sent to the OpenStreetMap Foundation (United Kingdom; the EU recognises the UK as having adequate data protection).
We don't send your data to any other third parties, and we never sell it.
10. How long we keep data
| Data | Kept for |
|---|---|
| Your account, profile and documents | As long as you have an account. Earlier versions of replaced documents are deleted when you delete your account. |
| Applications that weren't approved | [e.g. 6 months] after the decision |
| Invoices and payment records | 10 years, as German tax law requires (§ 147 AO, § 14b UStG) |
| Contact form messages | 12 months after your request is dealt with |
| Security log | [e.g. 2 years] |
| Server log files | [7–14] days |
11. Your rights
You have the right to:
- get a copy of your data (Art. 15 GDPR). Professionals can download it any time under Profile & documents → Your data;
- have incorrect data corrected (Art. 16 GDPR);
- have your data deleted (Art. 17 GDPR), unless we must keep it by law;
- restrict how we process your data (Art. 18 GDPR);
- receive your data in a common machine-readable format (Art. 20 GDPR);
- object to processing based on our legitimate interests (Art. 21 GDPR);
- withdraw your consent at any time, with effect for the future (Art. 7 (3) GDPR);
- complain to a data protection supervisory authority (Art. 77 GDPR), for example the one responsible for us: [data protection authority of your federal state].
To use your rights, email us at info@example.com.
12. Do you have to give us your data?
You don't have to. But without the details and documents marked as required, we can't approve you as a health professional or pay you. The vaccination record is always optional.
13. Security
We protect your data with technical and organisational measures. These include encrypted connections (HTTPS), hashed passwords, encrypted storage of sensitive settings, documents stored outside the public part of the website, role-based access for our staff, account lock-out after repeated failed logins, and a log of who accessed what.
14. Changes to this policy
We update this policy when our service or the law changes. The current version is always available on this page. If a change affects you significantly, we'll let you know by email.