Privacy notice
Handling Plan is a service of Thrive Better Living Limited. It is where a practitioner writes a person’s moving and handling plan and issues it to the care team that carries it out. This notice covers that product and this website. Last reviewed 12 October 2026.
Who the controller is
For your practitioner account, for billing, and for this website, the controller is Thrive Better Living Limited, registered in England and Wales, company number 15248600, registered office Aacsl Accountants House, Unit 9, Astra Centre, Edinburgh Way, Harlow, CM20 2BN. Email hello@handlingplan.com.
For the plans themselves, the controller is you or the service you work for. You decide that a plan is written, what goes into it and who it is sent to. We process it on your instructions as a processor, under the data processing agreement.
We have not appointed a statutory Data Protection Officer. Data protection questions go to hello@handlingplan.com, marked “Privacy”.
No client is named
A plan is saved against a client reference code, such as HCC-0007-F: an organisation reference or a practitioner’s initials, a running number and a single letter. We do not ask for, and have no field for, a name, date of birth or address. The reference is issued by the site so that no two clients share one and nobody has to invent a format.
That makes a plan pseudonymised, not anonymous. The clinical detail in it is still personal data about an identifiable person, because your service holds the key that links the reference back to them, and because it concerns someone’s health it is special category data. We treat it as personal data throughout. The reference itself discloses the issuing service and a letter for sex, so treat it with the same care as the rest of your records.
What we hold, why, and for how long
| What | Why | Lawful basis | Kept for |
|---|---|---|---|
| The plans chosen from the library, your edits to them, the client reference, the account that saved it, the plan code, the number of times it has been opened | To store a plan and let the care team open it | Processed on the controller’s instruction. Where we are controller: Article 6(1)(b), performance of a contract, with Article 9(2)(h) for health data | 12 months after the last save, then deleted |
| Read acknowledgements: the name, role and organisation a carer types, and the time | So the issuing practitioner can see the plan reached the team | Article 6(1)(b), and Article 6(1)(f), our and your legitimate interest in a record of delivery | With the plan, then deleted |
| Practitioner account: name, work email, telephone number, organisation, job role, professional registration number | To run your account, and because your name, number and telephone are printed on every plan you issue so the care team can reach you | Article 6(1)(b) | While the account is open, then 12 months |
| The care provider you send a plan to, and the provider email address used | To deliver the plan and to show where it went | Article 6(1)(b) | With the plan |
| Billing: subscription, invoices and receipts | To take payment and keep tax records | Article 6(1)(b) and Article 6(1)(c), legal obligation | 7 years, as tax law requires |
| Support tickets and enquiries | To answer you | Article 6(1)(f), our legitimate interest in supporting the service | 2 years |
| Security and access logs | To protect accounts and plans | Article 6(1)(f), our legitimate interest in security | 12 months |
Special category data
A moving and handling plan records a person’s mobility, transfers, weight bearing and risks, which is data concerning health under Article 4(15). Processing it needs a condition under Article 9 as well as a basis under Article 6. We rely on Article 9(2)(h), the provision of health and social care, read with paragraph 2 of Schedule 1 to the Data Protection Act 2018, and we hold the appropriate policy document that condition requires. A copy is available on request.
Who can open a plan
Anyone holding the plan code can read that plan, with no account and no password. That is deliberate: a carer on a landing should not be locked out of a plan by a password reset. It also means a code is the whole of a plan’s protection, and a practitioner should send it only to the provider responsible for that person. A printed plan carries a square that opens the live plan, so treat the paper as you would treat the plan itself.
The practitioner who saved the plan can see its access log. Named Thrive administrators can see saved plans where it is necessary for support and audit; that access is logged and everyone with it is under a written duty of confidence. Plans are marked so they are not indexed by search engines.
Who else is involved
| Processor | What it does | Where |
|---|---|---|
| Hostinger International Limited | Hosting and storage | Company in Lithuania. Data stored on servers in the United Kingdom. |
| Stripe Payments Europe Limited, with Stripe Inc | Card payments and subscriptions. Billing details only. No plan ever reaches Stripe. | Ireland, with processing in the United States |
| Resend | Transactional email: verification, password resets, and the message carrying a plan code | United States |
| Google Fonts | Serves the typeface this site uses, so a visitor’s IP address reaches Google | United States. We are moving the typeface onto our own servers. |
Where personal data is processed outside the United Kingdom, the transfer is made under the UK Addendum to the EU standard contractual clauses, supported by a transfer risk assessment available on request.
Cookies and tracking
There is no analytics, no advertising pixel and no session recording on this site. The only cookie we set is the one that keeps you signed in, which is strictly necessary and therefore needs no consent. That is why there is no cookie banner: there is nothing to opt out of.
Your rights
You may ask for access to your personal data, correction of it, erasure, restriction of processing, portability, and you may object to processing we carry out under legitimate interests. Where processing relies on consent you may withdraw it at any time. We answer within one month.
If the request concerns a plan rather than a practitioner account, the service that issued the plan is the controller and you should ask them. Tell us and we will help them answer.
To make a request, email hello@handlingplan.com with “Privacy” in the subject, or write to the registered office above. You do not need an account to make a request.
Complaining
You can complain to the Information Commissioner’s Office: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone 0303 123 1113, ico.org.uk/make-a-complaint. We would rather you told us first so we can put it right.
Reporting a breach to us
If you think a plan has gone to the wrong provider, or a code has reached someone it should not have, email hello@handlingplan.com with “Security” in the subject. We respond within 24 hours.
Changes to this notice
We review this notice when the law, the guidance or the service changes, and we show the date of the last review at the top. Contract-specific versions and supporting evidence are available through due diligence.