Criminal offence data: appropriate policy document
Version 1.0 · Approved by Collins Kofi Aboagye, 26 October 2026
This policy explains how Ethnatcel Care Ltd, trading as CleanOps Connect, protects criminal offence data it handles when a cleaner chooses to upload a DBS certificate. It is the appropriate policy document described in Schedule 1, Part 4 of the Data Protection Act 2018. Read it together with our privacy notice.
1. About this document
| Controller | Ethnatcel Care Ltd, trading as CleanOps Connect |
|---|---|
| Company number | 12674639 (England and Wales) |
| Registered office | 27 Conqueror Way, Pontefract, WF8 2YJ |
| Contact | ops@cleanop-connect.co.uk |
| Policy owner | The directors of Ethnatcel Care Ltd |
| Next review | By 26 October 2027, and sooner if the processing changes |
We keep this policy for the whole time we process this data and for at least six months afterwards. We review it each year and whenever the processing changes, and we give it to the Information Commissioner on request.
2. The data this covers
The policy covers criminal offence data (UK GDPR Article 10) about cleaners who choose to upload a DBS certificate. We hold three kinds of record about it.
| Record | What it is | Who can see it |
|---|---|---|
| Certificate copy | The PDF, JPG or PNG the cleaner uploads, up to 5 MB. It may show convictions or cautions. | Admin staff only, one file at a time. Never shown to customers, operators or other cleaners. |
| Decision record | Document type, upload date, who reviewed it, when, approved or rejected, and the reason for any rejection. | Admin staff, and the cleaner for their own. |
| Profile flag | A yes/no "DBS verified" on the cleaner's profile. | Shown as a badge to customers and used in job matching. |
We do not copy details from the certificate (such as the certificate number or any offence) into any other field, and we do not use the certificate for anything but deciding whether to show the badge.
3. Why we process it and the legal basis
We process a DBS certificate for one purpose: to let our team check that a cleaner's DBS certificate is genuine and current before a "DBS verified" badge appears on their profile, so customers can choose with confidence.
| UK GDPR Article 6 | Article 6(1)(f), legitimate interests: customer safety and trust in the platform. |
|---|---|
| UK GDPR Article 10 and Data Protection Act 2018, s.10 | Schedule 1, Part 3, paragraph 29: the cleaner has given explicit consent. |
| Consent | Given by choosing a file and pressing Upload, after reading the notice on the Compliance Documents tab. It is optional: a cleaner can receive domestic jobs without a DBS badge, which only affects how they rank. It can be withdrawn at any time by asking us to delete the file. |
Cleaners are told what we do with the certificate, who can see it and when it is deleted, in the notice on the Compliance Documents tab and in our privacy notice.
4. How we meet the data protection principles
| Principle | What we do |
|---|---|
| Lawfulness, fairness and transparency | We rely on the basis in section 3. The Compliance Documents tab tells the cleaner, before they upload, who can open the file and when it is deleted. Our privacy notice repeats this. Uploading is optional and never a condition of using the platform. |
| Purpose limitation | The certificate is used only to decide whether to show the DBS badge. It is not shown to customers, operators or other cleaners, and is not exported, sold or used for marketing. |
| Data minimisation | One file per document type. We do not copy anything from the certificate into another field; the profile holds only a yes/no flag. Only PDF, JPG and PNG files up to 5 MB are accepted, and the file's contents are checked, not just its name. |
| Accuracy | A person checks every certificate. If it is not accepted, the cleaner is emailed the reason and can upload another. An approved certificate replaces the previous one. The badge shows a satisfactory certificate was seen on the review date; staff can remove it at any time. |
| Storage limitation | Certificate copies are deleted automatically on the schedule in section 5. |
| Integrity and confidentiality | Only accounts with the admin role can open a file; staff passwords must be at least 12 characters and are stored only as one-way hashes. Files sit in their own database collection, are never included in any list, and are sent with no-store and no-sniff headers. Every time a file is opened, and every approval, rejection or deletion, is written to an audit log with who, when and why. Read-only support sessions cannot upload. Data is held with our database and hosting providers, who act only on our instructions, and moves over encrypted connections. |
| Accountability | This policy; the audit log; a data protection impact assessment of this feature, which we review each year; a yearly review; and a short briefing for every admin that certificates are opened only to review them. |
5. Retention and erasure
A DBS certificate copy is never kept longer than about six months. The database deletes it by itself, shortly after the date set, so deletion does not depend on someone remembering.
| Data | How long we keep it | How it is deleted |
|---|---|---|
| Certificate copy, not yet reviewed | 183 days from upload | Automatic (database expiry date) |
| Certificate copy, after approval | 183 days from the decision | Automatic |
| Certificate copy, after rejection | 30 days from the decision | Automatic |
| A copy replaced by a newer approved one | Deleted when the new one is approved | Automatic, at that moment |
| An upload replaced before review | Deleted when the cleaner uploads again | Automatic, at that moment |
| Decision record (who, when, approved or rejected, reason) | While the account is open, then 12 months after it closes | By an admin |
| "DBS verified" flag on the profile | While the account is open; removed by staff if a certificate is found to be false or no longer valid | By an admin |
| Audit log entries about the file | Kept for as long as we need them for security and to answer challenges; they never contain the certificate itself | By an admin |
Erasure on request. If a cleaner withdraws consent or asks us to erase their certificate, we delete the file within one month and keep only the decision record, unless the law lets us keep more. The request goes to ops@cleanop-connect.co.uk. An admin does this with a "Delete this file" button that asks for a reason and records it in the audit log.
6. Roles, rights and review
Who does what. The policy owner is responsible for this document and its yearly review. Only named people with an admin account may open a certificate, and only to review it. Cleaners decide whether to upload and can ask us to delete.
Cleaners' rights. A cleaner can ask to see what we hold, have it corrected or erased, restrict or object to its use, and withdraw consent at any time, by emailing ops@cleanop-connect.co.uk. We reply within one month. They can complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113.
If something goes wrong. A lost or wrongly opened certificate is treated as a personal data breach. We contain it, record it, tell the ICO within 72 hours where the law requires, and tell the cleaner without delay when the risk to them is high.
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