Iconic People Privacy Policy

Last updated 26 October 2026

Who we are

Experdental Limited is responsible for the personal information described in this notice. Our address is 310 Harrow Road, Wembley, HA9 6LL. For privacy questions or to exercise your rights, email info@iconicsmiles.co.uk.

This notice covers the Iconic People staff app and connected People service. It explains the information used to manage workplace access, rotas, attendance, leave, staff documents and communications. It covers staff employed by Experdental Limited and supplements any other employment privacy information provided to you. It is not a patient-record privacy notice.

Information we collect and use

Account and employment information: your name, email address, staff identifier, role, practice assignments and relevant employment records. We obtain this from you, your employer's authorised staff and your use of the service. We use it to provide access and show information relevant to your work.

Rota, attendance and leave: scheduled work, practice locations, clocking times, correction requests, leave balances, requests and decisions. These support workforce planning, attendance administration and associated payroll checks.

Clocking photos and location: when you initiate clocking, the app requests your current location and a camera photograph to verify attendance at a practice. Location accuracy depends on your device and permission settings. The app does not implement continuous background location tracking. Clocking photos are separate from Face ID or fingerprint unlock.

Sickness and supporting information: absence dates, explanations and relevant documents you or authorised management provide. These support absence administration, employment obligations and adjustments where appropriate. Management functions may display absence statistics, including Bradford scores. Contact your manager or our privacy contact to query the underlying information or its use.

Staff documents: employment, training, professional and compliance documents uploaded by you or management. Depending on the document, these may contain identity, financial, health or criminal-record information. Only provide documents relevant to the requested workplace purpose.

Messages and attachments: workplace messages, recipients, timestamps, delivery/read information, selected files and voice notes you send. The microphone is used when you choose to record a voice note. Camera and file-picker access support document and attachment uploads. Information you send is available to its intended recipients; authorised support or management access must be limited to a legitimate, necessary purpose.

Device and service information: push tokens, platform, notification preferences, authentication/session information, delivery diagnostics and operational logs. These support access control, notification delivery, troubleshooting and protection of the service.

Why we use this information

Our processing purposes are employment administration, meeting relevant employment and compliance obligations, coordinating work, communicating with staff and protecting the service.

For processing necessary to perform our employment contract with you, the legal basis is contractual necessity. For records required by employment, tax, right-to-work or other applicable law, the basis is legal obligation. For proportionate workplace communication, service security and attendance verification not otherwise covered by those grounds, we rely on our legitimate interest in operating a reliable and accountable workplace, balanced against your rights.

Health information requires an additional condition. Where necessary for employment, social-security or social-protection obligations and rights, the relevant condition is Article 9(2)(b) of the UK GDPR together with the applicable Data Protection Act 2018 employment condition. Legal-claims processing may have a separate condition. Criminal-record information requires its own applicable legal authority or Data Protection Act condition; a general employment interest alone is insufficient.

Phone permission prompts control access to device features. They do not replace the legal grounds required for employment processing. If a genuinely optional activity relies on consent, you can withdraw that consent without affecting earlier lawful processing.

Face ID, fingerprint and PIN access

Optional biometric unlock uses your phone's operating-system authentication and secure storage. The app does not receive your fingerprint or Face ID templates. Native session credentials are kept using operating-system secure storage. PIN access, where enabled, is checked through the People service. Password access and the available recovery route remain important if device unlock is unavailable.

Notifications

If enabled, we send updates through Expo's push service and Apple Push Notification service or Google Firebase Cloud Messaging, depending on your device. They process the device identifiers and notification payload needed for delivery. Rota alerts can include details of a shift change. Notifications may be visible on a locked phone according to your settings.

You can manage notifications and previews in phone settings and through the app's available controls. Expo states that notification contents are handled only as needed to pass them to Apple or Google; the app's own delivery records and the native providers' records have separate retention arrangements.

Hosting and recipients

The main People server is hosted by OVHcloud in London, United Kingdom. The configured standard VPS backup runs daily. OVHcloud describes this service as retaining a daily restore point for 24 hours on separate servers within the same datacentre. A server backup does not establish that every service provider processes information only in the UK.

Access to the live People service is restricted to authorised staff. Management users can access records needed for their responsibilities. Direct database administration is managed by Rishin Patel. Colleagues can see information intended for them through shared rota and messaging functions. Hosting and technical providers process information needed to operate the service. Any information made available to an authorised technical-support tool or provider must be limited to what is necessary for that task. Other disclosure must have a relevant purpose and legal basis, such as meeting a legal request or handling a claim.

The currently confirmed chat broadcast setting does not use Pusher as an active real-time provider. Chat information remains subject to People access controls and server processing. We will review this notice if a new communication provider is introduced.

International processing

Notification delivery involves Expo, Apple and Google and may involve processing outside the United Kingdom. Provider arrangements are separate from the London hosting location. Where a restricted international transfer occurs, an applicable lawful transfer mechanism is required, such as adequacy or contractual safeguards. Contact info@iconicsmiles.co.uk for information about the arrangements applicable to your data.

Provider information is available at https://expo.dev/privacy, https://firebase.google.com/support/privacy and https://www.apple.com/legal/privacy/.

How long information is kept

Management is responsible for reviewing and removing records when they are no longer needed. Retention depends on the type of record, its purpose, applicable duties and whether it is needed for a complaint, claim or investigation. Uninstalling the app does not erase employment records.

Automatic file cleanup is enabled for clocking photographs after 12 months and payslip copies held in People after 24 months. A further 30-day grace period applies before files become eligible for the monthly cleanup. Processing safeguards or a failed run can delay removal, so these are eligibility periods, not guaranteed deletion dates. The authoritative payslips are retained separately in the employer's payroll software.

Other file categories are managed through administrative review and configurable retention settings. Staff-document removal requires a downloaded archive under the current settings. Removing a file from People does not erase the associated database record, precise clocking coordinates, a downloaded archive or the payroll system's copy. Each remains subject to its own retention requirements.

Records needed to demonstrate minimum-wage compliance must be retained for the applicable six-year period, beginning at the end of the pay reference period following the one covered. Right-to-work evidence is kept for employment plus two years. CPD records follow the applicable professional requirement, including five years after the end of the relevant GDC cycle. Full DBS certificate information is normally retained no longer than six months after the relevant recruitment/check purpose, unless a documented reason justifies longer retention.

For other employment records, we assess ongoing employment needs, legal obligations and the time during which relevant claims may arise. Health and exposure records can require different periods from ordinary personnel files. Necessary pay and attendance evidence is distinguished from clocking photographs and precise coordinates.

For clocking images/location, routine messages and attachments, device registrations and technical/delivery logs, retention should be limited to the time needed for the relevant operational purpose, resolving discrepancies, support or security. A record linked to a formal case may need to be preserved with that case. Management reviews these records separately from the automatic photograph and payslip-file cleanup described above.

The standard OVHcloud rolling VPS backup described above has a 24-hour retention cycle. Exported archives and copies are separate and remain subject to the relevant record's retention requirements. Provider-held identifiers and records may have different lifecycles. We can explain the retention arrangements applicable to a particular record if you contact us.

Security and device permissions

The app connects to the People API using HTTPS. Native credentials use operating-system secure storage, and backend access controls restrict account functions. These measures do not make workplace messages end-to-end encrypted.

You can manage camera, microphone, location and notification permissions in your device settings. Refusing permission can prevent the corresponding feature, such as location-verified clocking or recording a voice note. Contact your manager about an alternative way to complete required workplace tasks. Keep your device and login details secure and report suspected unauthorised access promptly.

Your rights and deletion requests

Depending on the circumstances, you can request access to your information, correction, erasure, restriction, portability or object to processing. Where applicable, you can withdraw consent. These rights are subject to legal conditions, and records needed for legal obligations or claims may need to be retained.

Email info@iconicsmiles.co.uk to request account closure, deletion or exercise your rights. Explain your request and the account concerned; do not send passwords. We may ask for proportionate information to verify your identity. We will explain any information that needs to be retained and why. Disabling account access is different from deleting the underlying employment records.

You can complain to the Information Commissioner's Office at https://ico.org.uk/make-a-complaint/. You may contact us first so we can investigate your concern.

Changes

We will review this notice when relevant features, providers or uses of personal information change. The current notice is available at https://people.iconicos.co.uk/privacy. Material changes will be brought to staff's attention.