Clinical Attendance Monitoring System
Last updated: February 2026
This privacy notice explains how personal data is collected, used, and protected by the Clinical Attendance Monitoring System (“the System”), operated by King's College Hospital NHS Foundation Trust (“KCH”, “we”, “us”) in collaboration with King's College London (“KCL”) for the purpose of monitoring clinical placement attendance for medical students enrolled on the KCL MBBS programme undertaking placements at KCH sites.
KCH is the data controller for personal data processed through this System in relation to clinical placement activity. KCL remains the data controller for broader student records and academic progression data. This notice should be read alongside the KCH Privacy Notice, the KCL Privacy Notice for Students, and the MBBS Programme Regulations (Section 7.5).
We process your personal data under the following lawful bases:
Article 6(1)(e) UK GDPR — Public task: The processing is necessary for the performance of a task carried out in the public interest, namely the delivery of medical education and clinical training at KCH, and ensuring compliance with General Medical Council (GMC) requirements for medical school attendance monitoring.
Article 6(1)(f) UK GDPR — Legitimate interests: KCH and KCL have a legitimate interest in monitoring clinical placement attendance to support student welfare, identify students who may be struggling, fulfil regulatory obligations, and maintain the integrity of professional training programmes.
For the processing of location data (geolocation), the lawful basis is Article 6(1)(e) as attendance verification is necessary for the public task of ensuring genuine clinical placement attendance. Location data is processed only at the point of check-in and is not continuously tracked.
The System collects and processes the following categories of personal data:
Identity data
Full name, K-number (student identifier), email address, programme module.
Attendance data
Check-in timestamps, session type, session location (site name), supervising tutor name, check-in method (QR code, self-reported, or manual entry), tutor verification status.
Location data
Approximate geolocation (latitude, longitude, and accuracy in metres) captured at the moment of check-in only. This is used to verify that check-in occurred at or near the clinical placement site. Location is not tracked continuously — it is captured as a single data point when you check in.
Device data
Browser user agent string (captured at Code of Conduct acceptance). This is used for audit purposes only and is not used for tracking or profiling.
Absence data
Self-reported absence dates, reason categories (e.g. illness, personal, transport), free-text explanations provided by you, and review status.
Feedback data
Anonymous session ratings and comments. These are not linked to your identity — the System stores ratings against the session only, with no record of which student submitted which rating.
Tutor reports
If you report a tutor no-show, the System records the date, expected session, site, expected tutor name, and any notes you provide, along with your identity as the reporter.
Your personal data is used for the following purposes:
Attendance monitoring: Recording and verifying attendance at clinical placement sessions, as required by the MBBS programme regulations and GMC standards.
Student welfare: Identifying patterns of absence that may indicate a student is struggling, enabling timely pastoral support from personal tutors or educational supervisors.
Academic progression: Providing evidence of clinical engagement for progression decisions, and identifying where a student may not have covered mandatory learning objectives due to absence.
Fraud prevention: Using geolocation data and tutor verification to ensure the integrity of attendance records and identify potential falsification.
Teaching quality: Using anonymised session ratings to evaluate and improve the quality of clinical teaching.
Regulatory compliance: Meeting the GMC's requirements for medical schools to monitor and evidence student attendance at clinical placements.
Fitness to practise: Providing attendance evidence where relevant to fitness to practise proceedings, in accordance with KCL's established procedures.
Your attendance data may be shared with the following parties, where necessary and proportionate:
KCH clinical teaching staff: Session tutors and clinical supervisors at KCH can see the names of students who checked in to their sessions and can verify or dispute attendance. Tutors see aggregate anonymised session ratings only.
KCL GKT School of Medical Education: Module leads, Heads of Stage, programme administrators, and the Attendance Lead for the purposes of monitoring and supporting attendance.
Personal tutors and educational supervisors: To support pastoral care and identify students who may need additional support.
KCL Student Conduct and Appeals: If attendance records are relevant to a conduct investigation or fitness to practise hearing.
KCL Fitness to Practise committee: Where attendance is relevant to a fitness to practise concern.
Faculty Education Services: For administrative purposes related to your programme.
Your data is not shared with external third parties for marketing, advertising, or any purpose unrelated to your medical education and clinical training. Anonymised and aggregated attendance statistics may be used for quality improvement reporting without identifying individual students.
Personal data is stored in a cloud-hosted database provided by Supabase, Inc., with data held in the European Union. The System uses row-level security policies to ensure that users can only access data they are authorised to view.
All data is transmitted over encrypted connections (HTTPS/TLS). Authentication is handled via secure magic link or password-based login. Access to the administrative functions is restricted to authorised programme staff.
Where data is transferred outside the UK, appropriate safeguards are in place in accordance with UK GDPR requirements, including Standard Contractual Clauses or adequacy decisions as applicable.
Attendance records are retained for the duration of your enrolment on the MBBS programme plus six years, in line with KCH and KCL data retention schedules for student and clinical training records, and the requirements of professional regulators.
Anonymous session ratings are retained indefinitely as they contain no personal data. Code of Conduct acceptance logs are retained for the same period as attendance records.
At the end of the retention period, personal data will be securely deleted or anonymised.
Under the UK GDPR, you have the following rights in relation to your personal data:
Right of access: You can view your own attendance records, absence reports, and tutor no-show reports through the student portal at any time. You may also submit a formal Subject Access Request to KCH or KCL.
Right to rectification: If you believe your attendance data is inaccurate, you can contact the programme administrator or the KCH clinical education team to request correction.
Right to erasure: In limited circumstances, you may request deletion of your data. However, as processing is based on public task and legitimate interests, this right may be restricted where data is required for regulatory compliance or academic record-keeping.
Right to restriction of processing: You may request that processing of your data be restricted in certain circumstances, for example while a dispute about accuracy is being resolved.
Right to object: You have the right to object to processing based on public task or legitimate interests. KCL will consider your objection but may continue processing where there are compelling legitimate grounds.
Right to data portability: This right does not apply as processing is not based on consent or contract.
When you check in to a session, your device may request permission to access your location. This is used solely to verify that check-in is occurring at or near the clinical placement site.
You may decline location access. If you do, your check-in will still be recorded, but it will be flagged for administrative review as it cannot be geographically verified. Declining location access will not prevent you from checking in.
Location data is captured as a single point at the moment of check-in. The System does not track your location at any other time, does not run in the background, and does not access your location history.
The System uses strictly necessary cookies for authentication (maintaining your login session). No analytics, tracking, advertising, or third-party cookies are used. No data is shared with advertising networks or social media platforms.
This privacy notice may be updated from time to time. Material changes will be communicated to students via the System or by email. The date at the top of this notice indicates when it was last updated.
If you have questions about how your data is processed, contact:
KCH Clinical Education team: [Contact email to be confirmed]
KCL Faculty Education Services: MBBS@kcl.ac.uk
KCH Data Protection Officer: kch-tr.ig@nhs.net
KCL Data Protection Officer: info-compliance@kcl.ac.uk
If you are not satisfied with how your data is being handled, you have the right to lodge a complaint with the Information Commissioner's Office (ICO).