Clinical Attendance Monitoring System
Last updated: April 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”) in collaboration with King's College London (“KCL”).
The System monitors attendance of KCL MBBS programme students during clinical placements at KCH sites. KCH and KCL act as independent data controllers for their respective purposes relating to clinical placement delivery and MBBS programme administration. Personal data is shared between the two organisations on a controller-to-controller basis under the NHS Education contractual framework. Each organisation is independently responsible for compliance with UK GDPR.
This notice supplements the KCL Core Privacy Notice and the KCH Privacy Notice, available on the respective organisations' websites.
We process your personal data because it is necessary for the delivery of medical education and clinical training, as a public task carried out in the public interest (Article 6(1)(e) UK GDPR). This applies to all categories of personal data processed by the system, including identity data, attendance records, geolocation, absence reports, and device information.
Location data is captured once at the point of check-in only, to verify that attendance is occurring at the clinical site. It is not tracked continuously.
Identity data
Name, K-number, KCL email address.
Attendance data
Check-in timestamps, session type, site, supervising tutor, tutor verification status.
Location data
Approximate geolocation captured at the moment of check-in only, to verify presence at the clinical site. Location is not tracked continuously.
Absence data
Self-reported absence dates, reason categories, and any explanation you provide.
Device data
Browser user agent string, captured for audit and security purposes only.
Your personal data is used to:
Record and verify attendance at clinical placement sessions.
Identify patterns of absence so that pastoral support can be offered.
Provide evidence of clinical engagement for academic progression decisions.
Ensure the integrity of attendance records through geolocation verification and tutor review.
Provide attendance evidence where relevant to fitness to practise proceedings.
Your attendance data may be shared with relevant KCH and KCL staff involved in the delivery and administration of your clinical placements, including clinical tutors, module leads, personal tutors, educational supervisors, and programme administrators.
Data may also be shared with fitness to practise or student conduct panels where attendance is relevant to a concern or investigation.
Your data is not shared with external third parties for marketing or any purpose unrelated to your medical education.
Personal data is stored in a cloud-hosted database with all data held in the United Kingdom (AWS London region). The System uses role-based access controls and row-level security to ensure that users can only access data they are authorised to view.
All data is transmitted over encrypted connections (HTTPS/TLS) and encrypted at rest. Authentication is handled via secure magic link or password-based login.
Attendance records are retained in line with KCH and KCL data retention policies for student and clinical training records. At the end of the retention period, personal data will be securely deleted or anonymised.
Under data protection legislation, you have the right to:
Access your personal data. You can view your own attendance records through the student portal, or submit a formal Subject Access Request.
Rectification if you believe your attendance data is inaccurate.
Erasure in limited circumstances, although this may be restricted where data is required for regulatory compliance or academic record-keeping.
Object to processing. Your objection will be considered but processing may continue where there are compelling grounds.
When you check in, 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 site.
You may decline location access. Your check-in will still be recorded, but it will be flagged for review. 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 only. No analytics, tracking, advertising, or third-party cookies are used.
This notice may be updated from time to time. The date at the top indicates when it was last updated.
If you have questions about how your data is processed, please contact the programme administrator or visit the KCH and KCL websites for Data Protection Officer contact details.
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).