This Privacy Notice sets out details of the information that we, as health professionals responsible for your treatment, may collect from you and how that information may be used. Please take your time to read this Privacy Notice carefully.
In this Privacy Notice “we”, “us” or “our” to refer to us as the health professionals who are using your personal information.
In the event that you have any queries, comments or concerns in respect of the manner in which we have used, or potentially will use, your personal information then you should contact us directly and we would be happy to discuss further. You can contact Charlotte Turner, company director, by using the contact us form.
Your personal data
We are Data Controllers in respect of your personal information which we hold about you. This will mainly relate to your health or medical treatment but will be likely to also include other information such as financial data in relation to billing. I must comply with the data protection legislation and relevant guidance when handling your personal information, and so must any medical secretary who assists me in an administrative capacity. Your personal data may include any images taken in relation to your treatment which must not only be managed in accordance with the law, this Privacy Notice but also all applicable professional standards.
What personal information do we collect and use from patients / clients?
We will use “special categories of personal information” (previously known as “sensitive personal data”) about you, such as information relating to your physical and mental health.
In addition, you should note that in the event you amend data which we already hold about you (for instance by amending a pre-populated form) then we will update our systems to reflect the amendments. Our systems will continue to store historical data.
As one of our patients / clients, the personal information we hold about you may include the following:
b) Contact details, such as postal address, email address and telephone number (including mobile number)
c) Financial information, such as insurance policy details
e) Emergency contact details, including next of kin
f) Background referral details
Special Categories Personal Information
As one of our patients / clients, we will hold information relating to your medical treatment which is known as a special category of personal data under the law, meaning that it must be handled even more sensitively. This may include the following:
a) Details of your current or former physical or mental health, including information about any healthcare you have received from other healthcare providers such as GPs, dentists or hospitals (private and/or NHS), which may include details of clinic and hospital visits, as well as medicines administered. We will provide further details below on the manner in which we handle such information.
b) Details of services you have received from us
c) Details of your religion
d) Details of any genetic data or biometric data relating to you
e) Data concerning your sex life and/or sexual orientation
The confidentiality of your medical information is important to us, and we make every effort to prevent unauthorised access to and use of information relating to your current or former physical and mental health (or indeed any of your personal information more generally). In doing so, we will comply with UK data protection law, including the Data Protection Act 2018 and all applicable medical confidentiality guidelines issued by professional bodies.
From 25 May 2018, the current Data Protection Act will be replaced by the EU General Data Protection Regulation (GDPR) and a new Data Protection Act. All uses of your information will comply with the GDPR and the new Data Protection Act from that date onwards
How do we collect your information?
We may collect personal information from a number of different sources including, but not limited to:
b) Consultants and other clinicians (including their medical secretaries)
c) Other hospitals, both NHS and private
d) Mental health providers
e) Commissioners of healthcare services
Directly from you Information may be collected directly from you when:
A) You enter into a contract with us
B) You use our services
C) You submit a query to us including by email or by social media
D) You correspond with us by letter, email, telephone or social media.
From other healthcare organisations possible we may have to collect personal information about you from them. These may include:
a) Medical records from your GP
b) Medical records from other clinicians (including their medical secretaries)
c) Medical records from the NHS or any private healthcare organisation
Medical records include information about your diagnosis, clinic and hospital visits and medicines administered.
From third parties
As detailed in the previous section, it is often necessary to seek information from other healthcare organisations. We may also collect information about you from third parties when:
a) You are referred to us for the provision of services including healthcare services
b) We liaise with your current or former health professional or other treatment or benefit provider
c) We liaise with your family
d) We liaise with your insurance policy provider
We deal with experts (including medical experts) and other service providers about services How will we communicate with you?
We may communicate with you in a range of ways, including by telephone, SMS, email, and / or post. If we contact you using the telephone number(s) which you have provided (landline and/or mobile), and you are not available which results in the call being directed to a voicemail and/or answering service, we may leave a voice message on your voicemail and/or answering service as appropriate, including only sufficient basic details to enable you to identify who the call is from, very limited detail as to the reason for the call and how to call us back.
A) to ensure that we provide you with timely updates and reminders in relation to your healthcare (including basic administration information and appointment information (including reminders)), we may communicate with you by SMS and/or unencrypted email where you have provided us with your SMS or email address).
B) to provide you with your medical information (including test results and diet / exercise plans) and/or invoicing information, we may communicate with you by email (which will be encrypted unless you have requested that we send it unencrypted and accept the potential risks associated with this) where you have provided me with your email address. The first time I send you any important encrypted email, I will endeavour to contact you separately to ensure that you are able to access the encrypted email you are sent.
Please note that although providing your mobile number and email address and stating a preference to be communicated by a particular method will be taken as an affirmative confirmation that you are happy for us to contact you in that manner, we are not relying on your consent to process your personal data in order to correspond with you about your treatment. As set out further below, processing your personal data for those purposes is justified on the basis that it is necessary to provide you with healthcare service.
What are the purposes for which your information is used?
We may ‘process’ your information for a number of different purposes, which is essentially the language used by the law to mean using your data. Each time we use your data, we must have a legal justification to do so. The particular justification will depend on the purpose of the proposed use of your data. When the information that we process is classed as a “special category of personal information”, we must have a specific additional legal justification in order to use it as proposed.
Generally, we will rely on the following legal justifications, or ‘grounds’:
a) Taking steps at your request so that you can enter into a contract to receive healthcare services from us.
b) For the purposes of providing you with healthcare pursuant to a contract between you and us. We will rely on this for activities such as supporting your medical treatment or care and other benefits, supporting your nurse, carer or other healthcare professional and providing other services to you.
c) We have an appropriate business need to process your personal information and such business need does not cause harm to you. We will rely on this for activities such as quality assurance, maintaining our business records, monitoring outcomes and responding to any complaints.
d) We have a legal or regulatory obligation to use such personal information.
e) We need to use such personal information to establish, exercise or defend our legal rights.
f) You have provided your consent to our use of your personal information.
Note that failure to provide your information further to a contractual requirement with us may mean that we are unable to set you up as a patient or facilitate the provision of your healthcare.
We provide further detail on these grounds in the sections below.
Appropriate business needs
One legal ground for processing personal data is where we do so in pursuit of legitimate interests and those interests are not overridden by your privacy rights. Where we refer to use for our appropriate business needs, we are relying on this legal ground.
The right to object to other uses of your personal data
You have a range of rights in respect of your personal data, as set out in detail in sections below. This includes the right to object to us using your personal information in a particular way (such as sharing that information with third parties), and we must stop using it in that way unless specific exceptions apply. This includes, for example, if it is necessary to defend a legal claim brought against us, or it is otherwise necessary for the purposes of your ongoing treatment.
You will find details of our legal grounds for each of our processing purposes below. We have set out individually those purposes for which we will use your personal information, and under each one we set out the legal justifications, or grounds, which allow us to do so. You will note that we have set out a legal ground, as well as an ‘additional’ legal ground for special categories of personal information. This is because we have to demonstrate additional legal grounds where using information which relates to a person’s healthcare, as we will be the majority of the times we use your personal information.