Privacy Notice
This privacy notice tells you what to expect us to do with your personal information.
· What information we collect, use, and why
· Lawful bases and data protection rights
· Where we get personal information from
· How long we keep information
· Who we share information with
Contact details
Telephone
07429625223
matthew.ryan@hcaconsultant.co.uk
What information we collect, use, and why
We collect or use the following information to provide patient care, services, pharmaceutical products and other goods:
· Name, address and contact details
· Gender
· Pronoun preferences
· Date of birth
· NHS/HSC/CHI number
· Hospital number
· National Insurance number
· Next of Kin details including any support networks
· Emergency contact details
· Photographs
· Health information (including medical conditions, allergies, medical requirements and medical history)
· Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
· Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
· Payment details (including card or bank information for transfers and direct debits)
· Insurance policy details
· Credit reference information
· Records of meetings and decisions
· Call recordings
· Information about income and financial needs for funding or personal budget support
We also collect the following special category information to provide patient care, services, pharmaceutical products and other goods. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Religious or philosophical beliefs
· Health information
· Sex life information
· Sexual orientation information
We collect or use the following information for safeguarding or public protection reasons:
· Name, address and contact details
· NHS/HSC/CHI number
· Hospital number
· Emergency contact details
· Photographs
· Health information (including medical conditions, allergies, medical requirements and medical history)
· Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions)
· Relevant information from previous investigations
· Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
· Records of meetings and decisions
We also collect the following special category information for safeguarding or public protection reasons. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Religious or philosophical beliefs
· Health information
· Sex life information
· Sexual orientation information
We collect or use the following personal information for patient app or portal functionality:
· Names and contact details
· Addresses
· Medical history
· Payment details
· Account information, including registration details
· Information used for security purposes
· Marketing preferences
We also collect the following special category information for patient app or portal functionality. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Religious or philosophical beliefs
· Health information
· Sex life information
· Sexual orientation information
We collect or use the following personal information to comply with legal requirements:
· Name
· Contact information
· Identification documents
· Health and safety information
· Financial information
· Any other personal information required to comply with legal obligations
· Right to work
· Insurance details
· Tax information
· Safeguarding information
· Criminal offence data
We also collect the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Religious or philosophical beliefs
· Health information
· Sex life information
· Sexual orientation information
We collect or use the following personal information for dealing with queries, complaints or claims:
· Names and contact details
· Addresses
· Payment details
· Account information
· Purchase or service history
· Video recordings of public areas
· Audio recordings of public areas
· Video recordings of private or staff only areas
· Audio recordings of private or staff only areas
· Call recordings
· Witness statements and contact details
· Relevant information from previous investigations
· Customer or client accounts and records
· Financial transaction information
· Information relating to health and safety (including incident investigation details and reports and accident book records)
· Correspondence
We also collect the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Religious or philosophical beliefs
· Health information
· Sex life information
· Sexual orientation information
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
· Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
· Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Our lawful bases for collecting or using personal information for safeguarding or public protection reasons are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for patient app or portal functionality are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o In order to deliver healthcare services
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information to comply with legal requirements are:
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o To respond to queries and complaints in an effective manner with all relevant information.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
· Directly from you
· Other health and care providers
· Insurance companies
· None
How long we keep information
We will retain your information for twenty years, after which it will be deleted.
Who we share information with
Data processors
Carebit
This data processor does the following activities for us: Process patient records and billing information.
Others we share personal information with
· Other health providers (eg GPs and consultants)
· Insurance companies, brokers and other intermediaries
· Care providers
· Organisations we need to share information with for safeguarding reasons
· Organisations we’re legally obliged to share personal information with
· Debt collection agencies
· Suppliers and service providers
Duty of confidentiality
We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:
· you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
· we have a legal requirement (including court orders) to collect, share or use the data;
· on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
· If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
· If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint