Who we are and what we do
This policy is updated from time to time. The latest version updated on 22ndMay 2020 is published on this page of the Site. All updated versions of the policy will be published on this page of the Site.
Information we may collect from you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). When you visit our Site or correspond with us by phone, e-mail or otherwise you may give us information that would be classed as personal data about you and others you are acting on behalf of. We may collect, use, store and transfer different kinds of personal data about you when you do so which we have grouped together follows:
a. Identity Data which includes your first name, last name, username or similar identifier, marital status, title, date of birth and gender.
b. Contact Data which includes your home address, email address and telephone numbers.
c. Health Data which includes any information about your health including your medical history and/or current health status including but not limited to data regarding test results, diagnoses and medications.
d. Financial Data which includes your bank account and payment card details.
e. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
f. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site.
g. Usage Data which includes information about how you use our Site, products and services.
Except for data about your health, we do not collect any Special Categories of Personal Data (as defined in GDPR) about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation (unless as part of your health data), political opinions, or trade union membership. Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Keeping your data secure
We know that data security is important to you and it is therefore important to us. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions in accordance with this policy and they are subject to a duty of confidentiality.
Electronic and hard copy (such a written medical records) data are stored by Regional Medical Services (Southern) Ltd based within secure offices at Sarum Road Hospital, Winchester.
We and Regional Medical Services (Southern) Ltd use a secure, encrypted cloud-based hosted practice management service by PPM (www.ppmsoftware.com)
We and Regional Medical Services (Southern) Ltd also use a secure, encrypted cloud-based hosted practice management service by Carebit (https://www.carebit.co).
We and Regional Medical Services (Southern) Ltd use secure, encrypted forms of communication when handling personal data. The services that we use include Siilo secure messaging service (https://www.siilo.com) and Egress encrypted email service (https://www.egress.com).
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
At your request, we may occasionally transfer personal information to you via email, or you may choose to transfer information to us via email. Email is not a secure method of information transmission; if you choose to send or receive such information via email, you do so understanding the risks associated with doing so.
How we will collect your data
We use different methods to collect data from and about you including through:
a. Direct interactions. You may give us any of the categories of data identified above by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. This includes personal data you provide when you:
● register to use our Site;
● make a request for our products or services;
● give us some feedback.
c. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as analytics providers, advertising networks and/or search information providers based inside the EEA, including for example www.doctify.co.uk.
d. Contact, Financial and Transaction Data (if applicable) from providers of technical, payment and delivery services such as ICON Collections based inside the EU.
Why we will use your data
The lawful bases for processing personal data are set out in Article 6 of the General Data Protection Regulation (GDPR). We may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below. At least one of these must apply whenever we process personal data:
a. Contract: the processing is necessary for a contract we have with you (for example, to process and deliver goods or services to you and to manage our relationship with you), or because you have asked us to take specific steps before entering into a contract.
b. Legal obligation: the processing is necessary for us to comply with a legal or regulatory obligation (not including contractual obligations).
c. Vital interests: the processing is necessary to protect someone’s life.
d. Legitimate interests: the processing is necessary for our legitimate interests (for example to administer and maintain our website) or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
We rely on the following interests when processing your personal data:
- provide you with information, products or services that you request from us
- managing all aspects of our relationship with you, our products and services and any third parties who may provide products or services on our behalf
We also need to satisfy specific conditions for using your health data. We rely upon the following ground in this regard:
e. Healthcare provision: the processing of data concerning your health is necessary for us to provide you with a medical diagnosis and/or healthcare treatment.
Click here to find out more on the Information Commissioner’s Office website about the types of lawful basis that we will rely on to process your personal data.
Disclosing your personal data
We may have to share your personal data with the parties below in order to provide our services to you. We require all third parties to respect the security of your personal data and to treat it in accordance with the law, and when they are processing personal data on our behalf we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Examples of our third parties include:
a. Sub-contractors for the performance of any contract we enter into with them or you;
b. Service providers acting as processors who provide IT and system administration services.
c. Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
d. The NHS: If you are referred to us for treatment by the NHS or your care is transferred back to the NHS, we will share the details of your treatment with the part of the NHS that referred you to us, as necessary to perform, process and report back on that treatment or to facilitate ongoing care by the NHS.
e. Medical regulators: We may be requested – and in some cases can be required – to share certain information (including personal data and special category data) about you and your care with medical regulators such as the General Medical Council or the Nursing and Midwifery Council, for example if you make a complaint. We will ensure that we do so within the framework of the law and with due respect for your privacy.
f. Your General Practitioner (GP): we may also share information about your treatment with your GP. You can ask us not to do this, in which case we will respect that request if we are legally permitted to do so, but you should be aware that it can be potentially very dangerous and/or detrimental to your health to deny your GP full information about your medical history, and we strongly advise against it.
We do not transfer your personal data outside the European Economic Area (EEA).
Consider whether you want a digital log of your visit to our Site to be recorded in your browser. If you don’t want a record to be kept, you can choose to delete your browser history afterwards or view our pages in incognito mode / private browsing, which won’t store your browser history, cookies, or search history after you’ve closed your browsers. However, you are not invisible. Using incognito mode / private browsing does not hide your browser history from your internet service provider, us or your employer (if you are using a company device).
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How long we will keep your data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Generally, this means we will retain your personal data for 8 years.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to access the Information Commissioner’s Office website to find out more about these rights:
If you wish to exercise any of the rights set out above, please Contact us. If you are unhappy with how we are processing your personal data, you have the right to complaint to the Information Commissioner Office. The Information Commissioner can be contacted at:
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee £25 if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.