Your information and your rights – Privacy Notice
At The Guildhall Practice Ltd, we want you to be confident that your information is kept safe and secure with us and understand how we use it to provide great health care and a more personalised experience.
- WHO WE ARE
- WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
- HOW IS YOUR PERSONAL DATA COLLECTED.
- HOW WE USE YOUR PERSONAL DATA.
- WHO WE SHARE YOUR PERSONAL DATA WITH.
- INTERNATIONAL TRANSFERS.
- HOW WE STORE AND PROTECT YOUR DATA.
- DATA RETENTION.
- YOUR LEGAL RIGHTS.
- THIRD PARTY LINKS
- WHO WE ARE
We are The Guildhall Practice Limited, a company registered in England and Wales. Our company registration number is 06923668 and our registered office is at 265B Alcester Rd South, Kings Heath, Birmingham, B14 6DT, United Kingdom.
- WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
Personal data, or personal information, means any information about an identifiable person individual who can be directly or indirectly identified from the data.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, relationship status, title, date of birth, gender, next of kin and video images if you use our video consultation service.
Contact Data includes postal and billing address, email address and telephone numbers.
Special Category / Sensitive Data information about your health and wellbeing treatment and care such as medical history including but not limited to details of appointments and contact with you, medication, referrals, emergency appointments and admissions, clinical notes, treatments, results of investigations, supportive care arrangements, social care status, race, ethnic origin, genetics; sexual orientation and results of X-Rays, scans and laboratory tests;
Financial Data includes bank account and payment card details. This is retained by our third party payment service.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes your username, password any log in details, purchases or orders made by you, your interests, and preferences.
Usage Data includes information about how you use our website, products and services e.g. IP addresses and browsing behaviour from our website and any supporting apps you may use (please see more in our cookie section).
Marketing and Communications Data includes your preferences in receiving marketing from our third parties and us and your communication preferences.
- HOW IS YOUR PERSONAL DATA COLLECTED?
When you enquire about our services, we may collect:
Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, face to face via this website or otherwise.
Usage data collected from our website.
If you don’t provide us with information, we will not be able to respond to your enquiries about healthcare.
When you use our services, we may collect:
Identity, Contact, Special Category / Sensitive, Financial, Transaction, Profile, Usage and Marketing and Communications Data.
In addition, we may collect:
Your employer’s details (if we are providing occupational health services (either directly or via a trusted third party) or providing them with a medical report)
Your health insurer where applicable
Information from compliments, complaints and incidents
Your feedback and contribution to our patient questionnaires, surveys, promotions or competitions.
When you use our services, we may collect information from other sources.
We work closely with third parties such as health and care business partners and sub-contractors such as those providing pathology services, occupational health services, sexual health services, scans and X-rays. We therefore may receive information from them relating to your health and care such as referrals, reports and test results
We may also receive information about you from our trusted sub-contractors who provide technical support, payment services, advertising and analytics support. This could be confirmation of payment for your health and care services and information about your browsing behaviour on our websites and supporting applications.
- HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to in the following circumstances:
- Where we need to protect your vital interests or those of another person. It generally only applies to matters of life or death and would be particularly relevant for emergency medical care, when we would need to process your data for medical purposes but you are incapable of giving consent to the processing (Vital interest);
- Where we need to comply with any obligations arising from any contract we have entered into or are about to enter into with you (Performance of a contract);
- Where it is necessary for our legitimate interests as a provider of health care (or those of a third party, particularly where the individual is a child or vulnerable adult) and your interests and fundamental rights do not override those interests (Necessary for our legitimate interests);
- Where we need to comply with a legal obligation (Legal obligation);
- Where we need to perform a task in the public interest (Public interest); or
- Where you have provided us with clear consent for a specific purpose, such as making a referral or sending you direct marketing information (Consent).
Purposes for which we will use your personal data
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
- To register you as a new patient and customer (Performance of a contract);
- Providing and managing your healthcare and wellbeing on your behalf or on behalf of others (Performance of a contract/Vital interests);
- Managing all aspects of our relationship with you including but not limited to providing you with services and information you have requested, contacting you about your appointments through text message reminders and client feedback, your account, payments or refunds you require and collecting and recovering money owed to us, compliments, complaints, incident handling and claims etc. (Performance of a contract /Necessary for our legitimate interest to recover debts owed to us);
- To check and review the quality of care. (This is called audit and clinical governance). We may use personal or anonymised data to monitor how effective our services are and to make sure that the treatments and services we provide are meeting the needs of our clients. (Legal obligation/Necessary for our legitimate interest as a healthcare provider);
- To enable you to partake in a prize draw, competition or complete a survey (Necessary for our legitimate interest to study how customers use our products/services, to develop them and grow our business);
- To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (Necessary for our legitimate interest of running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise/Necessary to comply with a legal obligation);
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy); and
- To use data analytics to improve our website, products/services, marketing, customer relationships and experiences and ensure that the content is presented in the most effective and helpful way for you. Please see our section on cookies. (Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
- To make suggestions and recommendations to you about goods or services that may be of interest to you. You can opt out of this at any time (Necessary for our legitimate interests (to develop our products/services and grow our business).
- WHO WE SHARE YOUR PERSONAL DATA WITH
We may share your personal data with the parties set out below for the purposes set out above:
- Health care professionals and staff working in our clinics (Performance of a contract/vital interests);
- Your NHS GP; local hospitals, 111 and out of hours services; diagnostic and treatment centres; or other organisations involved in the provision of direct care to you (where you have given clear consent or this is in your vital interests);
- The Care and Quality Commission (CQC). The CQC regulates health and social care services to ensure that safe care is provided. The law says that we must report certain serious events to the CQC, for example, when patient safety has been put at risk. (legal obligation)
- The local health protection team (or Public Health England). The law requires us to share data for public health reasons, for example to prevent the spread of infectious diseases or other diseases, which threaten the health of the population. (public interest)
- External service providers acting as processors who provide payment facilities (Stripe, Merchant Services, Sumup), host our website (x) and IT and clinical platform system administration facilities (Clinico, Cliniqapps)
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services (legal obligation).
- HM Revenue & Customs based in the United Kingdom who require reporting of processing activities in certain circumstances (legal obligation).
- We must also share your information if a court of law orders us to do so (legal obligation).
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.
Sometimes we need to share information so that other people, including healthcare, staff, children or vulnerable adults who are unable to decide whether their information should be shared, are protected from risk of harm. These circumstances are rare. We do not need your consent or agreement to do this.
Information about you may be shared without your consent in other exceptional situations, such as when a serious crime has been committed or if there is a serious risk to the public or our colleagues.
- INTERNATIONAL TRANSFERS
Personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may be processed outside the EEA by one of our service providers. When we transfer your personal data, we will ensure that there are adequate protections in place, in line with UK Data Protection Laws.
From time to time we would like to contact you with details of other products and services we provide at The Guildhall Practice. .
When you register with us, we will ask you if you would like to receive marketing communication. We may use your Identity, Contact, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
If you have consented to receive information, you can of course change your choice or opt out at any time online, at the clinic, over the phone or in writing at any time. We will only use your preferred communication channels to contact you and you will be given the option to select this when opting in.
If you no longer wish to be contacted about our products and services, please call or email us so we can amend your contact preferences.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can set your browser not to accept cookies and the following websites tell you how to remove cookies from your browser. However, you may find that this impacts on your user experience when navigating the website.
- HOW WE STORE AND PROTECT YOUR DATA
The confidentiality and security of your information is of paramount importance 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 and they are subject to a duty of confidentiality.
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.
Our third party payment processors will process credit card payment transactions securely.
We enforce physical, electronic and procedural safeguards in connection with the collection, storage, disclosure and destruction of personal data. We may ask for proof of identity before we share your personal data with you or your representative
By sending us an email message, you will be sending us personal identifying information, such as your name and email address. In these cases, we may retain the information as long as necessary to respond to your request or otherwise resolve the subject matter of your e-mail. Please be aware that email is not necessarily secure from third party interception or misdirection. For your own protection you may wish to communicate sensitive information using a method other than email or send an encrypted email message.
- HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. Your medical records, which includes Special Category /Sensitive Data will be kept in accordance with the Records Management Code of Practice for Health and Social Care 2016.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will 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
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes, for the purpose of scientific or research or where the processing involves automated decision-making and profiling. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you have any questions or concerns about the information we hold on you, please contact our Data Protection Officer DPO at: email@example.com
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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 could 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.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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.
- THIRD-PARTY LINKS