We take your privacy seriously and will only use your personal information to administer your service request and to communicate with the providers of your care whilst providing the services you have requested from us.
Please read this policy and notice, together with any other data notice we may provide you on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
THE KIND OF PERSONAL INFORMATION WE COLLECT
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). There are “special categories” of more sensitive personal data which require a higher level of protection.
We will collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
- Date of birth
- Marital status and dependants
- Next of kin, and emergency contact information
- Bank account details
- Photographs of photo ID, and blood tests.
We also collect, store and use the following “special categories” of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation.
- Information about your health, including any medical condition, health and medical notes and advice from the medical professionals we refer you to.
- Genetic information and biometric data.
HOW IS YOUR PERSONAL INFORMATION COLLECTED
We collect personal information about you through our online patient intake form, phone calls, emails and web forms and web portals directly from Clients. We may sometimes collect additional information from third parties including information from the pharmacy, doctor, laboratory.
HOW WE WILL USE INFORMATION ABOUT YOU
|We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your interests (or someone else’s interests).
SITUATIONS IN WHICH WE WILL USE YOUR PERSONAL INFORMATION
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations of our regulatory body. The situations in which we will process your personal information are listed below. [We have indicated the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.
- transfer of data to doctors, nurses, pharmacy and laboratories to facilitate your diagnosis and treatment;
- communication with you;
- updating and enhancing Client records
- analysis to help us to manage your service
- legal and regulatory compliance
Business management and planning, including accounting and auditing
IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.
CHANGE OF PURPOSE
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
HOW WE USE PARTICULARLY SENSITIVE INFORMATION
|“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
1. With your explicit written consent.
WE DO REQUIRED YOUR CONSENT FOR PROCESSING SENSITIVE PERSONAL INFORMATION
As the services involve us collecting, processing and transferring your special category personal data, such as your health data, we do require your explicit consent and we ask you to provide an additional signature on our Agreement to provide us with such consent.
|We may have to share your data with third parties, including third-party service providers
We require third parties to respect the security of your data and to treat it in accordance with the law.
WHY MIGHT YOU SHARE MY INFROMATION WITH THIRD PARTIES
We will share your personal information with third parties where required by law, or where it is necessary to perform our obligation under our contract with you.
WHICH THIRD PARTY PROVIDERS MAY PROCESS MY PERSONAL INFORMATION
“Third parties” includes third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers: The following third-party service providers process personal information about you for the following purposes:
- Our selected doctors: to provide medical advice and diagnoses;
- Our selected blood testing companies to perform the blood testing and screening services as set out in our Agreement;
- Our selected nurse services: to carry out phlebotomy, IV nutrition therapy, self-injection training as set out in our agreement;
- Our selected pharmacies: to fulfil the doctor’s prescription
Our admin team: to answer requests, and assist in the ordering and management of prescription order and other queries requested by you.
HOW SECURE IS MY INFORMATION WITH THIRD PARTY PROVIDERS
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
WHAT ABOUT OTHER THIRD PARTIES
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
|We have put in place measures to protect the security of your information. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.|
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
We will only retain your personal information 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. 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 information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We delete your personal data in line with our regulatory and statutory requirements after you cease to be a Client.
Rights of access, correction, erasure, and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the provision of our services.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
- If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Client Relations Manager in writing at email@example.com.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Client Support Manager by emailing firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. If you have any questions about this privacy notice or how we handle your personal information, please contact the email@example.com. 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.
Changes to this privacy notice. We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. If you have any questions about this privacy notice, please contact Client Support Manager at firstname.lastname@example.org.