Gentle Procedures North London May 2018
We understand how important it is to keep your personal information safe and secure and we take this very seriously. We have taken steps to make sure your personal information is looked after in the best possible way and we review this regularly.
Please read this privacy notice (‘Privacy Notice’) carefully, as it contains important information about how we use the personal and healthcare information we collect on your behalf.
1 – WHY WE ARE PROVIDING THIS PRIVACY NOTICE
We are required to provide you with this Privacy Notice by Law. It explains how we use the personal and healthcare information we collect, store and hold about you. If you are unclear about how we process or use your personal and healthcare information, or you have any questions about this Privacy Notice or any other issue regarding your personal and healthcare information, then please do contact our Data Protection Officer (details below).
The Law says:
A. We must let you know why we collect personal and healthcare information about you;
B. We must let you know how we use any personal and/or healthcare information we hold on you;
C. We need to inform you in respect of what we do with it;
D. We need to tell you about who we share it with or pass it on to and why; and
E. We need to let you know how long we can keep it for.
2 – THE DATA PROTECTION OFFICER
The Data Protection Officer at the Clinic is Ms Anouska Plaut. You can contact her on 0207 118 8778 or firstname.lastname@example.org if:
- You have any questions about how your information is being held;
- If you require access to your information or if you wish to make a change to your information;
- If you wish to make a complaint about anything to do with the personal and healthcare information we hold about you;
- Or any other query relating to this Policy and your rights as a patient.
3 – ABOUT US
In this Privacy notice we use “we” or “us” or “our” or “GPNL” to refer to the clinicians (medical practitioners) and support staff at Gentle Procedures North London clinic, based at 999 Finchley Road, London NW11 7HB. We are a Data Controller of your information. This means we are responsible for collecting, storing and handling your personal and healthcare information when you register with us as a patient.
There may be times where we also process your information. That means we use it for a particular purpose and, therefore, on those occasions we may also be Data Processors. The purposes for which we use your information are set out in this Privacy Notice.
Gentle Procedures North London is a trading name for Josh Plaut Ltd, Company No. 09773658 and the personnel are the same.
4 – WHAT INFORMATION DO WE COLLECT FROM YOU
The information we collect from you will include:
A. Your contact details (such as your name, telephone number and email address);
B. Details and contact numbers of your next of kin;
C. Your age range and gender;
D. Your occupation;
E. Details in relation to your medical history;
F. Financial information such as credit/debit card details used to pay us.
Special Categories Personal Information:
As a patient of GPNL 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. The special categories of personal information we hold about you may include:
A. Details of your current or former physical or mental health. This may include information about any healthcare you have received or need, including appointments and medicines administered. We provide further details below on the manner in which we handle such information.
B. The reason for your visit to the clinic;
C. Medical notes and details of diagnosis and consultations with our clinician and other health professionals within the clinic involved in your direct healthcare.
D. Your religious or cultural background.
The confidentiality of your medical information is important to GPNL. We make every effort to prevent unauthorised access to and use of information relating to your current or former physical and mental health.
5 – HOW DO WE COLLECT INFORMATION ABOUT YOU ?
Information may be collected directly from you when:
A. You complete a registration questionnaire and consent form in the clinic
B. You complete enquiry / contact / appointment/ registration forms on the GPNL website
C. You submit a query to us including through our website or by email
D. You correspond with us by letter, email, telephone
E. You make a payment to us through our website or over the phone
We also collect personal information about you when it is sent to us from a hospital, a consultant or any other medical or healthcare professional, or any other person involved with your general healthcare.
6 – WHO WE MAY PROVIDE YOUR PERSONAL INFORMATION TO, AND WHY
Any information we hold regarding your medical history, care or treatments will remain completely confidential. It will only be shared with your permission or unless otherwise required by law.
We may pass your personal information on to the following people or organisations, because these organisations may require your information to assist them in the provision of your direct healthcare needs. It, therefore, may be important for them to be able to access your information in order to ensure they may properly deliver their services to you:
A. Hospital professionals (such as doctors, consultants, nurses, etc);
B. Other GPs/Doctors/Histologists;
D. Anyone you asked us to communicate with or provide as an emergency contact , for example your next of kin or carer.
E. The GP you provided us with details of.
We may also disclose your (non medical) information to the parties listed below for the reasons set out in this Privacy Notice. These may include:
F. Government bodies, including HMRC
G. Regulatory bodies such as the Care Quality Commission.
H. The police and other third parties where reasonable necessary for the prevention of detection of crime.
I. Our insurers
J. Debt collection agencies
K. Our third party services providers such as IT suppliers, auditors, lawyers, marketing agencies, document management providers.
7 – ANONYMISED INFORMATION
Sometimes we may provide information about you in an anonymised form. If we do so, then none of the information we provide to any other party will identify you as an individual and cannot be traced back to you.
8 – YOUR RIGHTS AS A PATIENT
The Law gives you certain rights to your personal and healthcare information that we hold, as set out below:
A. Access and Subject Access Requests
You have the right to see what information we hold about you and to request a copy of this information.
If you would like a copy of the information we hold about you please request this in writing or through our website. We will provide this information free of charge however, we may in some limited and exceptional circumstances have to make an administrative charge for any extra copies if the information requested is excessive, complex or repetitive.
We have one month to reply to you and give you the information that you require. We would ask, therefore, that any requests you make are in writing and it is made clear to us what and how much information you require.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct any information you think is inaccurate. It is very important that you make sure you tell us if your contact details including your mobile phone number has changed.
You have the right to ask for your information to be removed however, if we require this information to assist us in providing you with appropriate medical services and diagnosis for your healthcare, then removal may not be possible. You would need to make an appointment with Dr Plaut to discuss this.
We cannot share your information with anyone else for a purpose that is not directly related to your health, e.g. medical research, educational purposes, etc. We would ask you for your consent in order to do this however, you have the right to request that your personal and healthcare information is not shared by the clinic in this way. Please note the Anonymised Information section in this Privacy Notice.
You have the right to request that your personal and/or healthcare information is transferred, in an electronic form (or other form), to another organisation, but we will require your clear consent to be able to do this.
9 – THIRD PARTIES MENTIONED ON YOUR MEDICAL RECORD
Sometimes we record information about third parties mentioned by you to us during any consultation. We are under an obligation to make sure we also protect that third party’s rights as an individual and to ensure that references to them which may breach their rights to confidentiality, are removed before we send any information to any other party including yourself. Third parties can include: spouses, partners, and other family members.
10 – HOW WE USE THE INFORMATION ABOUT YOU
We use your personal and healthcare information in the following ways:
A. when we need to speak to, or contact other doctors, consultants, nurses or any other medical/healthcare professional or organisation during the course of your treatment or ongoing healthcare;
B. when we are required by Law to hand over your information to any other organisation, such as the police, by court order, solicitors, or immigration enforcement.
We will never pass on your personal information to anyone else who does not need it, or has no right to it, unless you give us clear consent to do so.
11 – LEGAL JUSTIFICATION FOR COLLECTING AND USING YOUR INFORMATION
The Law says we need a legal basis to handle your personal and healthcare information.
CONSENT: Sometimes we also rely on the fact that you give us consent to use your personal and healthcare information so that we can take care of your healthcare needs.
Please note that you have the right to withdraw consent at any time if you no longer wish to receive services from us.
NECESSARY CARE: Providing you with the appropriate healthcare, where necessary. The Law refers to this as ‘protecting your vital interests’ where you may be in a position not to be able to consent.
LAW: Sometimes the Law obliges us to provide your information to an organisation (see above).
12 – SPECIAL CATEGORIES
The Law states that personal information about your health falls into a special category of information because it is very sensitive. Reasons that may entitle us to use and process your information may be as follows:
PUBLIC INTEREST: Where we may need to handle your personal information when it is considered to be in the public interest. For example, when there is an outbreak of a specific disease and we need to contact you for treatment, or we need to pass your information to relevant organisations to ensure you receive advice and/or treatment;
CONSENT: When you have given us consent;
VITAL INTEREST: If you are incapable of giving consent, and we have to use your information to protect your vital interests (e.g. if you have had an accident and you need emergency treatment);
DEFENDING A CLAIM: If we need your information to defend a legal claim against us by you, or by another party;
PROVIDING YOU WITH MEDICAL CARE: Where we need your information to provide you with medical and healthcare services
13 – HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We carefully consider any personal information that we store about you, and we will not keep your information for longer than is necessary for the purposes as set out in this Privacy Notice.
14 – IF ENGLISH IS NOT YOUR FIRST LANGUAGE
If English is not your first language you can request a translation of this Privacy Notice. Please contact our Data Protection Officer.
15 – COMPLAINTS
If you have a concern about the way we handle your personal data or you have a complaint about what we are doing, or how we have used or handled your personal and/or healthcare information, please write to the complaints team in the first instance.
However, you have a right to raise any concern or complaint with the UK information regulator, at the Information Commissioner’s Office: https://ico.org.uk/.
16 – SECURITY
We take the security of your information very seriously and we do everything we can to ensure that your information is always protected and secure. We regularly update our processes and systems and we also ensure that our staff are properly trained. We also carry out assessments and audits of the information that we hold about you and make sure that if we provide any other services, we carry out proper assessments and security reviews.
17 – TEXT MESSAGING AND CONTACTING YOU
Because we are obliged to protect any confidential information we hold about you and we take this very seriously, it is imperative that you let us know immediately if you change any of your contact details.
We may contact you using SMS texting to your mobile phone in the event that we need to notify you about appointments and other services that we provide to you involving your direct care, therefore you must ensure that we have your up to date details. This is to ensure we are sure we are actually contacting you and not another person.
18 – WHERE TO FIND OUR PRIVACY NOTICE
You may find a copy of this Privacy Notice on our website, or a copy may be provided on request.
19 – CHANGES TO OUR PRIVACY NOTICE
We regularly review and update our Privacy Notice. This Privacy Notice was last updated on 21st May 2018.