1.0 INTRODUCTION
1.1 This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you.
1.2 This privacy notice applies to personal information processed by or on behalf of AHI Clinic.
1.3 This Notice explains
- Who we are, how we use your information and details of our Data Protection Officer (DPO)
- What kinds of personal information about you we process
- What the legal grounds are for our processing of your personal information (including when we share it with others)
- What you should do if your personal information changes
- For how long your personal information is retained by us
- What your rights are under data protection laws
1.4 The General Data Protection Regulation (GDPR) became law on 24th May 2016. This is a single EU-wide regulation on the protection of confidential and sensitive information. It entered into force in the UK on the 25th May 2018, repealing the Data Protection Act (1998).
1.5 For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), and the Data Protection Act 2018 (currently in Bill format before Parliament) this AHI Clinic is responsible for your personal data.
1.6 This Notice describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
2.0 HOW WE USE YOUR INFORMATION AND THE LAW
2.1 Advance Hair Implants Ltd will be what’s known as the ‘Controller’ of the personal data you provide to us.
2.2 We collect basic personal data about you. This does include name, address, contact details such as email and mobile number etc.
2.3 We will also collect sensitive confidential data known as “special category personal data”, in the form of health information, religious belief (if required in a healthcare setting), sex and ethnicity during the services we provide to you and or linked to your healthcare through other health providers or third parties.
3.0 HOW DO WE COLLECT YOUR INFORMATION?
We may collect your personal information from number of different sources including but not limited to including GPs, Dentist, directly from you, Mental Health Providers, Commissioners of Healthcare services, Clinicians, Hospitals both NHS and Private. Information may be collected from you when you enter into a contract with AHI Clinic, when you submit your enquiry to us via telephone, website, email, social media or in person. In order to provide best treatment possible, it is sometimes necessary to collect further information about yourself from other organisation (only with your prior consent). These may include, your GP/Dentist/other Clinicians/doctors/ and other healthcare Providers.
4.0 WHY WE NEED YOUR INFORMATION
4.1 The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. NHS Trust, DOCTOR Surgery, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.
4.2 AHI Clinic health records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Records which the AHI Clinic holds about you may include the following information;
- Details about you, such as your address, carer, legal representative, emergency contact details
- Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc.
- Notes and reports about your health
- Details about your treatment and care
- Results of investigations such as laboratory tests, biopsies etc
- Relevant information from other health professionals, relatives or those who care for you
4.3 To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the Clinic/other Health Care Providers. Information may be used within the AHI Clinic for clinical audit to monitor the quality of the service provided.
5.0 HOW WE LAWFULLY USE YOUR DATA
5.1 We need to know your personal, sensitive and confidential data in order to provide you with Healthcare services at AHI Clinic, under the General Data Protection Regulation we will be lawfully using your information in accordance with: –
Article 6, (e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
Article 9, (h) processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems
5.2 This Privacy Notice applies to the personal data of our patients and the data you have given us about your carers/family members.
6.0 RISK STRATIFICATION
6.1 Risk stratification data tools are increasingly being used in the NHS/Health Care Providers to help determine a person’s risk of suffering a condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention.
6.2 Information about you may be collected, if necessary, with your prior consent, from several sources including GPs, Dentist, directly from you, Mental Health Providers, Commissioners of Healthcare services, Clinicians, Hospitals both NHS and Private and from this AHI Clinic. A risk score is then arrived at, through an analysis of your de-identified information and is only provided back to your doctor as data controller in an identifiable form.
6.3 Risk stratification enables your doctor to focus on preventing ill health and not just the treatment of sickness. If necessary, your doctor may be able to offer you additional services.
6.4 Please note that you have the right to opt out of your data being used in this way.
7.0 MEDICINES MANAGEMENT
7.1 AHI Clinic may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost-effective treatments.
8.0 HOW WE MAINTAIN THE CONFIDENTIALITY OF YOUR RECORDS
8.1 We are committed to protecting your privacy and will only use information collected lawfully in accordance with:
- Data Protection Act 2018
- The General Data Protection Regulations 2016
- Human Rights Act 1998
- Common Law Duty of Confidentiality
- Health and Social Care Act 2012
- NHS Codes of Confidentiality, Information Security and Records Management
- Information: To Share or Not to Share Review
8.2 Every member of staff who works for an organisation has a legal obligation to keep information about you confidential. We will only ever use or pass on information about you if others involved in your care have a genuine need for it.
8.3 We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.” This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott Principles.
8.4 Our practice policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the General Data Protection Regulations (GDPR) and all UK specific Data Protection Requirements. Our policy is to ensure all personal data related to our patients will be protected.
8.5 All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. The practice will, if required, sign a separate confidentiality agreement if the client deems it necessary. If a sub-contractor acts as a data processor for Advance Hair Implants Ltd an appropriate contract (art 24-28) will be established for the processing of your information.
8.6 In certain circumstances you may have the right to withdraw your consent to the processing of data. Please contact the Data Protection Officer in writing if you wish to withdraw your consent.
8.7 In some circumstances we may need to store your data after your consent has been withdrawn to comply with a legislative requirement. Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified.
8.8 There may be occasions where authorised research facilities would like you to take part in innovations, research, improving services or identifying trends. Sometimes your information may be requested to be used for such research purposes – the Practice will always gain your consent before releasing the information for this purpose in an identifiable format. In some circumstances you can Opt-out of the practice sharing any of your information for research purposes.
8.9 We would however like to use your name, contact details and email address to inform you of services that may benefit you, with your consent only. This information is not shared with third parties or used for any marketing and you can unsubscribe at any time via phone, email or by informing the AHI Clinic.
8.10 At any stage where we would like to use your data for anything other than the specified purposes and where there is no lawful requirement for us to share or process your data, we will ensure that you have the ability to consent and opt out prior to any data processing taking place.
9.0 WHO MIGHT WE SHARE YOUR INFORMATION WITH?
9.1 From time to time we may be required to share your personal information with a third party;
- NHS Trusts / Foundation Trusts/ Our Insurers
- GPs, Third party providers such as Auditors, Lawyers and Tax Advisers
- NHS Commissioning Support Units
- Independent Contractors such as dentists, opticians, pharmacists
- Ambulance Trusts
- Clinical Commissioning Groups
- Social Care Services
- NHS England (NHSE) and NHS Digital (NHSD)
- Local Authorities, Governments bodies including Ministry of Defence, the Home Office and HMRC
- Education Services
- Fire and Rescue Services
- Police & Judicial Services
- Voluntary Sector Providers
- Private Sector Providers
- Other ‘data processors’ which you will be informed of
9.2 You will be informed with whom your data will be shared and in most cases asked for your consent before this can be shared.
9.3 We may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure.
9.4 All employees and sub-contractors engaged by our AHI CLINIC are asked to sign a confidentiality agreement. If a sub-contractor acts as a data processor for Advance Hair Implants Ltd an appropriate contract (art 24-28) will be established for the processing of your information.
10.0 WHERE WE STORE YOUR INFORMATION ELECTRONICALLY
10.1 All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information may be located on servers within the European Union.
10.2 No third parties have access to your personal data unless the law allows them to do so and appropriate safeguards have been put in place.
10.3 We have a Data Protection regime in place to oversee the effective and secure processing of your personal and or special category (sensitive, confidential) data.
11.0 HOW LONG WE WILL STORE YOUR INFORMATION
11.1 We are required under UK tax law to keep your information and data for the full retention periods as specified by the NHS Records management code of practice for health and social care and national archives requirements.
11.2 More information on records retention can be found online at https://digital.nhs.uk/article/1202/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016
12.0 HOW YOU CAN ACCESS, AMEND MOVE THE PERSONAL DATA THAT YOU HAVE GIVEN TO US
12.0 Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
12.1 Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
12.2 Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example for a research project), or consent to market to you, you may withdraw your consent at any time.
12.3 Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data is collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
12.4 Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this with a doctor to doctor data transfer and transfer of your hard copy notes.
13.0 ACCESS TO YOUR PERSONAL INFORMATION
13.1 Data Subject Access Requests (DSAR): You have a right under the Data Protection legislation to request access to view or to obtain copies of what information the AHI CLINIC holds about you and to have it amended should it be inaccurate. To request this, you need to do the following:
Your request should be made in writing to the AHI CLINIC – for information from hospitals and other providers you should write directly to them
There is no charge to have a copy of the information held about you
We are required to respond to you within one month
13.1 Data Subject Access Requests (DSAR): You have a right under the Data Protection legislation to request access to view or to obtain copies of what information the AHI CLINIC holds about you and to have it amended should it be inaccurate. To request this, you need to do the following:
- Your request should be made in writing to the AHI CLINIC – for information from hospitals and other providers you should write directly to them
- There is no charge to have a copy of the information held about you
- We are required to respond to you within one month
- You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified, and your records located information we hold about you at any time.
14.0 WHAT YOU SHOULD DO IF YOUR PERSONAL INFORMATION CHANGES
14.1 You should tell us so that we can update our records, please contact the AHI Clinic or Clinical Services Manager as soon as any of your details change, this is especially important for changes of address or contact details (such as your mobile phone number).
14.2 The AHI Clinic will from time to time ask you to confirm that the information we currently hold is accurate and up-to-date.
15.0 OBJECTIONS / COMPLAINTS
15.1 Should you have any concerns about how your information is managed at the AHI Clinic please contact us.
Please use the link on our website : Contact Us: hello@ahiclinic.co.uk
15.2 If you are still unhappy following a review by the AHI CLINIC, you have a right to lodge a complaint with a supervisory authority: You have a right to complain to the UK supervisory Authority as below.
Information Commissioner:
Wycliffe house
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 01625 545745
www.informationcommissioner.gov.uk
15.3 If you are happy for your data to be extracted and used for the purposes described in this privacy notice, then you do not need to do anything. If you have any concerns about how your data is shared, then please contact the AHI Clinic.
15.4 If you would like to know more about your rights in respect of the personal data, we hold about you, please contact the Data Protection Officer as below.
16.0 DATA PROTECTION OFFICER
Radha Muthuswamy is our named Data Protection Officer. Any queries about Data Protection issues should be addressed to our DPO.
Radha Muthuswamy: r.muthuswamy@nhs.net
Please write the name of our clinic when you contact our DPO for any data protection related querries
17.0 WEBSITE AND COOKIES
www.advancehairimplnats.co.uk and Advance Hair Implants Clinic, take a proactive approach to users privacy and ensure the necessary steps taken to protect the privacy f its users throughout their visiting experience.
What are cookies? Cookies are small files saved to the user’s computer hard drive that track, save and store information about the user’s interactions and usage of website, this can help to provide tailored and better experience to our users. Users can allow or disallow the use of this on their first visit to our website
17.1 External Links, Adverts and Sponsored links: Users are advised to adopt a policy of caution before clicking any external web links, adverts and sponsored links as we do not provide any guarantee or verify the contents of such contents. User should therefore note they click on these links on their own risk.
18.0 SURVEYS
We may contact to ask you to participate in surveys regarding your treatments with the AHI Clinic, which are usually sent via email. These are meant to only gather information of your experience of our services for the purpose of improving the quality of our services. Participation is completely voluntary, and you can unsubscribe from receiving further similar invitations.
19.0 CHANGES
It is important to point out that we may amend this Privacy Notice from time to time. If you are dissatisfied with any aspect of our Privacy Notice, please contact the Data Protection Officer.
20.0 CCTV RECORDING
For the safety of the staff and users we have 24 hour CCTV monitoring outside and inside the Clinic.