2. WHAT IS PERSONAL DATA?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as “any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier”.

Personal data is, in simple terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

3. WHAT ARE MY RIGHTS?

Under the GDPR, you have the following rights, which we will always work to uphold:

  • The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 10.
  • The right to access the personal data we hold about you. Part 9 will tell you how to do this. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 10 to find out more. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of certain personal data that we have. Please contact us using the details in Part 10 to find out more. Please note that this may be constrained by our own statutory obligation to retain financial and professional records.
  • The right to restrict (i.e. prevent) the processing of your personal data. The right to object to us using your personal data for a particular purpose or purposes. The right to data portability: to ask for the personal information you have made available to us to be transferred to you or a third party
  • Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 10.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

4. WHAT PERSONAL DATA DO YOU COLLECT?

We may collect some or all of the following personal data through your contact with us including by phone, by email, through our websites, by filling in application or other forms, through social media or in person (for example, in medical consultations, diagnosis and treatment). This may vary according to your relationship with us and the purposes for which you engage our services or purchase our products:

Standard personal information: for example, information we use to contact you, identify you or manage our relationship with you such as name; date of birth; and/or age; gender; address; email address; contact telephone number; business name, employment or profession; job title; payment information.

Special category information: Information about your health such as medical history, vaccination history, laboratory test results

Your personal data may also be collected from third parties (anyone acting on your behalf) such as:

  • Your parent or guardian, if you are under 18 years’ old
  • Your employer, if you are covered by a contract for services your employer has taken out or if we are providing occupational health services
  • Your health insurance provider
    Laboratories and imaging centres processing your test results

Your NHS GP, other doctors, clinicians, healthcare professionals and providers (for example specialist medical professionals pursuant to a referral made at your request).

5. HOW DO YOU USE MY PERSONAL DATA?

Under the GDPR, we must always have a lawful basis for using your personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it.

We process your personal information for a number of legitimate reasons, including managing all aspects of our relationship with you, to help us improve our services and products, for marketing and in order to exercise our rights, for example, in dealing with any complaints. We can only use your personal information to send you marketing material if we have your permission or a legitimate interest as described below.

Legitimate interest is one of the legal reasons why we may process your personal information. Taking into account your interests and rights, legitimate interests which allow us to process your personal information include:

  • To manage our relationship with you, our business and third parties who provide services or products for us
  • To provide health-care services on behalf of a third party, for example your employer or health insurance provider
  • To maintain up-to-date records and providing you with marketing as allowed by law for statistical research and analysis so that we can monitor and improve our services, websites, or develop new ones
  • To develop and carry out marketing activities so we can show you information that is of interest to you, based on our understanding of your preferences
  • To monitor our clinical and non-clinical performance

Your personal data may therefore be used for one of the following purposes:

  • Providing and managing your account.
  • Supplying our medical and healthcare services and products to you. Your personal data is required in order for us to enter into a contract with you for the provision of our services and products as requested by you.
  • To meet your healthcare needs: personalising and tailoring our services and products for you, for example providing services that are age-appropriate and vaccines that are licensed for specific age groups only.
  • Communicating with you. This may include responding to emails or calls from you; at your request sending you reports and results from recent medical or healthcare consultations; sending you reminder and recall appointment letters when products have expired or been replaced and/or services are next due.
  • Supplying you with information by email. With your permission and/or where permitted by law, we may use your personal data for our marketing purposes, which may include contacting you by email with health information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out by emailing info@fluclinic2you.com

6. HOW LONG WILL YOU KEEP MY PERSONAL DATA?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Your medical and healthcare data will be retained for a minimum period of 10 years as part of our duty of care and good medical practice as defined by the British Medical Association to retain such records and not destroy them.

Payment information will not be retained for longer than 6 months for accounting purposes. Credit card security numbers will be deleted as soon as payment is made and confirmed as received.

7. SECURITY: HOW AND WHERE DO YOU STORE OR TRANSFER MY PERSONAL DATA?

We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third parties.

These contracts ensure the same levels of personal data protection that would apply under the GDPR.

8. DO YOU SHARE MY PERSONAL DATA?

We will never sell, copy or generally distribute your personal data. We do sometimes need to share your information with other people or organisations for the purposes set out in this privacy notice and cookie policy:
doctors, specialist clinicians, other healthcare professionals or providers your employer
your health insurance provider

If you do not wish us to advise your NHS GP of any particular matters, please inform us during the consultation and we will ensure that this does not happen.

We will keep your information confidential, save for where in some very limited circumstances we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. If we must share your personal information, we will ensure appropriate protection is in place to protect your personal information in line with data-protection laws.

9. HOW CAN I ACCESS MY PERSONAL DATA?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email shown in Part 10.

There is normally no charge for a subject access request. If, however, your request is “manifestly unfounded or excessive” (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

10. HOW DO I CONTACT YOU?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

For the attention of Paras Maroo:

Email address: info@fluclinic2you.com