PATIENT PRIVACY NOTICE
1. This Privacy Notice sets out details of the information that Mr Vik Veer (I or me) may collect from you and how that information may be used. Please take your time to read this Privacy Notice carefully.
2. In the event that you have any queries, comments or concerns in respect of the manner in which I have used, or potentially will use, your personal information then you should contact me directly on either 0207 458 4584 or by email firstname.lastname@example.org
Your personal data3. I am the Data Controller in respect of your personal information which I hold about you. This will mainly relate to your medical treatment but will be likely to also include other information such as financial data in relation to billing. I must comply with the data protection legislation and relevant guidance when handling your personal information.
4. I will process your data in accordance with the law, the principles of this Privacy Notice and to the extent that it is necessary to do so.
5. Your personal information will be handled in accordance with the principles set out within this Privacy Notice. This means that whenever I use your personal data, I will only do so as set out in this Privacy Notice.
What personal information do I collect and use from patients?6. I will use “special categories of personal information” (previously known as "sensitive personal data") about you, such as information relating to your physical and mental health.
7. If you provide personal information to me about other individuals (including medical or financial information) you should inform the individual about the contents of this Privacy Notice. I will also process such information in accordance with this Privacy Notice.
8. In addition, you should note that in the event you amend data which I already hold about you (for instance by amending a pre-populated form) then I will update my systems to reflect the amendments. Our systems will continue to store historical data.Personal information
9. As one of my patients, the personal information I hold about you may include the following:
b) Contact details, such as postal address, email address and telephone number (including mobile number)
c) Financial information, such as credit card details used to pay us and insurance policy details
e) Emergency contact details, including next of kin
f) Background referral details
Special Categories Personal Information10. As one of my patients, I 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. This may include the following:
a) Details of your current or former physical or mental health, including information about any healthcare you have received from other healthcare providers such as GPs, dentists or hospitals (private and/or NHS), which may include details of clinic and hospital visits, as well as medicines administered.
b) Details of services you have received from me
c) Details of your nationality, race and/or ethnicity
d) Details of your religion
e) Details of any genetic data or biometric data relating to you
11. The confidentiality of your medical information is important to me, and I make every effort to prevent unauthorised access to and use of information relating to your current or former physical and mental health (or indeed any of your personal information more generally). In doing so, I will comply with UK data protection law, including the Data Protection Act 2018 and all applicable medical confidentiality guidelines issued by professional bodies.
12. From 25 May 2018, the current Data Protection Act will be replaced by the EU General Data Protection Regulation (GDPR) and a new Data Protection Act. All uses of your information will comply with the GDPR and the new Data Protection Act from that date onwards
How do I collect your information?13. I may collect personal information from a number of different sources including, but not limited to:
c) Other hospitals, both NHS and private (including Spire/Spire/another independent provider)
d) Mental health providers
e) Commissioners of healthcare services
f) Other clinicians (including their medical secretaries)
Directly from you14. Information may be collected directly from you when:
a) You enter into a contract with me
b) You submit a query to me including by email
c) You correspond with me by letter, email, telephone
From other healthcare organisations15. My patients will usually receive healthcare from other organisations, and so in order to provide you with the best treatment possible I may have to collect personal information about you from them. These may include:
a) Medical records from your GP
b) Medical records from other clinicians (including their medical secretaries)
c) Medical records from your dentist
d) Medical records from the NHS or any private healthcare organisation
16. Medical records include information about your diagnosis, clinic and hospital visits and medicines administered.
From third parties17. As detailed in the previous section, it is often necessary to seek information from other healthcare organisations. I may also collect information about you from third parties when:
a) You are referred to me for the provision of services including healthcare services
b) I liaise with your current or former employer, health professional or other treatment or benefit providerc) I liaise with your family
d) I liaise with your insurance policy provider
e) I deal with experts (including medical experts) and other service providers about services you have received or are receiving from me
f) I deal with NHS health service bodies about services you have received or are receiving
g) I liaise with credit reference agencies
h) I liaise with debt collection agencies
i) I liaise with Government agencies, including the Ministry of Defence, the Home Office and HMRC
How will I communicate with you?18. I may communicate with you in a range of ways, including by telephone, SMS, email, and / or post.
If I contact you using the telephone number(s) which you have provided (landline and/or mobile),and you are not available which results in the call being directed to a voicemail and/or answering service, I may leave a voice message on your voicemail and/or answering service as appropriate and including only sufficient basic details to enable you to identify who the call is from, very limited detail as to the reason for the call and how to call me back.
19. Please note that although providing your mobile number and email address and stating a preference to be communicated by a particular method will be taken as an affirmative confirmation that you are happy for us to contact you in that manner, I am not relying on your consent to process your personal data in order to correspond with you about your treatment. As set out further below, processing your personal data for those purposes is justified on the basis that it is necessary to provide you with healthcare service.
What are the purposes for which your information is used?20. I may 'process' your information for a number of different purposes, which is essentially the language used by the law to mean using your data. Each time I use your data I must have a legal justification to do so. The particular justification will depend on the purpose of the proposed use of your data. When the information that we process is classed as a “special category of personal information”, I must have a specific additional legal justification in order to use it as proposed.
21. Generally, I will rely on the following legal justifications, or 'grounds':
a) Taking steps at your request so that you can enter into a contract with me to receive healthcare services.
b) For the purposes of providing you with healthcare pursuant to a contract between you and me.
c) I have an appropriate business need to process your personal information and such business need does not cause harm to you.
d) I have a legal or regulatory obligation to use such personal information.
e) I need to use such personal information to establish, exercise or defend my legal rights.
f) You have provided your consent to my use of your personal information.
22. Note that failure to provide your information further to a contractual requirement with me may mean that I am unable to set you up as a patient or facilitate the provision of your healthcare.
Appropriate business needs23. One legal ground for processing personal data is where I do so in pursuit of legitimate interests and those interests are not overridden by your privacy rights.
The right to object to other uses of your personal data24. You have a range of rights in respect of your personal data. This includes the right to object to me using your personal information in a particular way (such as sharing that information with third parties), and I must stop using it in that way unless specific exceptions apply. This includes, for example, if it is necessary to defend a legal claim brought against me, or it is otherwise necessary for the purposes of your ongoing treatment.
Purpose 1: To set you up as my patient, including carrying out fraud, credit, anti-money laundering and other regulatory checks
25. As is common with most business, I have to carry out necessary checks in order for you to become a patient. These include standard background checks, which I cannot perform without using your personal information.
26. Legal ground: Taking the necessary steps so that you can enter into a contract with me for the delivery of healthcare.
27. Additional legal ground for special categories of personal information: The use is necessary for reasons of substantial public interest, and it is also in my legitimate interests to do so.
Purpose 2: To provide you with healthcare and related services
28. Clearly, the reason you come to me is to provide you with healthcare, and so I have to use your personal information for that purpose. 29. Legal grounds:
a) Providing you with healthcare and related services
b) Fulfilling your contract with you for the delivery of healthcare
30. Additional legal grounds for special categories of personal information:
a) I need to use the data in order to provide healthcare services to you
b) The use is necessary to protect your vital interests where you are physically or legally incapable of giving consent
Purpose 3: For account settlement purposes
31. I will use your personal information in order to ensure that your account and billing is fully accurate and up-to-date
32. Legal grounds:
a) Me providing you healthcare and other related services
b) Fulfilling my contract with you for the delivery of healthcare
c) Me having an appropriate business need to use your information which does not overly prejudice you
d) Your consent
33. Additional legal grounds for special categories of personal information:
a) I need to use the data in order to provide healthcare services to you
b) The use is necessary in order for me to establish, exercise or defend my legal rights
c) Your consent
Purpose 4: Communicating with you and resolving any queries or complaints that you might have.
34. From time to time, patients may raise queries, or even complaints, with me. It is important that I am able to resolve such matters fully and properly and so I will need to use your personal information in order to do so.
35. Legal grounds:
a) Providing you with healthcare and other related services
b) Having an appropriate business need to use your information which does not overly prejudice you
36. Additional legal grounds for special categories of personal information:
a) The use is necessary for the provision of healthcare or treatment pursuant to a contract with a health professionalb) The use is necessary in order for me to establish, exercise or defend my legal rights
Purpose 5: Communicating with any other individual that you ask us to update about your care and updating other healthcare professionals about your care.
37. In addition, other healthcare professionals or organisations may need to know about your treatment in order for them to provide you with safe and effective care, and so I may need to share your personal information with them.
38. Legal grounds:
a) Providing you with healthcare and other related services
b) I have a legitimate interest in ensuring that other healthcare professionals who are routinely involved in your care have a full picture of your treatment
39. Additional legal ground for special categories of personal information:
a) I need to use the data in order to provide healthcare services to you
b) The use is necessary for reasons of substantial public interest under UK law
c) The use is necessary in order for me to establish, exercise or defend my legal rights
Purpose 6: Complying with our legal or regulatory obligations, and defending or exercising our legal rights
40. As a provider of healthcare, I am subject to a wide range of legal and regulatory responsibilities. I may be required by law or by regulators to provide personal information, and in which case I will have a legal responsibility to do so. From time to time, clinicians are unfortunately also the subject of legal actions or complaints. In order to fully investigate and respond to those actions, it is necessary to access your personal information (although only to the extent that it is necessary and relevant to the subject-matter).
41. Legal grounds:
a) The use is necessary in order for me to comply with our legal obligations
42. Additional legal ground for special categories of personal information:
a) I need to use the data in order for others to provide informed healthcare services to you
b) The use is necessary for reasons of the provision of health or social care or treatment or the management of health or social care systems
c) The use is necessary for establishing, exercising or defending legal claims
Purpose 7: Managing my business operations such as maintaining accounting records, analysis of financial results, internal audit requirements, receiving professional advice (e.g. tax or legal advice)
43. In order to do this, I will not need to use your special categories of personal information and so I have not identified the additional ground to use your information for this purpose.
44. Legal grounds:
a) Me having an appropriate business need to use your information which does not overly prejudice you
Disclosures to third parties:45. I may disclose your information to the third parties listed below for the purposes described in this Privacy Notice. This might include:
a) A doctor, nurse, carer or any other healthcare professional involved in your treatment
b) Other members of support staff involved in the delivery of your care, like receptionists and porters
c) Anyone that you ask me to communicate with or provide as an emergency contact, for example your next of kin or carer
d) NHS organisations, including NHS Resolution, NHS England, Department of Health
e) Other private sector healthcare providers
f) Your GP
g) Your dentist
h) Other clinicians (including their medical secretaries)
i) Third parties who assist in the administration of your healthcare, such as insurance companies
j) Private Healthcare Information Network
k) Government bodies, including the Ministry of Defence, the Home Office and HMRC
l) The police and other third parties where reasonably necessary for the prevention or detection of crime
m) Our insurers
n) Debt collection agencies
o) Credit referencing agencies
p) Our third-party services providers such as IT suppliers, actuaries, auditors, lawyers, marketing agencies, document management providers and tax advisers q) Selected third parties in connection with any sale, transfer or disposal of our businessr) I may also use your personal information to provide you with information about products or services which may be of interest to you where you have provided your consent.
46. I may communicate with these third parties in a variety of ways including, but not limited to, email, post, fax and telephone.
How long do I keep personal information for?47. I will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Notice and in order to comply with my legal and regulatory obligations.
48. If you would like further information regarding the periods for which your personal information will be stored, please contact me using the details outlined in section 3.
International data transfers49. I (or third parties acting on my behalf) will not store or process information that we collect about you in countries outside the European Economic Area ("EEA").
Your rights50. Under data protection law you have certain rights in relation to the personal information that I hold about you. These include rights to know what information is held and how it is used. You may exercise these rights at any time by contacting me using the details provided at section 3 above.
51. There will not usually be a charge for handling a request to exercise your rights.
52. If I cannot comply with your request to exercise your rights we will usually tell you why.
53. There are some special rules about how these rights apply to health information as set out in legislation including the Data Protection Act (current and future), the General Data Protection Regulation as well as any secondary legislation which regulates the use of personal information.
54. If you make a large number of requests or it is clear that it is not reasonable for me to comply with a request then we do not have to respond. Alternatively, I can charge for responding.Your rights include: The right to access your personal information
55. You are usually entitled to a copy of the personal information I hold about you and details about how I use it.
56. Your information will usually be provided to you in writing, unless otherwise requested. If you have made the request electronically (e.g. by email) the information will be provided to you by electronic means where possible.
57. Please note that in some cases I may not be able to fully comply with your request, for example if your request involves the personal data of another person and it would not be fair to that person to provide it to you.
58. You are entitled to the following under data protection law.
1. Under Article 15(1) of the GDPR I must usually confirm whether I have personal information about you. If I do hold personal information about you, I usually need to explain to you:
i. The purposes for which I use your personal information
ii. The types of personal information I hold about you
iii. Who your personal information has been or will be shared with
iv. Where possible, the length of time I expect to hold your personal information. If that is not possible, the criteria I use to determine how long I hold your information
v. If the personal data I hold about you was not provided by you, details of the source of the information
vi. Your right to ask me to amend or delete your personal information
vii. Your right to ask me to restrict how your personal information is used or to object to my use of your personal information
viii. Your right to complain to the Information Commissioner's Office
2. I also need to provide you with a copy of your personal data, provided specific exceptions and exemptions do not apply.
The right to rectification59. I take reasonable steps to ensure that the information I hold about you is accurate and complete. However, if you do not believe this is the case, you can ask me to update or amend it.The right to erasure (also known as the right to be forgotten)
60. In some circumstances, you have the right to request that I delete the personal information I hold about you. However, there are exceptions to this right and in certain circumstances I can refuse to delete the information in question. In particular, for example, I do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercising or defending legal claims.
The right to restriction of processing61. In some circumstances, I must "pause" our use of your personal data if you ask, although I do not have to comply with all requests to restrict my use of your personal information. In particular, for example, I do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercise or defending legal claims.
The right to data portability62. In some circumstances, I must transfer personal information that you have provided to you or (if this is technically feasible) another individual/ organisation of your choice. The information must be transferred in an electronic format.
The right to withdraw consent63. In some cases, I may need your consent in order for my use of your personal information to comply with data protection legislation. Where we do this, you have the right to withdraw your consent to further use of your personal information. You can do this by contacting me using the details provided at section 3 above.
The right to complain to the Information Commissioner's Office64. You can complain to the Information Commissioner's Office if you are unhappy with the way that I have dealt with a request from you to exercise any of these rights, or if you think I have not complied with its legal obligations.
65. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/66. Making a complaint will not affect any other legal rights or remedies that you have.
Updates to this Privacy Notice67. I may update this Privacy Notice from time to time to ensure that it remains accurate. In the event that these changes result in any material difference to the manner in which I process your personal data then I will provide you with an updated copy of the Policy.
68. This Privacy Notice was last updated on 2nd May 2018
Effective date: August 19, 2018
Consultant Surgeon ("us", "we", or "our") operates the www.consultant-surgeon.co.uk website (the "Service").
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
Information Collection And Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
- Cookies and Usage Data
We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking & Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
Use of Data
Consultant Surgeon uses the collected data for various purposes:
- To provide and maintain the Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer care and support
- To provide analysis or valuable information so that we can improve the Service
- To monitor the usage of the Service
- To detect, prevent and address technical issues
Transfer Of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.
Disclosure Of Data
Consultant Surgeon may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Consultant Surgeon
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
- By email: email@example.com
- By visiting this page on our website: http://www.consultant-surgeon.co.uk/privacy.html
- By phone number: 02074584584