GLASGOW MEDICAL ROOMS
Patient Privacy Notice
• Why do we use your data? We use information about you for the purpose of providing you with our healthcare services. We use your sensitive data: As a patient, we will use information about your health, racial and ethnic origin, sexual orientation and religion
• Sharing data: We may share your data with third parties, including other healthcare providers who may contribute to your care, your GP, statutory bodies concerned with the regulation of your care, and other agencies who may be involved in your care.
• Security: We respect the security of your data and treat it in accordance with the law. International transfer: We work with international medical providers where we may transfer data with the patient’s express consent.
Glasgow Medical Rooms respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after patient’s personal data and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- IMPORTANT INFORMATION AND WHO WE ARE
- Under the General Data Protection Regulation and Data Protection Act 2018 (GDPR), we are required to explain to our patients why we collect information about you, how we intend to use that information and whether we will share this information with anyone else.
- This statement applies to all our patients and also prospective patients.
- We may update this statement at any time, and we will provide you with a new privacy statement 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.
- It is important that you read this statement so that you know how and why we use information about you. It is also important that you inform us of any changes to your personal information so that the information which we hold about you is accurate and up to date.
- We are PAMM Healthcare Limited, trading as Glasgow Medical Rooms and are a “data controller” for the information which we hold about you. This means that we are responsible for deciding how we hold and use the personal information which we hold about you.
- We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
- Our full details are:
Full name of legal entity: PAMM Healthcare Limited which is a company registered in Scotland under the company number SC489259 and whose registered address is 211 St Vincent Street, Glasgow G2 5QY.
Data Protection Officer email address: firstname.lastname@example.org
Postal address: 211 St Vincent Street, Glasgow G2 5QY
Telephone number: 0141 225 0140
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2 WHY ARE WE COLLECTING YOUR INFORMATION?
2.1 We ask for information about you so that we can make sure we provide you with the best healthcare care and service as our patient.
2.2 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide you with the service you require, but we will notify you if this is the case at the time.
3 TYPES OF PERSONAL INFORMATION WE USE
- We are collecting information about you which is relevant to your stay with us and the care which we provide to you. This includes:
- personal details (such as name, date of birth, gender, marital status, national insurance number, occupation);
- contact details (such as your address, personal telephone numbers and personal email address);
3.1.3 financial information (such as your bank account details and information about your financial circumstances
- information about your next of kin (for the purpose of emergency contact details);
- information about other healthcare providers (such as your GP and practice details);
- video and photographs of you (such as CCTV footage, photographs for security purposes, etc):
SPECIAL CATEGORIES OF PERSONAL DATA
- Some of the information which we collect about you may be “special categories of personal data”. Special categories of data require a greater level of protection. The special categories of personal data about you which we may collect include:
- information about your racial or ethnic origin
- information about your religious beliefs;
- information about your sex life and sexual orientation;
- healthcare information, including:
(a) any disabilities or special requirements which you may have;
(b) medical records relating to your treatment by us;
(c) your medical history; and
(d) records required by care regulators.
4 . SOURCE OF YOUR PERSONAL INFORMATION
- The above information which we collect about you will be obtained through a variety of sources which include:
- from you directly both prior to and during the course of your treatment by us;
- from your friends and relatives who provide us with information about you;
- from your employer (if they have been involved in directing you to us); and
- from other healthcare professionals and officers in the local authority/ social services department.
5. HOW AND WHY WE USE YOUR PERSONAL DATA
- In accordance with the data protection laws, we need a “lawful basis” for collecting and using information about you for any particular purpose.
- We have set out below the different purposes for which we collect and use your personal data, along with the lawful bases on which we will rely.
|Why we use your information||Our lawful basis for using your information|
|Provision of care and related services: To provide you with safe, appropriate and personalised care as one of our patients and ensure that we meet your individual requirements.||It is necessary to perform our contract with you.
It is necessary to meet legal/regulatory obligations.
It is necessary for our legitimate interests (where they are not overridden by your rights). It is necessary for the protection of your vital interests.
It is necessary for us to provide you with healthcare.*
|Finance: Administering payments for your treatment by us.||It is necessary for our legitimate interests (where they are not overridden by your rights). It is necessary to perform our contract with you.|
|Admin: Administrative matters which are necessary for the day to day functioning of our organisation. This may occasionally include the prevention, detection and investigation of fraud and corruption.||It is necessary to perform our contract with you. It is necessary to meet legal/regulatory obligations.
It is necessary for our legitimate interests (where they are not overridden by your rights). It is necessary for us to provide you with healthcare.*
|Analysis and monitoring: Analysing the quality of care delivered to our patients as part of our continuing service improvement.||It is necessary to perform our contract with you. It is necessary for our legitimate interests (where they are not overridden by your rights). It is necessary to meet legal/regulatory obligations. It is necessary for us to provide you with healthcare.*|
|Complaints: Handling any complaints made, concerns raised.||It is necessary to perform our contract with you. It is necessary for our legitimate interests (where they are not overridden by your rights). It is necessary to meet legal/regulatory obligations. It is necessary for us to provide you with healthcare.*|
|Safeguarding and regulation: We use your personal data for the purpose of safeguarding and regulation of healthcare.||It is necessary to perform our contract with you. It is necessary to meet legal/regulatory obligations. It is necessary for our legitimate interests (where they are not overridden by your rights). It is necessary for us to provide you with healthcare.*|
|Communication: We will need to use your personal information to communicate with you before, during and after your treatment.
For example, when you telephone us, we may record those calls for monitoring and training purposes.
|It is necessary to perform our contract with you. It is necessary for our legitimate interests (where they are not overridden by your rights).|
|Marketing: We will use your personal information to notify you of the details of our products and services which we think will be of benefit or interest to you.||It is necessary for our legitimate interests (where they are not overridden by your rights).|
|Improving our services: We may ask you to voluntarily complete patient surveys to help us improve the services which we provide to you.||We rely on your explicit consent for us to use your personal data.*|
|Security: We may need to capture images of you as part of our security processes such as use of CCTV footage.||It is necessary for our legitimate interests (where they are not overridden by your rights). It is necessary for the management of health and social care services.*|
|* This is an additional lawful basis which we need to rely on in order to use special categories of data such as information about your health|
6. COMPLYING WITH DATA PROTECTION LAW
- We will comply with data protection law when using your personal information. At the heart of data protection laws are the “data protection principles” which say 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; and
- kept securely.
7. SHARING YOUR INFORMATION
7.1 We will share your personal information with third parties where we have a lawful basis for doing so.
7.2 The types of organisations with whom we share your personal data are as follows:
7.2.1 Healthcare providers and multi-disciplinary teams: Where it is lawful and necessary to do so, we will share information about you with other medical service providers involved directly with your care including laboratory services, imaging centre or specialists to whom you have requested a referral.
7.2.2 Your Employer: If your employer provides GP Services as an employee benefit for you, we may tell your employer you have attended an appointment. We will not share any personally identifiable data or medical details without your explicit consent to do so (e.g. for pre-employment medicals)
7.2.3 Regulators / Safeguarding authorities / Commissioners: We also share your personal data with these public bodies where we are required to do so by law.
7.2.4 The Police and other law enforcement agencies: In limited circumstances, we may be required to share your personal data with the police if required for the purposes of criminal investigations and law enforcement.
7.2.5 IT service providers: We may use external IT providers who may have access to your personal data from time to time as is necessary to perform their services.
7.2.6 Attorneys: Where it is lawful to do so, we may share your personal information with any individual who has authority to act on your behalf such as those granted power of attorney.
7.2.7 Next of kin: we may share your personal information with your next of kin (if we are aware of their contact details) in an emergency
- We will only share your personal data with your regular GP where we have your explicit consent.
8. TRANSFERRING INFORMATION OUTSIDE THE EU
We work with international medical assistance providers and travel insurers who refer patients to us who need to see a doctor while in London. These patients sign a consent form to have data passed back to the Medical Assistance Provider/ insurer. NB These patients are usually not UK residents.
For patients who are not referred to us by a medical assistance provider, we will not transfer data outside of the EEA.
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us at email@example.com If you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
9. CAN WE USE YOUR INFORMATION FOR ANY OTHER PURPOSE?
- We typically will only use your personal information for the purposes for which we collect it. It is possible that we will use your information for other purposes as long as those other purposes are compatible with those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.
9.2 We may also use your personal information for other purposes where such use is required or permitted by law.
10. STORING YOUR INFORMATION AND DELETING IT
10.1 We will only retain your personal information for as long as necessary to fulfil the purposes for which we have collected it or to fulfil another lawful purpose (as described above). When we no longer have a lawful purpose for holding your data, we will securely destroy your personal information in accordance with our data retention policy. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us at firstname.lastname@example.org
10.2 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.
11. YOUR RIGHTS
11.1 Under certain circumstances, by law you have the right to:
11.1.1 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.
11.1.2 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.
11.1.3 Request erasure of your personal information in certain circumstances. 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).
11.1.4 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) or public interest as our lawful basis for processing and there is something about your particular situation which leads you to object to processing on this ground. You also have the right to object if we are processing your personal information for direct marketing purposes.
11.1.5 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.
11.1.6 Request the transfer of your personal information to another party in certain circumstances.
11.2 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 our Data Protection Officer in writing.
12. RIGHT TO WITHDRAW CONSENT
12.1 In the limited circumstances where we are relying on your consent as our lawful basis to process your data 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 our Data Protection Officer. 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.
13. AUTOMATED DECISION MAKING
13.1 You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
14. RIGHT TO COMPLAIN TO THE ICO
14.1 You have the right to complain to the Information Commissioner’s Office (the “ICO”) if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.