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.
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:
- We must let you know why we collect personal and healthcare information about you;
- We must let you know how we use any personal and/or healthcare information we hold on you;
- We need to inform you in respect of what we do with it;
- We need to tell you about who we share it with or pass it on to and why;
- We need to let you know how long we can keep it for.
THE DATA PROTECTION OFFICER
The Data Protection Officer at the ROC Private Clinic is Dr. Cristina Romete. You may contact her on email@example.com 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.
ROC Private Clinic Ltd registered at 45 Queen Anne Street, W1G 9JF 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.
INFORMATION WE COLLECT FROM YOU
The information we collect from you will include:
- Your contact details (such as your name, address and email address);
- Your date of birth;
- Details in relation to your medical history;
- The reason for your visit to the clinic;
- How you would like to be communicated with outside of the clinic (E.G. telephone/email/post);
- Medical notes and details of diagnosis and consultations with our GPs and other health professionals within the clinic involved in your direct healthcare.
INFORMATION ABOUT YOU FROM OTHERS
We also collect personal information about you when it is sent to us from the following a hospital, a consultant or any other medical or healthcare professional, or any other person involved with your general healthcare.
YOUR PATIENT MANAGEMENT RECORD
Your patient management record is an electronic record of your healthcare history (and other relevant personal information) held on the ROC Private Clinic database. The database used is Crosscare https://www.oneadvanced.com/solutions/crosscare .
Your record may be shared with other healthcare professionals and additions to this record may also be made by relevant healthcare professionals and organisations involved in your direct healthcare. When registering with the clinic you will be asked for your consent for sharing data. You may have the right to demand that this record is not shared with anyone who is not involved in the provision of your direct healthcare. If you wish to enquire further as to your rights in respect of not sharing information on this record then please contact our Data Protection Officer.
WHO WE MAY PROVIDE YOUR PERSONAL INFORMATION TO, AND WHY
Whenever you use a health or care service, such as attending a GP or specialist appointment, important information about you is collected to help ensure you get the best possible care and treatment. This information may be passed to other approved organisations where there is a legal basis. Confidential information about your health and care is only used in this way where allowed by law and would never be used for any other purpose without your clear and explicit consent.
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:
- Hospital professionals (such as doctors, consultants, nurses, etc);
- Other GPs/Doctors;
- Nurses and other healthcare professionals;
- The Doctor’s Laboratory
- Any other person that is involved in providing services related to your general healthcare, including mental health professionals.
- For the purposes of complying with the law e.g. Police, Solicitors, Insurance Companies, General Medical Council;
- Anyone you have given your consent to, to view or receive your record, or part of your record. Please note, if you give another person or organisation consent to access your record we will need to contact you to verify your consent before we release that record. It is important that you are clear and understand how much and what aspects of, your record you give consent to be disclosed.
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.
YOUR RIGHTS AS A PATIENT
The Law gives you certain rights to your personal and healthcare information that we hold, as set out below:
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 email our Data Protection Officer. 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.
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 ROC Private 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.
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.
HOW WE USE THE INFORMATION ABOUT YOU
We use your personal and healthcare information in the following ways:
- 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 diagnosis or treatment or ongoing healthcare;
- when we are required by Law to hand over your information to any other organisation, such as the police, by court order, solicitors, General Medical Council 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.
LEGAL JUSTIFICATION FOR COLLECTING AND USING YOUR INFORMATION
The Law says we need a legal basis to handle your personal and healthcare information.
CONTRACT: We have a contract with you to deliver healthcare services to you.
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).
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
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. The medical records retention period at ROC Private Clinic is 30 years.
There is a separate privacy notice for patients under the age of 16, a copy of which may be obtained here.
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.
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, then please contact our Data Protection Officer.
Alternatively, you can contact the Clinic Managers at firstname.lastname@example.org or email@example.com who can manage your complaint and send you a copy of the ROC Private Clinic complaints policy.
You also have the right to complain to the Information Commissioner Officer ICO https://ico.org.uk/make-a-complaint/. You may contact them by dialing 0303 123 1113.
OUR WEBSITE and COOKIES
The only website this Privacy Notice applies to is ROC Private Clinic’s website. If you use a link to any other website from the ROC Private Clinic website then you will need to read their respective privacy notice. We take no responsibility (legal or otherwise) for the content of other websites.
We will only collect personal information volunteered by you via our website, such as:
- Feedback from surveys and online forms.
- Email addresses.
- Preferred means of communication.
This personal information about you will be used to exercise our functions, and to improve the quality and safety of care.
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.
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 or your preferred method of contact.
We may contact you using email 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.
When registering with the clinic you will be asked for your preferred method of contact, including encryption.
WHERE TO FIND OUR PRIVACY NOTICE
You may find a copy of this Privacy Notice in the ROC Private Clinic waiting areas, on our website, or a copy may be provided on request.
CHANGES TO OUR PRIVACY NOTICE
We regularly review and update our Privacy Notice. This Privacy Notice was last updated on 25th January 2019.