Privacy Policy

1.0 Introduction:

This privacy notice lets you know what happens to any personal data that you give to us, or any information that we may collect from you or about you from other organisations.
This privacy notice applies to personal information processed by or on behalf of the clinic.
This Notice explains:

  • Who we are and how we use your information
  • Information about our Data Protection Officer
  • What kinds of personal information about you we hold and use (process)
  • The legal grounds for our processing of your personal information (including when we share it with others)
  • What should you do if your personal information changes?
  • For how long your personal information is retained / stored by us?
  • What are your rights under Data Protection laws

The General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA 2018) became law on 25th May 2018. The GDPR is a single EU-wide regulation on the protection of confidential and sensitive (special) information, the DPA 2018 deals with elements of UK law that differ from the European Regulation, both came into force in the UK on the 25th May 2018, repealing the previous Data Protection Act (1998).

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 the practice responsible for your personal data is Satin Healthcare.

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.

Satin Healthcare will be what’s known as the ‘Controller’ of your personal data.

We collect basic personal data about you and location-based information. This does include name, address and contact details such as email and mobile number etc.

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) ethnicity and sex life information that are linked to your healthcare, we may also receive this information about you from other health providers or third parties.

3.0 Why do we need your information?

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously. These records help to provide you with the best possible healthcare and treatment.
Satin Healthcare records may be electronic, paper-based or a mixture of both. We use a combination of working practices and technology to ensure that your information is kept confidential and secure.
Records about you may include the following information:

  • Details about you, such as your address, your carer or legal representative and emergency contact details.
  • Any contact the clinic has had with you, such as appointments, clinic visits, and emergency appointments.
  • Notes and reports about your health.
  • Details about your treatment and care.
  • Results of investigations such as laboratory tests, x-rays etc.
  • Relevant information from other health professionals, relatives or those who care for you.
  • Contact details (including email address, mobile telephone number and home telephone number)

To ensure you receive the best possible care, your records are used to facilitate the care you receive, including contacting you. Information held about you may be used to help protect the health of the public and to help us manage the services we provide. Limited information may be used within the clinic for clinical audit to monitor the quality of the service we provided.

4.0 How do we lawfully use your data?

We need your personal, sensitive and confidential data in order to provide you with healthcare services as a medical 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

This Privacy Notice applies to the personal data of our patients and the data you have given us about your carers/family members.
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, 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 consent to do so.

5.0 Legal justification for collecting and using your information

The law says we need a legal basis to handle your personal and healthcare information.

  • Consent: we 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).

6.0 Special categories

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 (eg 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

7.0 Medicines Management

The clinic will 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 Patient Communication

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.

We may contact you using SMS texting to your mobile phone in the event that we need 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. As this is operated on an ‘opt out’ basis we will assume that you give us permission to contact you via SMS if you have provided us with your mobile telephone number. Please let us know if you wish to opt out of this SMS service. We may also contact you using the email address you have provided to us. Please ensure that we have your up-to-date details.

9.0 Safeguarding

The clinic is dedicated to ensuring that the principles and duties of safeguarding adults and children are holistically, consistently and conscientiously applied with the wellbeing of all, at the heart of what we do.
The data collected by clinic staff in the event of a safeguarding situation will be as much personal information as is possible that is necessary to obtain in order to handle the situation. In addition to some basic demographic and contact details, we will also process details of what the safeguarding concern is. This is likely to be special category information (such as health information).
The clinic will either receive or collect information when someone contacts the organisation with safeguarding concerns, or we believe there may be safeguarding concerns and make enquiries to relevant providers.
The information is used by the clinic when handling a safeguarding incident or concern. We may share information accordingly to ensure duty of care and investigation as required with other partners such as local authorities, the police or healthcare professionals.

10.0 IT Services

Companies that provide IT services & support, including our core clinical systems; systems which manage patient facing services (such as our website and service accessible through the same); data hosting service providers; systems which facilitate appointment bookings or electronic prescription services; document management services etc.
Payment providers (for payment of services when using a debit or credit card)

11.0 How do we maintain the confidentiality of your records?

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

Every member of staff who works for Satin Healthcare 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. 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.

Our clinic policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the General Data Protection Regulation (GDPR) and all UK specific Data Protection Requirements. Our policy is to ensure all personal data related to our patients will be protected.

In certain circumstances you may have the right to withdraw your consent to the processing of data. Please contact Satin Healthcare in writing if you wish to withdraw your consent. In some circumstances we may need to store your data after your consent has been withdrawn to comply with a legislative requirement. Where we do this, we take strict measures to ensure that individual patients cannot be identified.

12.0 With your consent we would also like to use your information

There are times that we may want to use your information to contact you or offer you services, not directly about your healthcare, in these instances we will always gain your consent to contact you. We would however like to use your name, contact details and email address to inform you of other services that may benefit you. We will only do this with your consent.
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.

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 Satin Healthcare.

13.0 What should you do next?

You do not need to do anything if you are happy about how your confidential patient information is used.
If you do not want your confidential patient information to be used for research and planning, you can choose to opt out securely online or through a telephone service.

13.0 Where do we store your information electronically?

Jelly Software
The clinic uses a clinical system provided by a Data Processor called Jelly which stores Web data in a highly secure, third party cloud hosted environment.

14.0 Sharing your information without consent

We will normally ask you for your consent, but there are times when we may be required by law to share your information without your consent, for example:

  • where there is a serious risk of harm or abuse to you or other people;
  • safeguarding matters and investigations
  • where a serious crime, such as assault, is being investigated or where it could be prevented;
  • where a formal court order has been issued;
  • where there is a legal requirement, for example if you had committed a Road Traffic Offence.

15.0 How long will we store your information?

We are required under UK 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.
More information on records retention can be found online at https://transform.england.nhs.uk/information-governance/guidance/records-management-code/

16.0 How can you access, amend move the personal data that you have given to us?

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.
Right to object: If we are using your data and you do not agree, you have the right to object. We will respond to your request within one month (although we may be allowed to extend this period in certain cases). This is NOT an absolute right sometimes we will need to process your data even if you object.
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 send you information about us or matters you may be interested in), you may withdraw your consent at any time.

17.0 Access to your personal information

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 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 to the clinic.
There is no charge to have a copy of the information held about you
We are required to provide you with information within one month
You will need to give adequate information (for example full name, address, date of birth and details of your request) so that your identity can be verified, and your records located information we hold about you at any time.

18.0 What should you do if your personal information changes?

You should tell us so that we can update our records please contact Satin Healthcare 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), the clinic will from time to time ask you to confirm that the information we currently hold is accurate and up-to-date.

19.0 Our website

The only website this Privacy Notice applies to is the Surgery’s website. If you use a link to any other website from the Surgery’s website then you will need to read their respective Privacy Notice. We take no responsibility (legal or otherwise) for the content of other websites.

20.0 CCTV recording

CCTV is due to be installed on our practice premises covering both the external area of the building and the internal area excluding consulting rooms. Images are held to improve the personal security of patients and staff whilst on the premises, and for the prevention and detection of crime. The images are recorded onto an integral hard drive of the equipment and are overwritten on a rolling basis. Viewing of these digital images is password protected and controlled by Satin Healthcare.

21.0 Telephone system

Our telephone system does not currently record our telephone calls.

22.0 Objections / Complaints

Should you have any concerns about how your information is managed at the clinic, please contact the Satin Healthcare. If you are still unhappy following a review by Satin Healthcare, you have the 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
https://ico.org.uk/

If you are happy for your data to be 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 Satin Healthcare.