Privacy Policy and Cookies

 Privacy Notice

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data.

Dr Sandy Flann is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Our email address is [email protected]

Our postal address is PO Box 574, Tonbridge, TN9 9NA, UK.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected]

Patients – Sensitive Data

We need to collect the following sensitive data about you in order to provide you with medical care. 

This will require the following information:

Full name

Date of birth

Postal address

Email address

Telephone number

Name of registered GP and GP practice with which you are registered

Whether you have health insurance or are self-paying. 

If you have health insurance, the name of your insurance company, your policy number and authorisation code.

We require your explicit consent for processing sensitive data.

VIP Club members

We need to collect the following data about you: 

Full name

Job title, place of work and GMC no if applicable

Email address

 

2. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when legally permitted. The most common uses of your personal data are:

• Where we need to perform the contract between us.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at [email protected]

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing
To register you as a new client	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests to recover debts owed to us
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests to keep our records updated and to study how clients use/view our services
To enable you to partake in a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests to study how clients use our services, to improve upon them and grow our business
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (b) Necessary to comply with a legal obligation
To deliver relevant content to you and measure and understand the effectiveness of our advertising	(a) Identity (b) Contact (c) Profile (d) Usage (e) Communications (f) Technical	Necessary for our legitimate interests to study how customers use our services, to develop and improve upon them, to grow our business
To use data analytics to improve our website, services, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests to define types of clients for our services, to keep our site updated and relevant, to develop our business

 

Marketing communications 

You will receive marketing communications from us if you have:

• requested information from us or purchased or services from us; or
• if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
• in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for their marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by emailing us at [email protected]

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

3. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 2 above:

• Referral on to another specialist medical/surgical consultant or service as part of your ongoing medical care.
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties to whom we transfer or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).]

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers 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 do our best to ensure a similar degree of security of data 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; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for a minimum of six years after they cease being clients for tax purposes.

Medical records are kept in line with the Records Management Code of Practice for Health and Social Care 2016, namely for a minimum of eight years after the last consultation for standard adult health records, thirty years after the last consultation or eight years after patient death for skin cancer health records and up to the 25^th or 26^th birthday for childrens’ health records.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at [email protected]

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Cookies Policy

Cookies are pieces of information that a website transfers to a user’s hard drive for record-keeping purposes. Cookies make web-surfing easier for you by saving your preferences while you’re at a site.

The use of cookies is an industry standard — you’ll find them at most websites. For example, we may use cookies on the site to verify a subscriber’s login status. They are not used to store personal information, or to retain historical or transactional subscriber data.

By showing how and when visitors use the site, cookies help us see which areas are popular and which are not. Information such as the total number of visitors and pages viewed is most easily tracked with cookies. We may use the information from cookies to make improvements and updates to the site and to tailor our services to our visitors needs.

Specifically this site uses Google Analytics, which sets cookies, to analyse visitors and use of the site.

You always have the option of disabling cookies using your browser preferences. Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or indicate when a cookie is being sent. However, please be aware that some features of the Site will not function properly or may be slower if you refuse cookies.

By using browser settings which allow cookies and continuing to using our site you consent to our use of cookies.