System C Healthcare Limited of Arden Court, Arden Street, Stratford-upon-Avon, Warwickshire, CV37 6NT ("we"/"us"/"our") is committed to protecting and respecting your privacy.
Scope of Policy
This policy sets out how we use and protect any information about you.
For the purpose of the UK General Data Protection Regulation (UK GDPR) and any additional data protection legislation, the data controller responsible for your personal data is the healthcare provider who uses our products and services to deliver care and treatment to you (Data Controller).
We collect certain information and data about you whenever we provide our services or you use our patient portal or any of our mobile apps.
- Information by which you can be identified
- Questions, queries or feedback you leave, including your email address and mobile number if you provide it to us
- Details that allow you to access NHS services (you will always be told when this information is being collected, and it will only be used for the purpose you provide it for)
- Personal Data (including Special Category Data) which will be used for your direct care and treatment
Keeping your Data Secure
We will always treat the information you send us with the strictest confidence and ensure that our products and services meet all relevant security standards. However the World Wide Web is not completely secure and it is important that you are aware accessing or transmitting any data over the internet carries a risk and that we cannot guarantee the security of it. It is possible, though very unlikely, that someone other than you or us could access and read information sent to us or received from us in this way. If you feel concerned about this, please use another form of contact, e.g. telephone or post.
We have procedures and security features in place to keep your data secure once we receive it and in any electronic responses back to you.
Where your Data is Stored
Data collected as part of our services will be stored in accordance with the Data Controller’ instructions.
Data you provide to us when using our patient portal or mobile apps is stored on Microsoft® HealthVault™ or the Microsoft© Azure™ cloud platform’s secure servers in the United Kingdom.
Controlling your Personal Information
We will not sell, distribute or lease your personal identifiable information to third parties without your express permission.
Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
For the avoidance of doubt, you may request access to medical records held about you under the Data Protection Act 2018.
To exercise any of these rights you must contact our Data Protection Officer.
What do we do with the Information we Gather?
We require Personal Data to understand your needs and provide you with a better service.
Special Category Data is collected so that it will be available, as necessary and in a timely way, to enable members of your care team to safely and effectively treat and care for you.
The lawful basis for us processing your Personal Data and Special Category Data is the management of health and social care systems and services.
Who is your Information Shared with?
We will only share your information with the Data Controller.
In addition, we may disclose your personal information to third parties if we are required to do so by law or if we believe that such action is necessary to protect and defend the rights, property or personal safety of us, or any of our products or services.
How Long do we Keep your Information for?
We will only store your information in accordance with the Data Controller’s instructions and we will not hold your data for any longer than is necessary.
This policy may change from time to time, so please check this page periodically.
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights. Our Data Protection Officer’s contact details are: firstname.lastname@example.org
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 our Data Protection Officer in the first instance.