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Cookies, Privacy Policies and GDPR

General Data Protection Regulation (GDPR) is effective from May 25th 2018. GDPR means that we at Harley Street Gynaecology will be more accountable for handling of people’s personal information and as such we have updated our data protection policies.

The practice aims to meet the requirements of the Data Protection Act 2018, the General Data Protection Regulation (GDPR), the guidelines on the Information Commissioner’s website as well as our professional guidelines and requirements.

You will be asked to provide personal information when joining the practice. The purpose of us processing this data is to provide optimum health care to you.

When Can Harley Street Process Personal data?

The processing of personal data under the GDPR needs to have a legal basis for the processing to be valid, often referred to as the “conditions for processing” under the DPA.

It is important that Harley Street Gynaecology determine the legal basis for processing as under the GDPR this has an effect on individuals rights. For example, if we only rely on consent as the basis for processing personal data, individuals have stronger rights such as having data deleted

The categories of data we process are:

  • Personal data for the purposes of staff and self-employed team member management
  • Personal data for the purposes of direct mail/email/text/other marketing
  • Special category data including health records for the purposes of the delivery of health care
  • Special category data including health records and details of criminal record checks for managing employees and contracted team members

We never pass your personal details to a third party unless we have a contract for them to process data on our behalf and will otherwise keep it confidential. If we intend to refer a patient to another practitioner or to secondary care such as a hospital we will gain the individual’s permission before the referral is made and the personal data is shared.

  • Personal data is stored in the EU whether in digital or hard copy format
  • Personal data is stored in the US in digital format when the data storage company is certified with the EU-US Privacy Shield
  • Personal data is obtained when a patient joins the practice, when a patient is referred to the practice and when a patient subscribes to an email list

The lawful basis for processing special category data such as patients’ and employees’ health data is:

  • Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of Union or Member State law or a contract with a health professional

The lawful basis of processing personal data such as name, address, email or phone number is:

  • Consent of the data subject
  • Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract.
  • We do not share these data with the third parties.

The retention period for special data in patient records is a minimum of 10 years and may be longer for complex records in order to meet our legal requirements. The retention period for staff records is 6 years. The retention periods for other personal data are 2 years after it was last processed. Details of other retention periods are available in the Record Retention (M 215) procedure available from the practice directly.

You have the following personal data rights:

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure (clinical records must be retained for a certain time period)
  • The right to restrict processing
  • The right to data portability
  • The right to object

Further details of these rights can be seen in our Information Governance Procedures (M 217C) or at the Information Commissioner’s website. Here are some practical examples of your rights:

  • If you are a patient of the practice you have the right to withdraw consent for important notifications, newsletters, surveys or marketing. You can inform us to correct errors in your personal details or withdraw consent from communication methods such as telephone, email or text. You have the right to obtain a free copy of your patient records within one month.
  • If you are not a patient of the practice you have the right to withdraw consent for processing personal data, to have a free copy of it within one month, to correct errors in it or to ask us to delete it. You can also withdraw consent from communication methods such as telephone, email or text.

We have carried out a Privacy Impact Assessment (M 217S) and you can request a copy from the details below. The details of how we ensure security of personal data is in our Security Risk Assessment (M 217M) and Information Governance Procedures (M 217C).

Comments, suggestions and complaints
Please contact the Practice Manager  for comments, suggestions or a complaints about your data processing. This can be via Email, in writing or by visiting the practice. We take complaints very seriously.

If you are unhappy with our response or if you need any advice you should contact the Information Commissioner’s Office (ICO). Their telephone number is 0303 123 1113.

The ICO can investigate your claim and take action against anyone who’s misused personal data.

Cookies

Related practice procedures
You can also use these contact details to request copies of the following practice policies or procedures:

  • Data Protection and Information Security Policy (M 233-DPT), Consent Policy (M 233-CNS)
  • Privacy Impact Assessment (M 217S), Information Governance Procedures (M 217C)
  • We will never share your information with other organisations for marketing, market research or commercial purposes.
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  • The anonymous information generated by Google Analytics cookies about your use of this website is transmitted to Google – not me. This information is processed to compile statistical reports on website activity for this site only. I use these reports to evaluate aggregate visitor usage so that I can optimise the content, and its marketing, to better meet your needs. This is essential for me to operate this website as a free to use service.
  • In summary, your anonymity is safe. That is my personal commitment to you as a valued reader. For more information, see my posts about online privacy best practice.
  • Further Information
  • For further information about how Google Analytics uses cookies and IP address data, see: http://www.google.com/intl/en/analytics/privacyoverview.html.
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