For the purposes of the processing your personal data, we are the data controller (as set out under EU General Data Protection Regulation 2016 (GDPR). We are committed to protecting your privacy, both on-line and in the real world. We appreciate that you do not want the personal information you provide to us distributed indiscriminately and here we explain how we collect information, what we do with it and what controls you have over our processing of your information.
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
Unless otherwise specified, any processing of personal data under taken by us or by one of our authorised subcontractors including doctors and pharmacists or our call centre operatives, relating to providing our healthcare services to a customer, an Authorised User of our Platform (or their dependants) is processed on the basis of our contractual relationship (or in anticipation of a contractual relationship). Where we do not have, or are not anticipating, a contractual relationship with a data subject (for example where processing personal data relating to a child or other dependant, we will generally be processing that data on the basis of legitimate interests.
In addition, where the personal data that we will be processing is “special data” which should be given additional safeguards, such as health information, we will only process that information if there is a valid special condition for processing (as set out in Article 9 of the GDPR). For the purposes of health data, we will rely on Special Condition Article 10(2)(h) (processing of health data where there are adequate safeguards and confidentiality obligations in place).
If we are processing personal data for the purposes of marketing, we will only do so if we have express consent of the data subject.
We may collect and process the following information about you:
You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services.
We will use the information you provide to:
We need to use your personal information for those purposes to provide our services and to perform our contract with you. In some cases, the collection of data may be a statutory or contractual requirement and we will be limited in the services that we can provide you with without your consent to Us to be able to use such data.
We also collect, store and use the personal information listed above to:
We have a legitimate interest in using your personal information for these purposes, so that we can constantly improve our Platform and our services, and to ensure that we are only sending you information that is going to be useful or relevant to you.
Finally, we use your personal information to:
Information that identifies you: We will only share personal information, from which you can be identified, in certain limited circumstances as described below.
We may share medical information about you, including your medical history, illnesses and prescriptions, with our doctors (all of whom are registered with the General Medical Council). We share your medical information with doctors in order to enable them to better assess health conditions, advise you and deliver the services that you request (in accordance with our terms and conditions). We may share your medical information with our doctors located outside the European Economic Area ("EEA"), including North America and Australia.
Unless the Terms and Conditions relating to your access and use of the Platform expressly state otherwise, we will not share any personal information, including medical records, with your insurer. If this situation changes, we will ask you before we share information in this way, unless you have already indicated your consent directly to your insurer. We may share your medical information related to certain referral pathways directly with your insurer, but only with your consent at the time of the consultation.
To process a prescription for medication on the Platform (as offered by a doctor or requested by you in accordance with our Terms and Conditions), it may be necessary to share basic identification data (such as your name, postal address, email address and phone number) with our dispensing pharmacy affiliate, taking all reasonable steps to protect your personal information, for the purposes of the pharmacy verifying your identification on collection of your prescription.
Partner providing you with the Healthcare Scheme
We may share certain basic identification information (such as name, date of birth, email and phone details) with our Partner who provides you with the Healthcare Scheme in order for them to verify your eligibility to use / continue to use the Service, to check you are happy with the Service you are receiving, for analytical purposes and to assist such Partners in improving their products, processes and services.
We may share certain basic identification information (such as name, date of birth, email and phone details) with our out-of-hours call centre [operated by a third-party provider], when you contact customer services in order to properly track and deal with whatever issues you have raised.
These call centre operatives may be located outside the UK but will be based within the EEA unless we otherwise inform you.
Some data from phone or text messaging communications may be temporarily transferred to, and stored on, servers located outside of the EEA.
Identity Checking Services
We will share certain identification information (such as name, date of birth, address, gender, identity document containing biometric data and photograph of data subjects face) with our identity checking partner:
Information that does not identify you
We may disclose aggregate statistics about visitors to the Platform, users and sales in order to describe our services to prospective partners, investors, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.
We will not disclose, sell or rent your personal information to any third party unless you have consented to this first. If you do consent but later change your mind, you may contact us, and we will cease any such activity. However, in the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.
We may also disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the Platform or the rights, property or personal safety of any person.
All medical and other health information collected and supplied to Doctor Care Anywhere will be treated as strictly confidential and all such data will be held strictly in accordance with, and as long as required, under UK regulatory codes of practice on records management and data privacy laws.
How long we keep your medical data: All health records are retained in digital form by our subsidiary company, Doctor Care Anywhere, in a secure and encrypted environment and are confidentially stored in accordance with the retention periods set out in the NHS code of practice on records management, which may be updated from time-to-time. A copy of the code can be found here. We also maintain our own internal Data Retention Policy, on which our staff are trained, which is regularly reviewed to ensure compliance with industry best practices.
What we do with consultation notes:
Audio and video records: as agreed in our contract with you, Doctor Care Anywhere will make audio and video recordings of your Appointment for training, quality, clinical governance and account management purposes which will be treated as confidential and will be held safely and securely and strictly in accordance with, and as long as required, under UK regulatory codes of practice on records management. These recordings will not be made available to any other party without your prior written consent.
Sharing information with GPs: Whilst in certain circumstances we may strongly encourage you to inform your regular in-person GP of any health concerns you may have discussed with your doctor, we will not share information with your regular GP unless we have your express permission or there is an overriding public interest in disclosing the information without your consent. This is in accordance with the General Medical Council’s guidance which may from time-to-time change. This guidance can be found here.
Security and encryption: Doctor Care Anywhere runs in a HTTPS secure mode - and encrypts all audio, video and text information shared during your consultation. There are clear procedures in place to ensure paper and computer systems and databases are protected against unauthorised disclosure, use, loss and damage. Nevertheless, electronic transmissions sent via the internet are never completely private or secure and there is a risk, therefore, that any such electronic communications sent may be intercepted and potentially read by others. You should ensure that any computer or telephone you use to access your online patient record is suitably protected from potential interception.
Doctor Care Anywhere is ISO27001:2013 Certified (Information Security).
When you visit the Website, we may automatically collect additional information about you, such as the type of internet browser you use, the Website from which you have come to the Website and your IP address (the unique address which identifies your computer on the internet) which is automatically recognised by our web server. You cannot be identified from this information and it is only used to assist us in providing an effective service on the Website and to collect broad demographic information for aggregate use.
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
Cookies are pieces of information that include a unique reference code that a website transfers to your device to store and sometimes track information about you. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Website and will last for longer.
All cookies used on our Website are set by us.
Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the Website.
Our cookies will be used for:
Performance and measurement
We have a legitimate interest in using any personal information collected through performance and measurement cookies, so that we can constantly improve our Platform and our services.
We place great importance on the security of all personally identifiable information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it from occurring.
You should bear in mind that submission of information over the internet is never entirely secure and whilst we take appropriate technical and organisational measures to safeguard the personal information you provide to use, we cannot guarantee the security of information you submit via the Platform whilst it is in transit over the internet and any such submission is at your own risk.
You should always close your browser when you have finished your user session to help ensure others do not access your personal information, particularly if you use a shared computer or a computer in a public place.
You have a legal right to access the personal information we hold about you at any time.
You also have a right to ask us to: update and correct any out-of-date information or errors in that information free of charge; object to our use of your personal information for certain purposes; erase your personal information; and transfer to you or (where technically possible) another organisation a copy of the personal information about you that has been provided to us.
Where we are processing your personal data on the basis of consent, You may withdraw your consent for Doctor Care Anywhere to use your personal data as set above at any time by contacting Doctor Care Anywhere using the details below, and subject to the regulatory and legal requirements for Doctor Care Anywhere to retain certain information on your medical history and your doctor consultation notes, you can withdraw your consent to our use of any of your personal information at any time, including any data sharing, using the settings in your Doctor Care Anywhere profile or by calling +44 (0)330 088 4980 or emailing email@example.com.
You also have the right to lodge a complaint at any time about our treatment of your personal information with a relevant supervisory authority (including, the Information Commissioner's Office in the UK).
The different ways to contact the ICO’s office can be found at https://ico.org.uk/global/contact-us/
Automated Decision-Making and Profiling
In the event that Doctor Care Anywhere use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Doctor Care Anywhere.
The right described above does not apply in the following circumstances:
Where Doctor Care Anywhere uses your personal data for profiling purposes, the following shall apply:
Doctor Care Anywhere,
Second Floor, Harmsworth House,
13-15 Bouverie Street,
London, EC4Y 8DP
You can also contact Liam Adamcsik, our Data Protection Officer by emailing firstname.lastname@example.org