Last updated: 25 October 2018
Who I am?
Kara Heelan is a consultant dermatologist who provides dermatology consultations and treatments. The DPO (Data Protection Officer) – Dr Kara Heelan
What is a privacy notice?
This notice also explains what rights you have to control how we use your information.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), who is the supervisory authority for data protection issues in the UK (phone: 0303 123 1113 or at www.ico.org.uk/concerns).
Why and how we collect information about you?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity of the individual has been removed (anonymous data). We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases, we need you to provide your personal data so we can provide care and treatment and receive payment for these services.
We may process personal information about you which will be used to support delivery of appropriate care and treatment. This is to support the provision of high-quality care. These records may include but are not limited to:
- Your name, address and contact details, including email address and home and mobile telephone numbers, date of birth and gender
- Your previous and current medical health records whether provided by HCA UK or other third parties
- The terms and conditions of your contract with us for the provision of healthcare and related services
- Your financial information (your bank account and national insurance number) if you are a ‘self pay’patient or the financial information of the company or individual who is responsible for the payment of invoices/bills relating to your care (e.g. insurer or sponsor)
- Information about your marital status, next of kin, dependents nominated and/or emergency contacts
- Information about your nationality and entitlement to treatment in the UK
- Information about medical or health conditions, including whether or not you have a disability for which the organisation needs to make reasonable adjustments
- Information about medical or health conditions of your family
- Information received in response to any surveys or, complaints claims
- Equal opportunity monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief
- Contact we have had, such as appointments and home visits
- Details and records of treatment and care, including notes and reports about your health
- Results of x-rays, blood tests, etc.
We may also process sensitive personal data or special category personal data such as sexuality, race, your religion or beliefs, and whether you have a disability, allergies or health conditions. It is important for us to have a complete picture, as this information assists staff involved in your care to deliver and provide improved care, deliver appropriate treatment and care plans, to meet your needs.
Where we need to collect personal data by law, or under the terms of a contract that we have with you, and you fail to provide that data where requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this circumstance, we may have to cancel the provision of our services with you, but we will notify you if this is the case.
We use different methods to collect personal data from and about you including through:
You may provide us with your personal data by filling in forms (including at the hospital or clinic where you are seen), discussing matters with us and by otherwise corresponding with us by post, phone, email or otherwise.
Third parties or publicly available sources:
We may receive personal data about you from various third parties, including via referral from your GP or healthcare professional or the hospital provider you have received treatment or services from.
How we use your personal data
We will only use your personal data when law allows us to. Most commonly, we will use your personal data in the following circumstances:
- With your consent and please note that you have the right to withdraw your consent at any time by contacting us firstname.lastname@example.org
- Where we need to perform a contract we are about to enter into, or have entered into, with you.
- 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.
- Where it is necessary for the purposes of: preventative or occupational medicine; medical diagnosis; the provision of health care or treatment; the provision of social care; and/or the management of health care systems or services or social care systems or services.
- To help inform decisions that we make about your care.
- To ensure that your treatment is safe and effective.
- To work effectively with other organisations who may be involved in your care.
- To support the health of the general public.
- To ensure our services can meet future needs.
- To review care provided to ensure it is of the highest standard possible.
- To train healthcare professionals.
- For research and audit.
- To prepare statistics on private healthcare performance measures.
It helps you because;
- Accurate and up-to-date information assists us in providing you with the best possible care.
- If you see another healthcare professional, specialist, they can readily access the information they need to provide you with the best possible care.
- Where possible, when using information to inform future services and provision, non-identifiable information will be used.
We will only use your personal data for the purposes set out above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like us to explain how the new processing is compatible, please contact us email@example.com. If we need to use your personal data for an unrelated purpose, we will notify you and explain our legal basis for doing so. Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
How information is retained and kept safe?
Information is retained in secure electronic and paper records and access is restricted to only those who need to know.
It is important that information is kept safe and secure, to protect your confidentiality. There are a number of ways in which your privacy is shielded; by removing your identifying information, using an independent review process, adhering to strict contractual conditions and ensuring strict sharing or processing agreements are in place.
Technology allows us to protect information in a number of ways, in the main by restricting access. Our guiding principle is that we are holding your information in the strictest confidence. We have put in place procedures to deal with any suspected personal data breach and we will notify you and any applicable regulator of a breach where we are legally required to do so.
We can only keep your personal data for as long as necessary for the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. The precise length of time we hold your personal data for varies depending on the individual circumstances, but in determining 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. We regularly review our retention periods to ensure that we are not keeping your data for longer than necessary. However, this may include indefinite retention if deemed important for the provision of high-quality long-term healthcare.
Who will the information be shared with?
To provide best care possible, sometimes we will need to share information about you with others. We may share your information with a range of Health and Social Care organisations and regulatory bodies. You may be contacted by any one of these organisations for a specific reason; they will have a duty to tell you why they have contacted you. Information sharing is governed by specific rules and law.
Access: you may request access to your personal data, which enables you to receive a copy of the personal data that we hold about you and to check to see if we are processing it lawfully.
Transfer: you may request that we transfer your personal data to you or 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. Please 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 with you.
Rectification: you may request rectification 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.
Erasure: you may request erasure of the personal data that we hold about you. 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: you may object to how we are processing 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.
Restriction: you may request that we restrict how we process 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.
Withdrawal of Consent: where we have relied on your consent to process your personal data you will have the right to withdraw your consent at any time. 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. 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 identify 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.
Contacting us about your information
By email at: firstname.lastname@example.org
Or write to us at: Dr Kara Heelan, Chelsea Outpatients Centre, 280 Kings Road, London SW3 5AW