This Privacy Notice is designed to help you understand everything you need to know about the what, why and how’s of our data gathering and processing operations, and what your legal rights are.
We hope you’ll take some time to read this document; we’ve tried to keep it all as simple as possible and we will keep you informed if there are any changes to the way we process your personal data in the future, before making them.
Health and Care Innovations LLP takes its responsibility of protecting your data very seriously and we do advise you get to know our practices – If there’s anything in this policy you don’t understand or if you want to ask any questions, please feel free to contact us using any of the details below.
Who are we?
We are Health and Care Innovations LLP, registered in England and Wales at Hengrave House, Torbay Hospital, Newton Road, Torquay, England, TQ2 7AA (Reg No OC407372). In this document Health and Care Innovations LLP will sometimes be referred to as “we” or “HCI”.
What kind of personal data might we ask you to provide?
Health and Care Innovations LLP will only ever ask for personal data if it is required for a specific purpose; with that in mind we have created a full list of all the kinds of personal data that we may ask you to provide in order to achieve those purposes. The kinds of personal data we may collect are:
Data subjects/Data categories:
Actors/Script writers: Name, address, telephone, email, bank account details, NI Number
Clinicians: Hospital contact, name, address, telephone, email, subscriber name, telephone, email,
Patient/App Users: Name, address, telephone, email, patient data, medical data (including appointment information, medication information and health score information)
Professional or principal contact: Name, address, telephone, email
Applicants: Name, address, telephone, email.
Why do we collect personal data?
We will use personal data firstly to fulfil any contractual obligations that exist between us and yourself; where we request personal data be provided to meet the terms of any such contract you will be required to provide the relevant personal data or we will not be able to deliver the goods and/or services you want. In such cases the lawful basis of us processing the personal data is that it is necessary for the performance of a contract.
We may also process your personal data in accordance with our legitimate business interests; this is on the considered measure that we need the personal data to achieve the various purposes and that it could be reasonable for an individual to expect their data to be used for those purposes.
Our data processing activities conducted on the lawful basis of ‘legitimate interests’ are:-
To provide you with goods and services you are looking for
To inform you of other goods and services we provide, or offers that may interest you (direct marketing)
To send notifications on subjects you have subscribed to, or otherwise asked us to keep you informed of
To allow us to understand the scale and range of our customer base; for statistical analysis and market research
To recognise when customers re-engage with our services
To allow us to support and maintain our products in active service
Improve website so content is delivered more efficiently
To enhance the security measures in place that protect data we are responsible for
To protect the company’s assets
To use the data that remains within the app, health care professionals and the company itself, under Article 9 Health or Social Care, allowing processing of data for the following reasons:
- Archiving, researching or statistics with a basis in law to use the data to both archive and use it to further internal mechanisms, including the selling of data externally
To use the data that remains within the app, health care professionals and the company itself, under Article 9 (2)(h), Health or Social Care, allowing processing of data for the following reasons:
- Preventive or occupational medicine;
- The assessment of an employee’s working capacity;
- Medical diagnosis;
- The provision of health care or treatment;
- The provision of social care (this is likely to include social work, personal care and social support services); or
- The management of health care systems or services or social care systems or services
We may also process your personal data in order for Health and Care Innovations LLP to comply with our various legal obligations; this might include:
Providing for financial commitments between us and yourself, or to relevant financial authorities
Complying with industry regulatory requirements and any self-regulatory schemes
Cooperating with relevant authorities for reporting criminal activity, or to detect and prevent fraud
To investigate any insurance claims, claims of unfair dismissal, claims of any kind of harassment or of discrimination, or any other claim whereby we may have to defend ourselves.
Where we have received your consent to do so we will process your personal data.
You may withdraw your consent for us to process your personal data for these purposes at any time; after a withdrawal of consent request is received we may contact you to verify the request.
Withdrawing your consent for us to process your personal data will not affect the lawfulness of the processing beforehand.
Where we process special categories of personal data, other than where we have your consent to do so we shall be processing this data on one or more of the following lawful basis:
It is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems or pursuant to contract with a health professional
It is necessary for reasons of public interest in the area of public health such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices.
Where did we obtain your personal data?
For the majority of our app services, other than collecting data directly from you;
We source personal data from some publicly accessible sources such as:
Trust/organisation web sites, LinkedIn, Twitter
We may gather personal data from sources including:
Technical sources that gather data over time when you visit our online platforms
From third party organisations, which can mean your personal data has been provided directly by another company for a specific purpose, or where you may have accessed our platforms through a third party online service
Local or national authorities provided for specific purposes
Who might we share your information with?
We may share your personal data with the other members of our group of companies, which includes any subsidiary or the holding company (each as defined by the Companies Act 2006) of Health and Care Innovations LLP.
In order to achieve the above stated purposes for which we process your personal data, we may need to share your personal data with various third-party service providers who act as data processors, such as marketing companies, system infrastructure companies, data protection companies, database companies and similar.
We may share your personal data with third party organisations acting as data controllers or with specific individuals, groups or other organisations who act as neither data controllers nor data processors, but only where we are either legally require to do so by law or where doing so is necessary to achieve the intended stated purpose of processing the data
In the event that we sell or reorganise our business, or if otherwise required by law or by an authorised regulator, we may transfer your personal data as a part of the general business data to the relevant parties.
Where is my data going to be stored?
Whenever Health and Care Innovations LLP transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it 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 UK and/or European Commission.
- Where we use certain service providers, we may use specific contracts such as those approved by the European Commission.
How long will we keep your data for?
We will keep your personal data only for as long as required in order to achieve the purposes for which it was gathered, in line with this privacy notice.
For determining when personal data should be erased we shall take into consideration the amount of and sensitivity of the personal data we have, the amount of harm that could be caused by a data breach, the benefits of the purposes the data is being used for and any legal requirements that we are bound to.
You may request that we erase your personal data an anytime, though in cases where there is a remaining relevant or legal reason why we are required to keep the data we may opt to restrict the amount of processing being conducted to what is absolute necessary in line with your legal rights in order to minimise the impact the processing will have.
Cookies and similar technology
When you visit our sites or when you use our sites, apps and elearning platforms, we may collect personal data from you automatically using cookies or similar technology.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages of our sites, apps and elearning platforms are being used. This helps us analyse data about web page traffic and improve our sites, apps and elearning platforms in order to tailor them to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. If you complete a survey within our site, the data is anonymised. The survey provider uses third party cookies and the experience you receive will be based upon your settings.
Overall, cookies help us provide you with a better site, app or elearning platform, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
How do I disable cookies?
If you want to disable cookies you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.
Further details on how to disable cookies for the most popular browsers are set out below:
- For Microsoft Internet Explorer: Choose the menu “tools” then “Internet Options” Click on the “privacy” tab Select the setting the appropriate setting
- For Google Chrome: Choose Settings> Advanced Under "Privacy and security," click “Content settings”. Click “Cookies”
- For Safari: Choose Preferences > Privacy Click on “Remove all Website Data”
- For Mozilla firefox: Choose the menu “tools” then “Options” Click on the icon “privacy” Find the menu “cookie” and select the relevant options
- For Opera 6.0 and further: Choose the menu Files”> “Preferences” Privacy
Your Rights, Our Responsibility
There are several rights granted to you immediately upon providing us with your personal information; some of these are mentioned above. We’d like you to know that at Health and Care Innovations LLP we take your rights as a Natural Person seriously and will always conduct ourselves in a way that is considerate of our responsibility to serve your legal rights.
You have the Right of Access
This grants you the right to confirm whether or not your personal data is being processed, and to be provided with relevant details of what those processing operations are and what personal data of yours is being processed.
If you would like access to the personal data we have about you, we ask that you contact us by using any of the details below.
The Right to Rectification
This one is fairly straight forward; if you notice that the data we have about you is inaccurate or incomplete, you may request we rectify the mistake. We will make every effort to respond to requests of this type immediately.
The Right to Objection
The right to object is a basic freedom all democracies enjoy. If you wish to object to the way we use, or have used, your personal data you may do so freely.
The Right to Portability
This is a legal right afforded to you that states we must pass on all of the details you have provided to us in a machine-readable format, either to your or to another provider of your choosing.
Right to Opt-Out of NHS Data
Where NHS data is concerned, since May 2018, you are allowed to Opt Out of any of your data being used for research purpose. With future apps being developed, HCI may start to collect NHS data. Information about your health and care helps the NHS to improve your individual care, speed up diagnosis, plan your local services and research new treatments.
In May 2018, the strict rules about how this data can and cannot be used were strengthened. You can choose whether your confidential patient information is used for research and planning.
To find out more visit: https://www.nhs.uk/your-nhs-data-matters/
The Right to Complain
We will always try to maintain the highest standards and encourage the confidence our customers have in us as an organisation. In order that we can achieve this we do request that any complaints be first brought to our attention so we can properly investigate matters; if however you would like to complain about Health and Care Innovations LLP to a supervisory authority you may do so by contacting the Information Commissioners Office on 0303 123 1113, or anyone of the other reporting methods listed on their website – https://ico.org.uk/concerns
Our Data Protection Officer
Thorn Business Park
Our contact details
If you wish to get in touch with Health and Care Innovations LLP please do so with any of the following contact details:
Health and Care Innovations LLP
Torbay and South Devon NHS Foundation Trust
Torquay TQ2 7AA
T: 01626 833937