Data Privacy Notice for Private Clients
ICO Registration Bluebird Medical Ltd ZA447597
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”). We’ve outlined the key terms here for you.
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person Categories of data: Personal data and special categories of personal data
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified - in particular - by reference to an identifier (as explained in Article 6 of GDPR). For example, name, address or phone number. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
Bluebird Medical Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our Data Protection Officer is Faisal Khan. Our contact details are:
3. The purpose(s) of processing your personal data
Below is a list of the personal data we may request in the course of your consultation and subsequent visits. Not all of it may be requested We use your personal data for the following purposes:
For your appointment bookings:
Recording your booking on our private online appointment system
Recording your email address to respond to queries and/or to contact you about your appointment
Recording your telephone no. to contact you about your appointment
Recording your email address for any clinic updates
For your medical notes:
Recording your name, date of birth, sex and age
Recording your response to whether you are using your legal name or not
Recording your personal contact details and emergency contact details
Recording your GP contact details
Recording your responses to status of Diabetes/ Hepatitis A, B & C/ Immune System Deficiency/Arthritis/Stroke/Cancer
Recording your responses to prior history of injury or illness
Recording your stated medications and known allergies
Recording your stated medical conditions and prior medical/surgical history
Recording your responses to a history of treatment with other medical professionals for the complaint you are presenting with
Recording additional responses to supplemental questions as required such as travel outside the EU, nature of occupation and types of leisure or professional sporting activities
Additionally - for children under 18:
Recording the name of the child’s school for infection monitoring purposes
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Identifying Data: name, email address, telephone number
Medical & Health: physical health, disabilities, family or individual health history (such as diabetes), health records
5. What is our legal basis for processing your personal data?
Under Article 6 of the GDPR our lawful basis for processing your general personal data:
Article 6 (1) (a): The data subject has given consent to the processing of his or her personal data for one or more specific purposes; (This is the GDPR consent form completed by new patients)
Article 6 (1) (d): Processing necessary to protect the vital interests of a data subject or of another natural person
Article 6 (1)(f): Processing is necessary for the purposes of the legitimate interests pursued by the controller More information on lawful processing can be found on the ICO website.
Under Article 9 of the GDPR our lawful basis for processing special category data:
Article 9 (2) (h): Processing 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
6. Sharing your personal data
Your personal data will be treated as strictly confidential and will be shared only with parties in conjunction with your health or personal needs such as your GP or medical insurance company.
7. How long do we keep your personal data?
We keep your personal data for as long as you remain in our care and no longer than reasonably necessary for a period of 7 years in order to conform to ICO data protection.
8. Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will mean that we would not be able to provide any healthcare supplies, treatments or services to yourself. We require your personal data as it is a statutory requirement necessary to enter into a contract, that involves the recording of your medical pathway onto medical notes.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of the personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
[The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data];
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
You may exercise any of the rights described in this section by sending an email to firstname.lastname@example.org.. Please note we will ask you to verify your identity before taking any further action on your request: if we cannot identify you we cannot act on your request. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive). You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
10. Transfer of Data Abroad
We do not store or transfer personal data outside the EEA
11. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
13. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Officer at email@example.com. If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
Cookies: For some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences, connection stability, monitoring performance of our services and generally providing and improving our Services. If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org . Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.
Clear Gifs: We and certain Third-Party Services may employ a software technology called “clear gifs” (a.k.a. Web Beacons/Web Bugs), which enables them and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, however are not stored on your device, but instead embedded within our Services.
Flash and HTML5: We and certain Third Party Services may also employ certain tracking technologies known as “Flash cookies” and “HTML5”, which are mainly used for advertising purposes. Various browsers may offer their own management tools for removing or blocking such technologies.
Behavioural Targeting & Re-Targeting: Certain Third-Party Services may manage our advertising on other websites. Such parties may use certain tracking technologies to collect certain information about your activities on the Services and different third-party Services to provide you with targeted advertising based on your interests and preferences. You may opt-out of receiving targeted ads from certain advertisers and ad networks by visiting YourChoicesOnline.eu. Please note this does not opt you out of receiving all advertising and that your opt-out will only be in relation to the specific advertising. You will continue to receive advertising for which you have not opted out.
“Do Not Track” Signals: Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application