Fair Processing Notice
1: What is the purpose of this document?
Ulster Independent Clinic (the “Clinic”) is committed to protecting the privacy and security of your personal information.
This fair processing notice describes how we collect and use personal information about you during and after your treatment, in accordance with the General Data Protection Regulation (GDPR).
Ulster Independent Clinic is a “data controller” for any of your personal data it holds. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
The Consultant/s providing your private medical treatment at the Clinic are joint “data controllers” in relation to your personal data which they hold for the provision of your private medical care.
This notice is for all patients of the Clinic. We reserve the right to update this privacy notice at any time. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this fair processing notice or how we handle your personal information, please contact the DPO, Company Secretary at 028 9066 1212. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
2: Data Protecting Principles
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
3: The kind of information we hold 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 has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection.
We will collect, store, and use certain personal information about you which includes:
Non-sensitive personal data:
- Personal contact details such as name, title, addresses, telephone numbers and personal email addresses.
- Personal details such as date of birth, gender, marital status, photographic ID and dependants.
- Next of kin and emergency contact information.
- Medical insurance details, including membership numbers and compensation history.
- Payment information, including payment methods, bank/card details and billing address.
Sensitive personal data:
- Details of your health comprising records of treatments and care received, including notes and reports about your health from your GP.
- Results of x-rays, blood tests and other relevant medical examinations.
4: How is your personal information collected?
We collect personal information about patients through the referral process, either directly from the patient or sometimes from the patient’s GP, consultant or other healthcare provider by a referral letter, medical insurance provider or in some instances from a legal representative.
The Clinic will collect additional personal information in the course of providing your private medical care.
5: How we will use your non-sensitive personal data
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform an agreement we have entered into with you.
2. Where we need to comply with a legal obligation.
3. 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
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest.
Situations in which we will use your personal information
We need all the categories of data in the list above primarily to allow us to provide any agreed healthcare services and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
- Administering our healthcare services as agreed.
- To help inform the decisions your consultant and healthcare team make about your treatment.
- To ensure that your treatment is safe and effective.
- To work effectively with the joint data controllers who may be involved in your care.
- Complying with health and safety obligations.
- To prevent fraud.
- Where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests).
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6: How we use particularly sensitive personal data
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate security and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:
1. Primarily for carrying out our legal obligations in connection with your medical care for the purpose of preventative or occupational medicine, medical diagnosis, provision of health or social care or treatment or the management of health and social care systems and services, carried out under the supervision of a health professional or another person who owes a duty of confidentiality under law (being your consultant/s).
2. In limited circumstances, with your explicit written consent.
3. Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of your medical care. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
7: Data Sharing
We may have to share your data.
We require third parties to respect the security of your data and to treat it in accordance with the law.
If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will only share your non-sensitive personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so, for example with your medical insurance provider, legal representative or third party making payment on your behalf.
How secure is my information with third-party service providers?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other data controllers?
We will only share your personal information (including your sensitive personal data) with the healthcare professionals and Consultant/s providing your private medical care at the Clinic for the purpose of fulfilling our legal obligations to you, namely for the purposes of preventative or occupational medicine, medical diagnosis, provision of health or social care or treatment or the management of health and social care systems and services, carried out under the supervision of the consultant/s who owe a duty of confidentiality under law.
8: Rights of access, correction, erasure, and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your treatment.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our DPO.
9: Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our DPO. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
