Privacy Policy

INTRODUCTION

HealthSteer Limited (“We”) are committed to protecting and respecting your privacy.

This Privacy Policy (together with our Terms https://healthsteer.co.uk/terms-conditions/ and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This Privacy Policy will also tell you about your privacy rights and how the law protects you. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Our website and the platform through which we provide our services (“Platform”) are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other Privacy Policy or fair processing policy we may provide on specific occasions when we are collecting, or processing, personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Capitalised terms in this Privacy Policy shall have the meanings given to them in the Terms unless they are separately defined in this Privacy Policy.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time.  If we make any such amendments, we will notify you by email when you next log on to the platform.  Your continued use of the Platform will constitute your deemed acceptance of such amendments. This Privacy Policy was most recently updated on Friday 20th March 2020.

CONTROLLER

The data controller of your data is HealthSteer Limited of AK Advisory, Cambrai Court, Stratford Road, Hall Green, Birmingham, B28 9AA, United Kingdom.

WE MAY COLLECT AND PROCESS THE FOLLOWING 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 has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • information (such as your name, email address, postal address and telephone number) that you provide by completing forms on the Platform, including if you register to create an account on the Platform, subscribe to any service, upload or submit any material via the Platform, or request any information (“Contact Information”);
  • in connection with an account sign-in facility, your password and log-in details (“Account Details”);
  • details of any transactions made by you through the Platform (“Transaction Information”);
  • communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Platform or its content (“Enquiry Information”);
  • information from surveys that we may, from time to time, run on the Platform for research purposes, if you choose to respond to them (“Survey Responses”);
  • details of your visits to the Platform, the resources you access and any data you download (“Usage Information”);
  • medical information about you and your medical history, illnesses, prescriptions and other medical information which you might discuss with a Doctor as part of your use of the Services made available through the Platform (“Medical Information”).

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when 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 case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

HOW YOUR INFORMATION IS USED

We will use the information you provide in the following ways:

  • We may use your Contact Information, Account Details, Enquiry Information and Medical Information to enable us to provide you with our services and information offered through the Platform and which you request (our lawful basis for doing so is your consent and the relevant condition that we rely on is Article 9(a) of the General Data Protection Regulation (explicit consent));
  • We may use your Contact Information, Account Details, Transaction Information, and Usage Information in order to administer your account with us (our lawful basis for doing so is that this processing is necessary for us to perform our contract with you);
  • We may use your Contact Information and Transaction Information to verify and carry out financial transactions in relation to payments you make online (our lawful basis for doing so is that it necessary for our legitimate interest of processing payments that you owe to us for services provided);
  • We may use your Usage Information to audit the downloading of data from the Platform (our lawful basis for doing so is that it is necessary for our legitimate interest in analysing customers’ use of our services and Platform);
  • We may use your Usage Information and Survey Responses to improve the layout and/or content of the pages of the Platform and customise them for users (our lawful basis for doing so is that it is necessary for our legitimate interest in improving our services and Platform);
  • We may use your Contact Information, Account Details and Usage Information to identify visitors to the Platform (our lawful basis for doing so is that it is necessary for us to perform our contract with you);
  • We may use your Contact Information, Survey Responses and Usage Information to carry out research on our users’ demographics (our lawful basis for doing so is our legitimate interest in informing our business and marketing strategy);
  • We may use your Contact Information to send you information we think you may find useful or which you have requested from us, including information about our products and services or those of carefully selected third parties, provided you have indicated that you do not object to being contacted for these purposes (our lawful basis for doing so is your consent);
  • We may use your Contact Information to allow, with your consent, carefully selected third parties to send you information directly which you may find useful regarding their products and services (our lawful basis for doing so is your consent).

You can tell us not to contact you with information regarding our products and services or those of third parties or to share your details with third parties so that they can send you information regarding their products and services, either at the point such information is collected on the Platform (by checking or un-checking (as directed) the relevant box) or where you do not wish us to continue to use your information in this way by following the unsubscribe instructions on any communications sent to you. You can also exercise the right at any time by contacting us using the contact details at the end of this Privacy Policy.

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

MEDICAL DATA

All information collected and supplied to us will be treated as confidential.

We maintain records of the notes made by Doctors during their Consultations as well as audio and video recordings of the Consultation for clinical governance purposes, in accordance with data processing requirements. These medical records and any personally identifiable information you give to us will be treated as strictly confidential and will not be disclosed without your express permission except under special circumstances, for example in complying with a legal obligation. All medical records are retained in a secure area and are confidentially stored in accordance with the NHS code of practice on records management, which may from time-to-time change, a copy of which can be found here: https://digital.nhs.uk/data-and-information/looking-after-information/data-security-and-information-governance

We generally encourage you to inform your existing GP of any health concerns you may have, but we will not share information with your 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. [http://www.gmc-uk.org/guidance/ethical_guidance/confidentiality_64_66_sharing_information.asp ]

We monitor the use of our Platform for statistical purposes only and to improve the services we provide.

We encrypt all audio/video and text information shared during your Consultation. We have clear procedures in place to ensure paper and computer systems and databases are protected against unauthorised disclosure, use, loss and damage. Nevertheless, electronic transmissions are never completely private or secure and there is a risk, therefore, that any electronic communications sent may be intercepted and potentially read by others. You should, therefore, ensure that any computer or telephone you use to access your online patient record is suitably protected from potential interception.

PAYMENTS

Payments made on the Platform are made through or payment solutions provider, Barclaycard at www.Barclaycard.co.uk.  You will provide your credit/debit card information directly to Barclaycard, who will process payment details and authorising payment using a secure server and encryption.  Information that you provide to Barclaycard is subject to Barclaycard’s own privacy policy and terms and conditions (available at https://www.barclaycard.co.uk/business/terms-of-use), and is not within our control.

ADDITIONAL SERVICES

When you visit the Platform, 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 Platform 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 Platform and to collect broad demographic information for aggregate use.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see [LINK TO YOUR COOKIE POLICY].

INFORMATION SHARING

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 be anonymous and include no personally identifiable information.

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 disclose your personal information to professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services to us.

We may disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or cybercrime or to protect the Platform or the rights, property or personal safety of any person.

WHERE WE STORE YOUR PERSONAL DATA

Information that you supply to us via the Platform is sent to and stored on secure servers located in the EU and or United States.  This is necessary in order to process the information.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent any unauthorised access, loss, misuse or alteration.

INTERNATIONAL TRANSFERS

Whenever we 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 European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine 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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact and Transaction Information) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction 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.
  • Request erasure of your personal data. 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 to processing of 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.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • 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.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to 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. 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.
  • Withdraw consent at any time where we are relying on consent to process your personal data. 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.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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 could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity 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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Right to make a complaint

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

THIRD PARTY LINKS

Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

CONTACT

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to Healthsteer, 112 Main Street, Dickens Heath, Solihull, B90 1UA OR info@healthsteer.co.uk.

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