Premier Clinic Ltd treats the privacy of its customers and website users very seriously and we take appropriate security measures to safeguard your privacy. This policy explains how we protect and manage personal data – “personal data means any information that may be used to identify an individual, including, but not limited to, a first and last name, a home or other physical address and an email address or other contact information, whether at work or home.”
How we obtain your personal data
Information provided by you
You provide us with your personal data either on your personal information form, via an online form or over the telephone. This includes name, address, and date of birth, email address, telephone numbers, emergency contact details and your personal GP details.
We use this information to in order to manage and administer your care/treatment. We may also keep information contained in any correspondence you may have with us by post or by email. We also may record telephone conversations.
We may obtain sensitive medical information directly from you or your GP or other healthcare practitioner in relation to your care/treatment. The subject of this information is subject to your express consent. If we do not receive this consent from you, then we may be unable to offer any care/treatment. The provision of this personal data is essential for us to provide you with the upmost care/treatment. This means that the legal and clinical basis of our holding your personal data is for the performance of a contract.
Information we get from other sources
We only obtain information from third parties if this is permitted by law. We may also use legal public sources to obtain information about you, for example, to verify your identity.
This information (including your name, address, email address, date of birth etc.), as relevant to us, will only be obtained from reputable third-party companies that operate in accordance with the General Data Protection Regulation (GDPR). You will have already submitted your personal data to these companies and specifically given permission to allow them to pass this information to other companies that provide similar services to those we offer.
How we use your personal data
We use your personal data to manage and administer your care/treatment. We also act as a controller and processor in regard to processing of your payments and in regards to insurance claims or requests for assistance made to our company. We undertake at all times to protect your personal data, including any health or financial details, in a manner which is consistent with your practitioners duty of professional confidence and the requirements of the Data Protection Regulation (GDPR) concerning data protection. We will also take reasonable security measures to protect your personal data in storage.
Do we use your personal data for marketing purposes?
Any information that you choose to give us will not be used for marketing purposes by us. We will hold your personal data only for the purposes of your care/treatment.
We will keep information about you confidential and we will only share your information with other persons who are involved in your care/treatment. We will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:
The company co-ordinating your rehabilitation
Your legal representative
Your GP (if requested)
Appointed Medico Legal Expert
The insurance company dealing with your treatment
Employer, if associated with this treatment
Any legal or crime prevention agencies and/or to satisfy any regulatory request (including recognised practitioner bodies) if we have a duty to do so or if the law allows us to do so.
How long do we keep this information about you?
We keep information in line with current legislation for healthcare. These retention periods are in line with the length of time we need to keep your personal information in order to manage your care/treatment or requests for information by another practitioner. These reasons can vary from one piece of information to the next. In all cases our need to use your personal information will be assessed on a regular basis and information which is no longer required will be disposed of.
Data subject rights
Subject access requests
The General Data Protection Regulation (GDPR) grants you (hereinafter referred to as the “data subject”) the right to access particular personal data that we hold about you. This is referred to as a subject access request. We shall respond promptly and certainly within one month from the point of receiving the request and all necessary information from you. Our formal response shall include details of the personal data we hold about you, including the following:
Sources from which we acquired the information;
The purposes for processing information; and
Persons or entities with whom we are sharing the information.
Right to rectification
You, the data subject, shall have the right to obtain from us, without undue delay, the rectification of inaccurate personal data we hold concerning you. Taking into account the purposes of the processing, you, the data subject, shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure
You, the data subject, shall have the right to obtain from us erasure of personal data concerning you without delay.
Right to restriction of processing
Subject to exemptions, you, the data subject, shall have the right to obtain from us restriction of processing where one of the following applies:
The accuracy of the personal data is contested by you, the data subject, and is restricted until the accuracy of the data is validated;
The processing is unlawful and you, the data subject, oppose the erasure of the personal data and instead request the restriction in its use;
We no longer need the personal data for the purpose of processing, but it is required by you, the data subject, for the establishment, exercise of defence of legal claims;
You, the data subject, have objected to processing of your personal data pending the verification of whether there are legitimate grounds for us to override these objections.
Notification obligation regarding rectification or erasure of personal data or restriction of processin
We shall communicate any rectification or erasure of personal data or restriction of processing as described above to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort. We shall provide you, the data subject, with information about those recipients if you request it.
Right to data portability
You, the data subject, shall have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit this data to another controller, without hindrance from us.
Right to object
You, the data subject, shall have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you, including any personal profiling; unless this relates to processing that is necessary for the performance of a task carried out in the public interest or an exercise of official authority vested in us. We shall no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of you, the data subject, or for the establishment, exercise or defence of legal claims.
Right to not be subject to decisions based solely on automated processing
We do not carry out any automated processing, which may lead to an automated decision based on your personal data.
Invoking your rights
If you would like to invoke any of the above data subject rights with us, please write to the Data Protection Officer at Premier Clinic Ltd, 11 Cunningham Court, Lions Drive, Shadsworth Business Park, Blackburn BB1 2QS.
Accuracy of information
In order to provide the highest level of customer service possible, we need to keep accurate personal data about you. We take reasonable steps to ensure accuracy of any personal data or sensitive information we obtain. We ensure that the source of any personal data or sensitive information is clear and we carefully consider any challenges to the accuracy of the information. We also consider when it is necessary to update the information, such as name or address changes and you can help us by informing us of these changes when they occur.
Questions and queries
If you have a complaint
If you have a complaint regarding the use of your personal data or sensitive information then please contact us by writing to the Data Protection Officer at 11 Cunningham Court, Lions Drive, Shadsworth Business Park, Blackburn BB1 2QS and we will do our best to help you.
If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 5456745 or 0303 123 1113. You also have the right to judicial remedy against any legally binding decision of the ICO where you consider that your rights under this regulation have been infringed as a result of the processing of your personal data. You have the right to appoint a third party to lodge your complaint on your behalf and exercise your right to seek compensation.