This policy is applicable to all areas processing patient records containing medical data.
This policy applies to all staff, contract medical staff and contractors within the scope, with ultimate oversite by the Information Security Risk & Compliance Manager under approval from the Managing Director.
Business details of Data Processor/Controller
Check4Cancer Ltd is a company registered in England and Wales under company number 8866941 and with a registered office at 1 The Mill, Copley Hill Business Park, Cambridge Road, Cambridge, CB22 3GN (“Check4Cancer”) and includes the following trading names, BOWELHEALTH UK, BREASTHEALTH UK, GENEHEALTH UK, GYNAEHEALTH UK, LUNGHEALTH UK, PROSTATEHEALTH UK, SKINHEALTH UK.
Data Controller or Processor
If Check4Cancer Ltd is provided with personal information under contract via a third party, it is likely we will be acting as a Data Processor or acting as Joint Controllers. If this is not the case, then Check4Cancer will be acting at the Data Controller.
Collecting personal information
We may collect, store and use the following kinds of personal information:
- information about your computer and about your visits to and use of our websites including your IP address, search terms, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths;
- information that you provide to us when registering with our websites including your email address & contact details;
- information that you provide when completing your profile on our websites including your name, address, gender, date of birth, relationship status, health records, employment records & payment details;
- information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters;
- information that you provide to us when using the services on our websites, or that is generated in the course of the services we provide including appointment times, medical data, doctors contact details etc.;
- information relating to any purchase of services or any other transactions that you enter into through our websites, online chat or directly through our contact centre including your name, address, telephone number, email address and card details;
- information that you provide when responding to customer service feedback or complaints.;
- information contained in or relating to any communication that you send to us or send through our websites, email or telephone calls (call recording) including the communication content and metadata associated with the communication; and
- payment data when purchasing services online or over the phone.
- medical information related to the results of any screening diagnostic service we provide at your request.
- we may also record phone calls for the purposes of staff training, mitigation of disputes and the collection of consent from data subjects.
Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
Using personal information
Personal information submitted to us through our websites, phone calls, emails or in person will be used for the purposes specified in this policy.
We may use your personal information to:
- administer our websites and business;
- personalise our websites for you;
- enable your use of our services;
- send you information;
- process payments;
- send statements, invoices and payment reminders to you, and collect payments from you;
- send you non-marketing commercial communications;
- send you email notifications that you have specifically requested that form part of the service;
- send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
- send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
- provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
- deal with enquiries and complaints;
- keep our websites secure and prevent fraud; and
- verify compliance with the terms and conditions governing the use of our websites (including monitoring private messages sent through our websites private messaging service).
- we may contact you for the purposes of customer feedback and marketing testimonials. If you object to this processing then please do let us know. We do not currently pass any of your details to external customer review services. If this changes in future we will seek your consent prior to sharing your details.
- we will not, without your expressed consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
- all our websites financial transactions are handled through our payment services provider, Sage Pay or PayPal. We will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our websites, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
- data supplied by you for the purposes of our medical services is stored in our data centre currently hosted with Rackspace. Details of Rackspace security standards can be found here https://www.rackspace.com/en-gb/managed-security-services/privacy-data-protection
- we do not use any automated decision-making processes or profile of you based on the data you provide, with the limited exception of processing family data related to your health profile.
Disclosing personal information
We may disclose your personal information to any of our employees, officers, insurers, professional advisers, consultants, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy and in the delivery of our services.
We also share your data with Health Authorities (i.e. Public Health England & National Disease Registration Service) for the purposes of knowledge sharing and improving services to patients. More information can be found here https://www.gov.uk/guidance/phe-data-and-analysis-tools#cancer
We may disclose your personal information to any member of our group of companies. This means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes set out in this policy.
We may disclose your personal information:
- to the extent that we are required to do so by law;
- in connection with any ongoing or prospective legal proceedings;
- in order to establish, exercise or defend our legal rights including providing information to others for the purposes of fraud prevention and reducing credit risk;
- to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
- to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
- except as provided in this policy, we will not provide your personal information to third parties.
International data transfers
All data is stored in our datacentres within the EEA. All external parties with whom we may share data are based in the EEA. Any data we collect from data subjects outside the EEA may be stored & processed within the EEA and the country of residence of the data subject and where there is a legal premise to do so.
Your explicit consent to the transfers of personal information described in this section will be recorded if applicable.
Retaining personal information
This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
Without prejudice to other obligations set out in this contract or legal obligations, we will usually delete personal data falling within the categories set out below at the date/time set out below:
- personal & sensitive data of a medical nature will be deleted 30 years after patient discharge or last seen;
- when you ask us to erase your data compliant with GDPR Article 17; Notwithstanding the other provisions of this policy, we will retain documents & records containing personal data:
- to the extent that we are required to do so by law;
- if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
There is no statutory period defined in legislation, so our retention period is based on recommendations from Information Governance Alliance Records Management Code of Practice for Health and Social Care 2016.
Security of personal information
We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
All communications via our websites, payment transactions, electronic documents and database records will be protected by encryption technology.
You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You are responsible for keeping the password you use for accessing our websites confidential; we will not ask you for your password (except during authenticating access to electronic systems).
We may update this policy from time to time by publishing a new version on our websites.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We may notify you of any changes to this policy by email.
Please let us know if the personal information that we hold about you needs to be corrected or updated.
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
- there is no payment required; and
- the supply of appropriate evidence of your identity for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address.
- We may withhold personal information that you request to the extent permitted by law.
- you may instruct us at any time not to process your personal information as permitted by law.
- you can instruct us to erase your data, compliant to GDPR Article 17.
- you have the right to lodge a complaint with the Data Protection Authority, if you consider your rights have been breached in anyway.
Note: The UK Data Protection Authority can be contacted on the following link: https://ico.org.uk/global/contact-us/
Third party websites
Our websites include hyperlinks to, and details of, third party websites.
We have no control over, and are not responsible for, the privacy policies and practices of third parties if you register with them independently.
Cookies & Trackers
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
We use both session and persistent cookies on our websites.
The purposes for which they are used, are set out below:
- Category 2 – Performance Cookies
These are cookies we use to gather browsing data anonymously to enable us to monitor the effectiveness of our websites. The information gathered is not used for any other purpose.
- Category 3 – Functionality Cookies
These are cookies we use to track your session when you log into our site. This cookie stores a unique identity reference for the browser, so that when you log in / verify your email during a survey, your session can be protected / linked only to you NONE of the cookies on this site contain or pass any personal, confidential or financial information or any other information that could be used to identify individual visitors or customers purchasing from our websites.
Most browsers allow you to refuse to accept cookies; for example:
- in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
- in Firefox (version 47) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
- in Chrome (version 52), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
Note: Blocking all cookies will have a negative impact upon the usability of many websites and you may not be able to use all the features on the websites.
You can delete cookies already stored on your computer; for example:
- in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internetexplorer/delete-manage-cookies#ie=ie-11);
- in Firefox (version 47), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
- in Chrome (version 52), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.
Note: Deleting cookies will have a negative impact on the usability of many websites.
Data protection registration
We are registered as a data controller with the UK Information Commissioner’s Office & Care Quality Commission.
Our data protection registration can be found here: https://ico.org.uk/ESDWebPages/Entry/Z1201347
Our CQC registration can be found here: https://www.cqc.org.uk/location/1-1794403643?referer-widget4
Our websites and call centre are owned and operated by Check4Cancer Limited.
We are registered in England and Wales under registration number 8866941, and our registered office is at 1 The Mill, Copley Hill Business Park, Cambridge Road, Cambridge, CB22 3GN.
Our principal place of business is at 1 The Mill, Copley Hill Business Park, Cambridge Road, Cambridge, CB22 3GN.
You can contact us:
by post, using the postal address given above;
using our website contact forms;
by telephone, on the contact number published on our websites; or
by email, using the email address published on our websites.
by online live chat
Or you can contact our Information Security Risk & Compliance Manager directly by email at [email protected]; please note consent is granted for genuine customer enquiries, consent for any other purpose is NOT granted.