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Current data privacy legislation requires data controllers to provide data subjects with information relating to the processing of their personal data under GDPR Article 12.
To provide data subjects with transparency about the information we collect and process, enabling them to provide informed consent.
This policy is applicable to all areas processing prospective patient information and patient records containing medical data.
- Abbreviations and Definitions
GDPR General Data Protection Regulations 2018
ICO Information Commissioners Office
EEA European Economic Area
PHE Public Health England
This policy applies to all staff, contract medical staff and contractors within the scope. This policy is managed and maintained by the Senior Information Risk Officer under approval from the Clinical Services Director & Chief Medical Officer.
- 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 Lower Court 3-4, 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 and Legal Basis
Check4Cancer Ltd is the Data Controller in relation to the personal and medical data we collect and process. On occasion, it maybe, we act as Joint Data Controllers, or Data Processors, under commercial or contracted arrangements. Where this is the case you will be informed at the point of processing.
To process your enquiry, we require your consent in accordance with the GDPR Article 6 (a).
Where you engage Check4Cancer for our medical screening services, we will be relying on Legitimate Interests of the GDPR Article 6 (f).
- Collecting personal information
We may collect, store and use the following kinds of personal information:
(a) 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;
(b) information that you provide to us when registering with our websites including your email address & contact details;
(c) information that you provide when completing your profile on our websites, phone, online chat, or email including your name, address, gender, date of birth, relationship status, health records, employment records & payment details;
(d) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters;
(e) 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.;
(f) 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 payment card details;
(g) information that you provide when responding to customer service feedback or complaints;
(h) 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
(i) payment data when purchasing services online or over the phone.
(j) medical information related to the results of any screening and/ or diagnostic services we provide at your request.
(k) we may also record phone calls for the purposes of staff training, mitigation of disputes and the evidence 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. If consent cannot be reasonably obtained, or there is any concern around the capacity of the individual to give consent, we may decline to process your enquiry.
- 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:
(a) administer our websites and business;
(b) personalise our websites for you;
(c) enable your use of our medical screening services;
(d) send you information;
(e) process payments;
(f) send statements, invoices and payment reminders to you, and collect payments from you;
(g) send you non-marketing commercial communications;
(h) send you email notifications that you have specifically requested that form part of the service;
(i) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(j) 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);
(k) 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);
(l) deal with enquiries and complaints;
(m) keep our websites secure and prevent fraud; and
(n) verify compliance with the terms and conditions governing the use of our websites (including monitoring private messages sent through our websites private messaging service).
(o) 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.
(p) 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.
(q) all our websites financial transactions are handled through our payment services provider. 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.
(r) data supplied by you for the purposes of our medical services is stored in our outsourced data centres. The data is stored in the EEA and the arrangements are managed under contractand EU legislation that protect your data.
(s) 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.
For corporate clients using our services, Check4Cancer will only inform the employer that a test has been performed for the purposes of invoicing for that test. Check4Cancer will never share the results of an employee’s test with the employer.
For privately insured members using our services, Check4Cancer will only inform the insurance company that a test has been performed for the purposes of invoicing for that test. Check4Cancer will never share the results of an insured member’s test with the insurance company.
We also send and receive information about you with the National Disease Registration Service (NDRS) at Public Health England (PHE) for the purposes of knowledge sharing and improving services to patients. PHE will provide Check4Cancer with cancer diagnosis data restricted to those cancers that we have clinical services for, as well as cancer staging and treatment data. This data is essential to allow Check4Cancer to perform a comprehensive and effective audit of all clients and patients who use our cancer screening and diagnostic services, and the anonymised data may be used for internal clinical reports that may be presented or published and compared to reference datasets or publications. You can find out more about the NDRS at PHE, and how they will process your data, here: https://www.ndrs.nhs.uk/
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 also disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights including providing information to others for the purposes of fraud prevention; (d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
(e) 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.
(f) except as provided in this policy, we will not provide your personal information to third parties.
- International data transfers
Your data will only be stored in the EEA or other jurisdiction where the European Council have given an adequacy decision. A list of these countries can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
In very limited cases we may need to process your data in a jurisdiction that falls outside the above. These arrangements are managed either under contract or via a regulated framework i.e. EU-US Privacy Shield.
- 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:
(a) personal & sensitive data of a medical nature will be deleted 10 years after patient discharge or last seen;
(b) when you ask us to erase your data compliant with GDPR Article 17;
Notwithstanding the other provisions of this contract, we will retain documents & records containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) 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 organisational 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 chanes 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 for example a change to your address or GP details.
- YOUR RIGHTS
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) there is no payment required; and
(b) 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.
(c) we may withhold personal information that you request to the extent permitted by law.
(d) you may instruct us at any time not to process your personal information as permitted by law.
(e) you can instruct us to erase your data, compliant to GDPR Article 17. Please note, it is highly unlikely we will comply with any erasure requests of medical screening data given our statutory obligations.
(f) you have the right to lodge a complaint with the Data Protection Authority, if you consider your rights have been breached in anyway.
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 AND 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. More information on cookies can be found here: https://en.wikipedia.org/wiki/HTTP_cookie
Note: Deleting cookies can have a negative impact on the usability of many websites.
- DATA PROTECTION REGISTRATION
Check4Cancer Ltd is registered with the UK Information Commissioner’s Office & Care Quality Commission. Our registration detail can be found here:
- OUR DETAILS
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 Lower Court 3-4, Copley Hill Business Park, Cambridge Road, Cambridge, CB22 3GN.
Our principal place of business is at Lower Court 3-4, 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 Data Protection Officer directly by email at [email protected]; please note consent is granted for genuine customer enquiries, consent for any other purpose is NOT granted.
- LIST OF APPENDICES