Welcome to Broomwell Healthwatch Limited’s and Broome & Wellington LLP’s (together called ‘Broomwell’ or ‘us’ or ‘we’ or ‘our’) privacy notice.
We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
Name of organisation: Broomwell Healthwatch Ltd and Broome & Wellington LLP
Name of Data Protection Officer: Steve Ives
Email address of Data Protection Officer: firstname.lastname@example.org
Postal address: Broomwell Healthwatch Ltd, 7th Floor, 17-21 Chorlton Street, Manchester, M1 3HY
Telephone number: 0161 236 0141
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.
Scope of privacy notice
This privacy notice applies to anyone whose data we process.
Whose data do we process and what type of data do we process
Subscribed patients – who have subscribed to our service. We process demographic information including name, demographic details, address and contact details (this data is provided by the subscribed patient). We process medical history (provided by the subscribed patient or by their doctor/practice) and a record of any contacts we have had including diagnostic tests sent to us and any advice given and records of communication between us. We process invoicing details (such as bank details which the subscribed patient has provided us with) and records of payments made and any contracts signed.
Healthcare professionals / organisations – who send us diagnostic tests to interpret or pay for these tests to be interpreted. We process details of the name of the person or organisation that sends us tests, their address and contact details (provided by the person / organisation who uses the service or who commissions the service). We process a record of any contact we have had including details of the tests sent to us and our interpretation of these tests, details of any orders and records of communications between us. We process invoicing details (provided by the person / organisation who uses the service or who commissions the service) where appropriate and also any contracts signed. We process profile data (usernames and passwords) where you use our software / applications. We process data regarding how often and when you use our services.
Non subscribed patients – who have not contacted us directly but whose diagnostic test is sent to us for interpretation. We process demographic information including name, demographic details, (sometimes) address and (sometimes) contact details (all provided by the GP Practice where the patient is registered either directly to us or via a Hub where the test is performed). We process whatever medical history (if any) that we have been provided and a record of any diagnostic tests sent to us and interpretation/advice given and records of communication about each patient.
People who visit our website, order from us, contact us, conduct the quiz on our website. We process any information you send to us when you order electrodes or contact us. Whilst visiting our website IP addresses are automatically collected by our webserver as part of traffic data, and cookies are used.
Prospective customers. We process your contact details and store messages we have sent you and any messages you have sent us (if any). We may send you marketing emails or make marketing phone calls to you or send marketing letters to you from time to time. You can opt out of receiving these marketing communications at any time by emailing email@example.com.
Employees or prospective employees. We process applications, CVs, any contact between yourself and us, references, employment records, contracts, performance records, disciplinary records.
We may also process aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
What is the purpose of our processing
The purposes of our processing are:
- To interpret diagnostic tests
- To consider any relevant medical history and demographic details to assist with such interpretation
- To contact patients in the rare cases that this is required
- To identify which test belongs to which patient
- To keep records in order to obtain insurance and comply with good record keeping
- To invoice for the work we have done
- To recruit, train and retain staff
- To comply with the law
What is the lawful basis for our processing
The lawful basis for our processing is the legitimate interest we have in providing an accurate, useful and successful healthcare service and business. These legitimate interests include (a) providing a high quality medical service with accurate and appropriately written reports (b) operating a successful business where we can contact current or prospective customers and charge for services delivered (c) keeping good records so that we can reference previous records as appropriate respond to claims or comments and also maintain insurance for our business (d) monitoring performance (e) training and educating our staff and learning from our experience.
Because we process special category data (health records and demographic information) we have also conducted a legitimate interest assessment for the special category data that we process.
With whom do we share the data we process
We share your information within Broomwell Healthwatch and Broome & Wellington LLP. We share your information with the staff we employ within these companies.
We share diagnostic test results and reports, to the healthcare professional / organisation who sent us tests to interpret and occasionally with other NHS organisations that require it (eg a hospital to whom you have been referred).
We share your information with other healthcare professionals with whom we work if we need their expert opinion on the test interpretation.
We engage other companies or professionals to support us by providing support services (eg accounting, payroll, audit, IT). These companies or professionals may process your data in the course of them providing these support services to us.
We invoice for our services and sometimes share your information for invoicing purposes with the entity which pays the invoices.
We transfer your data in various ways (web, email, post etc) and the entity which enables these transfers may process your data in the course of such transfer.
How long do we retain information
For medical records and diagnostic tests and results we are under an obligation to maintain records for a minimum period as set out by our insurance. The minimum retention period required is currently 10 years.
However for ECGs sent to us which we may need to refer back to when interpreting later ECGs we retain the information securely and safely for as long as the customer who sent us the test remains our customer.
You have the right to:
Request confirmation that we process your data
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 consider your request to decide whether we agree that the data we hold is inaccurate.
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 reasons which will be notified to you, if applicable.
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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
For all of the above we will need to first verify your identity (usually by working with your practice as we will not usually have details of your address / telephone number) and will then respond in a timely manner.
Third Party links
Our website may from time to time include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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