GDPR Privacy Notice

Conscious Healthcare
Privacy Notice

1.  IMPORTANT INFORMATION AND WHO WE ARE  


Conscious Healthcare ("we," "us," or "our") is a private GP service committed to protecting the privacy and security of your personal data and subject to the common law duty of confidentiality and consent.
As health care professionals who provide care, we need to keep records regarding your consultations.  These records help to provide you with the best possible healthcare.  We collect and hold data for the primary purpose of providing healthcare services to our patients. In carrying out this role we may collect information about you which helps us respond to your queries or secure specialist services. We may keep your information in written form and/or in digital form. The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health.
This Privacy Policy sets out how Conscious Healthcare collects, uses and protects your personal data through the use of our website (https://www.conscioushealthcare.co.uk), services or other interactions with us, including any data you may provide when you register with us, use our services or portal.
This website is not intended for children and we do not knowingly collect data relating to children.
We adhere to the principles outlined in the UK General Data Protection Regulation (UK GDPR) ((EU) 2016/679), the Data Protection Act 2018 (DPA 2018) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426) (PECR).  Conscious Healthcare is the data controller under this data protection legislation and responsible for your personal data.  Personal data means any information about an individual from which that person can be identified.  We are registered with the Information Commission under the Data Protection (Charges and Information) Regulations 2018.
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (Paragraph 9), please contact us using the information set out in the contact details section (Paragraph 10).


2.  THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU  


At Conscious Healthcare, the health care professionals who provide you with care maintain records about your health and any treatment or care you have either provided us with, or records received in relation to your healthcare.  These records help to provide you with the best possible healthcare.  Personal data we may hold about you includes: 

  • Identity Data including first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Identification documents.
  • Health information (including past and current notes and reports on your health, such as medical history (including any surgical procedures), family history of health conditions, drug history (including a list of medications and supplements),  dietary requirements, allergies and health conditions, biometric information, genetic information, sex life information, sexual orientation information).
  • Details about your treatment and care.
  • Any contact we have had with you, such as records of appointments, decisions and referrals.
  • Call recordings. 
  • Results of investigations, such as laboratory tests, blood tests, imaging, x-rays etc.
  • Relevant information from other health professionals, relatives or those who care for you.

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

  • Financial Data including bank account and payment card details.
  • Transaction Data including details about payments to and from you and other details of services you have purchased from us.
  • Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
  • Profile Data including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data including information about how you interact with and use our website, products and services.
  • Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.


3.  HOW IS YOUR PERSONAL DATA COLLECTED?  


 We use different methods to collect data from and about you including through: Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email, telephone or otherwise. This includes personal data you provide when you:

  • apply for our services;
  • create an account on our clinical portal, Function 365;
  • subscribe to our service or publications;
  • request marketing to be sent to you; or
  • give us feedback or contact us.


Please note that we use the following services to interact with you:

  • Heidi Health, an AI medical scribe for clinicians, for recording calls.  Please go to their website to learn more: GDPR Compliance UK | Data Privacy Standards.
  • Function 365, a medical management system for granting you access to your own electronic healthcare records and personalised clinical portal.   Please go to their website to learn more: Function 365 Practice Management Software - Privacy Notice Patients and Function 365 Practice Management Software - Customer Privacy Notice.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using a GP out-of-hours form, cookies, server logs and other similar technologies.
  • Third parties. We will receive personal data about you from various third parties, for example, when blood tests, imaging tests or other tests are requested from a laboratory or imaging centre.      

Technical Data is collected from the following parties: Analytics providers such as Google, Facebook and Instagram based outside the UK.
Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe based outside the UK.


4.  HOW WE USE YOUR PERSONAL DATA  


LEGAL BASES
The law requires us to have a legal basis for collecting and using your personal data to provide healthcare services. We rely on one or more of the following legal bases for processing your personal data:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.  All of your data protection rights may apply except the right to object.


Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience in relation to your healthcare. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).  All of your data protection rights may apply, except the right to portability. Our legitimate interests are to work look after your physical or mental health.

Vital interests: We may need to collect or use your personal data in the event that your physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter.  All of your data protection rights may apply, except the right to object and the right to portability.

Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Consent: We have permission from you after we gave you all the relevant information and rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.  All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.


DIRECT MARKETING  
During the registration process on our website when your personal data is collected, you will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving the marketing.
THIRD-PARTY MARKETING 
We use Google Analytics, Google Ads, and Facebook Ads (with Facebook Pixel) and share some data with these companies to track website performance and run targeted adverts. We will get your express consent before we share your personal data with any other third party for their own direct marketing purposes. 

OPTING OUT OF MARKETING  
You can ask to stop sending you marketing communications at any time by selecting the opt out box when you register on our site.  If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example appointment reminders, updates to our Terms and Conditions, checking that your contact details are correct.


5. DISCLOSURES OF YOUR PERSONAL DATA  


We do not share your information with other healthcare organisations without your permission.
We may share your personal data where necessary with the parties set out below for the purposes set out within this policy or as specified.
Specific third parties such as laboratories or imaging centres (for the purposes outlined above).      
Heidi Health, for recording calls (as outlined in clause 3 above).
Function 365, for your clinical portal (as outlined in clause 3 above).
If you lack mental capacity and have a named advocate or power of attorney, we may share information with your advocate or power of attorney.
In the event of a legal or safeguarding case we may be obliged to share information with other health professionals, lawyers, police or the courts.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS  


We may transfer your personal data to service providers that carry out certain functions on our behalf.  This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.
Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that we only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.

7.  DATA SECURITY  

We ensure that information we hold is kept in secure locations, is protected by appropriate security and access is restricted to authorised personnel.  We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  These measures include: encryption, secure servers, restricted access to personal data.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.  DATA RETENTION  


We retain your personal data for as long as reasonably necessary to fulfil the management of patient records in accordance with data protection legislation and medical professional best practice.  We may retain some of your personal data for a longer period where required by law (for example, in the event of a complaint, death 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.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

9.  YOUR LEGAL RIGHTS   

You have a number of rights under data protection laws in relation to your personal data.
Right of access - You have the right to ask us for copies of your personal information (commonly known as a “subject access request”).  You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.