Here at MCHOUC, we take privacy rights seriously. We respect the privacy of all individuals we deal with, including our website visitors, clients who use our medical services, suppliers, enquirers and anyone else we encounter in our business.
This Policy sets out information about how we use, store and transfer personal data which we receive through our website [URL] (the Site) or otherwise. We are a data controller in relation to that personal data, which means we determine the purposes and means of the processing of that personal data.
We or us means Mayo Clinic Healthcare in Partnership with Oxford University Clinic LLP, a limited liability partnership registered in the United Kingdom under number OC418962 whose registered offices are at One Glass Wharf, Bristol, United Kingdom BS2 0ZX.
Full details are set out in the relevant sections of this Policy below, but keeping it brief:
- we normally receive your personal data from you, but sometimes it might be from a third party with whom we are mutually acquainted (e.g. referrers);
- we use your personal data to deliver our services, conduct our business, keep appropriate records and meet our legal obligations;
- we may ask you to complete separate consent forms in relation to special category data relating to your health or to other sensitive matters;
- we only provide your personal data to third parties for our business purposes or as permitted by law. We don’t share your data with third party advertisers;
- we store personal data for specified periods;
- you have legal rights in relation to your personal data which you can exercise on request;
- you can contact us to enquire about any of the contents of this Policy.
1. Personal Data we Collect
In this Section we have set out the kinds of personal data that we may collect, use, store and transfer. We have grouped that data together into different categories based on its subject matter, and based on the kinds of individuals to whom they relate.
Data relating to almost everyone we deal with: e.g. Site users, enquirers, suppliers
1.1 We may process data about your use of our Sites (usage data), which we obtain through our analytics tracking systems. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.
1.2 We may process information contained in or relating to any enquiry or communication that you send to us or that we send to you (correspondence data). This could for example include enquiries from potential clients, enquiries from journalists or any other correspondence. The correspondence data may include the communication content and metadata associated with the communication, as well as any contact details you may provide to us such as your name, email address, phone number, job title, address or social media username.
Data relating to clients and their families
1.3 We may process the registration data (registration data) you provide to us in setting up your registration with us as a client. The registration data may include your name, email address, phone number, postal address, contact details of previous and current physicians, dependents or next of kin.
1.4 We may process information provided by you to us, or created by us in the course of providing you with clinical services and treatment. This will largely relate to your health and treatment so we will refer to it as health data, but it might also include records relating to other matters such as your personal history, ethnicity, sex life or sexual orientation. Because this information is all sensitive in nature (and treated as special category data for the purposes of the General Data Protection Regulation (GDPR)) we will seek specific consents from you before we collect or use it.
1.5 We may process information relating to payments we receive from you or make to you (payments data), which may include your contact details, your payment account details and the transaction details. We do not collect or process your credit or debit card details when you make payments. We use a payment processing service provider who will collect and process your card details.
1.6 We may receive personal data relating to your dependents, carers, next of kin or employers. We call this family data. Typically this information will comprise contact details only.
Data relating to suppliers and other commercial partners
1.7 If we have some other commercial relationship with you or with your employer (for example, a supply, purchase, sponsorship or referral relationship) then we may handle your contact details (name, job title, email address, postal address, telephone number), any related communications, and any related documents (such as contracts, POs and invoices, proposals and so on). We call all of this partner data.
Data relating to visitors
1.8 We may process information relating to visitors to our premises, such as their name, employer, role, contact details and vehicle registration number. We call all of this visitor data.
Personal data we obtain from others
1.9 Your personal data may be provided to us by someone other than you. We might be introduced to you in correspondence by a mutual acquaintance, or your employer might introduce us to you, or we may obtain your contact details in the course of market research if you have a public role and if those details are publicly available. Normally this data will be correspondence data or partner data as described above.
2. Our purposes and legal bases of processing
2.1 We have set out below, in table format, a description of all the ways we may use your personal data. We are also required by law to identify the legal basis on which we handle personal data. These legal bases are set out in Article 6 of the General Data Protection Regulation (GDPR). When we process personal data on the basis of our legitimate interests then we also need to identify those legitimate interests and have done so below.
2.2 Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your data. You may contact us for further information if you wish.
3. Providing your personal data to others
3.1 Our advisors. We may disclose your personal data to our insurers and/or professional advisers to take professional advice and manage legal disputes.
3.2 Disclosures designated by you. We may disclose your personal data to third parties designated by you, such as family members or consultant physicians.
3.3 Our service providers. We may disclose personal data to our service providers or subcontractors in connection with the uses we’ve described above. For example, we may disclose:
(a) any personal data in our possession to suppliers which host the secure servers on which our data is stored, or to freelance staff whose duties involve handling the relevant personal data;
(b) correspondence data to providers of email or email marketing services;
(c) payments data to our payment processing service providers;
(d) usage data to providers of analytics services; and
(e) partner data and other relevant personal data to third parties for the purposes of fraud protection, credit risk reduction and debt recovery.
3.4 We do not allow our data processors to use your personal data for their own purposes. We only permit them to use your personal data for specified purposes, in accordance with our instructions and applicable law.
3.5 Compliance. We may also disclose your personal data where necessary to comply with law.
3.6 Restructuring. If any part of our business is proposed to be sold or transferred, your personal data may be disclosed to the new owner or in connection with the relevant negotiations.
4. International transfers of your personal data
Some of the third parties to whom we may transfer your personal data, discussed above, may be located outside the EEA or may transfer your personal data to their own service providers located outside the EEA. If so, then we will ensure that transfers by our appointed data processors will only be made lawfully (e.g. to countries in respect of which the European Commission has made an “adequacy decision”, or with appropriate safeguards such as the use of standard clauses approved by the European Commission or the use of the EU-US Privacy Shield). You may contact us if you would like further information about these safeguards.
5. Data security
5.1 We have put in place appropriate security measures to protect your personal data. We also have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where required by law.
5.2 Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem.
6. Retaining and deleting personal data
6.1 We comply with our legal obligations in relation to the retention and deletion of personal data, and in particular ensure that personal data that we process is not be kept for longer than is necessary for the relevant purposes. In particular:
(a) partner and payments data will be retained for seven years after the end of the relevant contractual relationship;
(b) correspondence data will be retained for the period of the enquiry or chain of correspondence and then deleted after twenty-four months, unless it relates to a client in which case it shall be retained for the same period as the related registration and health data;
(c) most data associated with any client, including registration, health and family data, will be kept for eight years following the conclusion of treatment; and
(d) any data which is anonymised, and therefore not personal data, may be retained by us indefinitely. Typically this will be derived from usage data.
6.2 We maintain system backups for disaster recovery purposes. That means that information which is deleted from our live systems may still remain in backup until it is overwritten.
6.3 We may retain your personal data longer than set out above where necessary to comply with law or in connection with any legal claim.
7. Your rights
7.1 You have rights under data protection law – they are complex, and subject to exemptions, and you can read guidance from the Information Commissioner’s Office at www.ico.gov.uk for a fuller explanation of your rights. In summary, though:
(a) the right to access: you have the right to confirmation as to whether or not we process your personal data and, where we do, to access to the personal data, together with certain additional information;
(b) the right to rectification: you have the right to have any inaccurate or incomplete personal data about you rectified or completed;
(c) the right to erasure: in some circumstances you have the right to the erasure of your personal data (for example, if the personal data are no longer needed for the purposes for which they were processed or if the processing is for direct marketing purposes);
(d) the right to restrict processing: you have the right to restrict the processing of your personal data to limit its use. Where processing has been restricted, we may continue to store your personal data and will observe the restrictions on processing except to the extent permitted by law;
(e) the right to object to processing: you have the right to object to our processing of your personal data on the basis of legitimate interests (discussed above) or for direct marketing purposes and if you do so we will stop processing your personal data except to the extent permitted by law;
(f) the right to data portability: you have the right to receive your personal data from us if the legal basis for our processing is the performance of a contract with you, and such processing is carried out by automated means; and
(g) the right to complain to a supervisory authority: if you consider that our processing of your personal data is unlawful, you have a legal right to lodge a complaint with the ICO.
8.1 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.
8.2 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.
8.3 Cookies do not typically contain any information that personally identifies a user (except for IP addresses in some cases), but personal information that we store about you may be linked to the information stored in and obtained from cookies.
8.4 We use these kinds of cookies:
(a) Strictly Necessary Cookies: these cookies are essential to provide you with services available through our Site and to enable you to use some of its features.
For example, they allow you to log in to secure areas of our Site and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
(b) Functionality Cookies: These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customise. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
(c) Analytical/Performance Cookies: These cookies are used to collect information about traffic to our Site and how users use our Site. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages that they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
(d) Google Analytics: The Sites use Google Analytics (an analytical/performance cookie) to help analyse how users use the Sites, collecting standard internet log information and visitor behaviour information in an anonymised form from which no user is identifiable. This information is transmitted to Google and processed to compile statistical reports on activity on the Sites. These reports allow us to optimise our user experience. Google provide a browser add-on for users who wish to prevent their data from being used by Google Analytics.
Further information is available at https://tools.google.com/dlpage/gaoptout/.
8.5 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can obtain up-to-date information about blocking and deleting cookies via the support pages made available by your browser operator.
9. Third Parties
The Site may contain links to third party websites and refer to third party service providers and other entities. If you follow a link to any third party website or deal with any third party referred to on the Site, then they may have their own privacy and cookie policies, and we are not responsible for their use of any personal data which you may provide to them.
We may update this Policy from time to time by publishing a new version on the Site. You should check occasionally to ensure you are happy with any changes to this Policy, although we may notify you of significant changes to this Policy using the contact details you have given us.
11. Data protection registration
We are registered as a data controller with the UK Information Commissioner’s Office. Our data protection registration number is ZA495447
12. Contact Us
Last updated: 28 January 2019