We take your privacy very seriously and are committed to protecting your personal data. Please read this privacy policy carefully as it contains important information on who we are, the personal data we collect about you and how it is collected and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data, how your data is kept secure and how to contact us in the event you have a complaint.
We collect, use and are responsible for certain personal data about (i) visitors to our website, (ii) patients or prospective patients. This website and our services are not intended for children and we do not knowingly collect data relating to children.
This privacy policy applies to Harley Clinic Group Ltd, a company registered in England and Wales (“HCG“). If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us (see ‘How to contact us’ below).
This privacy policy is set out as follows:
- Key terms
- Personal data we collect about you
- How your personal data is collected
- How and why, we use your personal data
- Who we share your personal data with
- Where your personal data is held
- How long your personal data will be kept
- Transferring your personal data out of the UK and EEA
- Your rights
- Keeping your personal data secure
- How to complain
- Changes to this privacy notice
- How to contact us
- Governing law
1. Key terms
The key terms used in this privacy policy are as follows:
“We”, “us”, “our” | HCG |
“Personal data” | Any information about an individual from which that person can be identified |
“Special category personal data” | Certain sensitive personal data, including: · data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; · genetic data; · biometric data (where used for identification purposes); or · data concerning health, sex life or sexual orientation. |
“Data subject” | The individual who the personal data relates to |
2. Personal data we collect about you
The personal data we collect use, store and transfer about you depends on our relationship to you, and specifically on whether you are:
- are a visitor to our website;
- a patient of ours; or
- a prospective patient of ours.
The types of data we collect can be split into broad categories, including identity data, contact data, financial data, transaction data, technical data, profile data, usage data, medical data and marketing and communications data. We may collect and use the following personal data about you within these categories depending on our relationship with you (each as applicable on a case-by-case basis):
a. All (any website visitor)
Identity and contact data, including:
- your name, gender and contact information, including personal email address and telephone number, if provided to us.
Technical and usage data, including:
- location data, if you choose to give this to us;
- information about how you use our website, IT, communication and other systems;
- retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes; and
- internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
Marketing and communications data, including:
- your preferences in receiving marketing from us and our third parties and your communication preferences.
b. Patients or prospective patients
In addition to the data collected in relation to website visitors as above, we will also collect additional data on patients or prospective patients if you enlist or enquire to enlist our services.
Identity and contact data, including:
- additional identity and contact details, such as your address;
- identity and contact details for your next of kin, including name, address, telephone number and email address;
- CCTV footage if you attend our clinic
- work information and contact details for you, including your place of work, work email address, contact number and details such as job title.
Financial data, including:
- your billing information, transaction and payment card information, bank account, financial accounts and other relevant information.
Transactional data, including:
- details about payments to and from you and other details of products and services you have purchased from us.
Profile data, including:
- your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Medical data, including:
- details of referrals, quotes and other correspondence with you;
- details of services and/or treatment you have received from us or which have been received by you from a third party; and
- notes about your health and treatments received previously and with us, including details about hospital/clinic visits, appointments, treatments, procedures, medicines and follow ups.
Where you provide us with personal information about third parties, such as your next of kin, it is important that you make them aware of this and of this policy. We do not take any responsibility for the provision of such information to us.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from being able to engage with you.
3. How your personal data is collected
We collect most of this personal data directly from you — in person, by telephone, text or email and/or via our website. However, we may also collect information:
- from publicly accessible sources, such as the internet;
- from NHS medical records accessible to healthcare providers, including any letters and patient data provided by your GP;
- from a third party with your consent, e.g. your GP, other healthcare professionals where you are referred onwards, your family, your insurer or your employer;
- from cookies on our website—for more information on our use of cookies, please see our cookie policy [insert link]; or
- via our IT systems, e.g. our computer networks and automated systems on our website.
4. How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason. These reasons include:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- in a medical emergency, to protect your vital interests;
- where necessary for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We carry out assessments when relying on legitimate interests to balance our interests against your own.
The table below explains what we use your personal data for and why for the various purposes which may apply if you are (i) a visitor to our website or (ii) a patient or prospective patient:
a. All (any website visitor)
What we use your personal data for | Type of data | Our reasons |
To manage our relationship with you | Identity data Contact data | To respond to communications either: — for our legitimate interests in offering you the best service — in connection with a potential contract with you |
Preventing and detecting fraud against you or us | Technical data | For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us |
To enforce legal rights or defend or undertake legal proceedings | Identity data Contact data Technical data | Depending on the circumstances: — to comply with our legal and regulatory obligations — in other cases, for our legitimate interests, i.e. to protect our business, interests and rights |
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | Identity data Technical data | To comply with our legal and regulatory obligations |
Ensuring business policies are adhered to, e.g. policies covering security and internet use | Technical data | For our legitimate interests, i.e. to make sure we are following our own internal procedures |
Operational reasons, such as improving efficiency, training and quality control | Identity data Technical data | For our legitimate interests, i.e. to be as efficient as we can for your benefit |
Statistical analysis to help us manage our business, e.g. in relation to website usage, our financial performance, customer base or other efficiency measures | Identity data Technical data | For our legitimate interests, i.e. to be as efficient as we can for your benefit |
Preventing unauthorised access and modifications to systems | Identity data Technical data | Depending on the circumstances: — for our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for you and/or us — to comply with our legal and regulatory obligations |
Marketing our services to: — existing and former customers — third parties who have previously expressed an interest in our services — third parties with whom we have had no previous dealings | Identity data Contact data Marketing and communications data | For our legitimate interests, i.e. to promote our business to existing and former customers |
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary | Identity data Contact data Technical data | Depending on the circumstances: — to comply with our legal and regulatory obligations — in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets |
b. Patients or prospective patients
What we use your personal data for | Type of data | Our reasons |
Providing care and other services to you | Identity data Contact data Financial data Transactional data Medical Data | To perform a contract with you or to take steps before entering into a contract To satisfy our legal obligations in providing your care and to regulators, usually with your explicit consent To protect your vital interests in a medical emergency |
To manage our relationship with you | Identity data Contact data Medical Data | To perform or enter into a contract with you To notify you about changes to our terms or our privacy policy To protect our legal rights, comply with regulatory obligation and protect legitimate interests where a complaint or claim is made against us |
Conducting checks to identify our customers and verify their identity Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. for audits, under health and safety law or rules issued by regulators | Identity data Contact data Medical data | Depending on the circumstances: — to comply with our legal and regulatory obligations — for our legitimate interests |
Updating and enhancing customer records | Identity data Contact data Profile data Medical data | Depending on the circumstances: — to perform our contract with you or to take steps at your request before entering into a contract — to comply with our legal and regulatory obligations — for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products or services |
Improving our services, such as by providing training and security updates | Identity data Contact data Profile data Medical data | For our legitimate business interests and compliance with regulatory requirements |
How and why we use your personal data — Special category personal data
If you are a patient or prospective patient or if you provide such information to us as a website visitor, we will collect special category personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, information about your health, and genetic and biometric data).
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g:
- we have your explicit consent (and where you have voluntarily provided such information to us);
- the processing is strictly necessary to provide our services to you;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
- the processing is necessary to establish, exercise or defend legal claims.
We also ensure such data is processed in line with applicable professional and industry confidentiality standards, including the General Medical Counsel’s Good Medical Practice.
How and why we use your personal data — sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing and initial communications
We may use your personal data to send you updates (including by email, telephone or post) about our products and services.
We have a legitimate interest in using your personal data for marketing purposes and to contact you to ask you to offer services via our platform (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you these kinds of communications. If we change our approach in the future so that consent is needed, we will ask for this separately and clearly.
You do, however, have the right to ‘opt in’ and ‘opt out’ of receiving marketing and other communications at any time by:
- contacting us (see ‘How to contact us’ below); or
- using the ‘unsubscribe’ link in emails.
We may ask you to confirm or update your contact preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes unless we have your consent to do so.
5. Who we share your personal data with
We routinely share non-special category personal data with:
- our suppliers and subcontractors, such as IT providers and delivery companies, to perform the contract we have with you.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data and if we have a legitimate basis for sharing such information.
We may also share special category personal data in the following ways if you are a patient or prospective patient:
- doctors, nurses and other medical professionals who work with or for us where necessary for your treatment;
- third-party service providers such as laboratories and medical device companies;
- external practitioners, including the NHS, your GP or where we refer you onwards;
- your insurer where necessary and required for the provision of your treatment at their cost;
- regulatory bodies, such as the General Medical Counsel and the Private Healthcare Information Network; and
- our insurers or solicitors where necessary.
Who we share your personal data with — further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
6. Where your personal data is held
Personal data may be held on our servers in the United Kingdom and those of our service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
7. How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data. Further details on this are available on request.
In general and in line with usual limitation periods, if we are no longer providing or procuring goods or services to or from you, or our relationship has otherwise ended, we will usually delete or anonymise your account data after seven years.
8. Transferring your personal data out of the UK and EEA
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
We may transfer your personal data to our service providers located outside the UK and the EEA, if needed to maintain or enhance our service.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
- there is an adequacy decision;
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under relevant data protection law.
Where we or our processors transfer your personal data outside the UK or EEA, we take reasonable steps to ensure that this is done in line with applicable data protection laws.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
9. Your rights
You may have the following rights in respect of your personal data:
- Access (also known as a subject access request) – the right to be provided with a copy of your personal data;
- Rectification – the right to require us to correct any mistakes in the personal data that we hold on you;
- Erasure (also known as the right to be forgotten) – the right to require us to delete your personal data in certain situations where there is no good reason for us continuing to process it. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
- Restriction of processing – the right to require us to suspend processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data or if the use of the data is unlawful but you do not want us to erase it;
- Data portability – the right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party. This will only apply to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
- To object – the right to object, at any time to your personal data being processed. This can apply either for direct marketing (including profiling) or in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims;
- Not to be subject to automated individual decision making – the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you; and
- To withdraw consent – the right to withdraw consent to use your personal data if you have provided us with such consent, easily and at any time. You may withdraw consent by contacting us (see ‘How to contact us’ below). Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.
If you would like to exercise any of those rights, please email us — see below: ‘How to contact us’; and:
- provide enough information to identify yourself (e.g. your full name and address) and any additional identity information we may reasonably request from you; and
- let us know what right you want to exercise and the information to which your request relates.
10. Keeping your personal data secure
We have appropriate security measures to prevent personal data from being lost accidentally, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
11. How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’)We hope we will be able to resolve any issues you may have.
You may also have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction. For example, the UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Please contact us if you would like further information.
12. Changes to this privacy policy
This privacy policy was published on 16th June 2024 and last updated on 17 June 2024..
We reserve the right to change this privacy policy as our discretion from time to time — when we do we will inform you via our website or other means of contact such as email.
13. How to contact us
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
Email address: contact@harleyclinic.com
Postal address: Harley Clinic Group Ltd, 85 Great Portland Street, London, England, W1W 7LT
14. Governing law
This policy is prepared in accordance with the laws of England and Wales and shall be governed and construed accordingly.