App Privacy policy

We also collect the following special category information for patient app or portal functionality. This information is subject to additional protection due to its sensitive nature:

· Racial or ethnic origin

· Health information

We collect or use the following personal information for information updates, marketing or market research purposes:

· Names and contact details

· Website and app user journey information

· Personal information used for the purpose of research

· Information relating to the national data opt-out

We also collect the following special category information for information updates, marketing or market research purposes. This information is subject to additional protection due to its sensitive nature:

· Health information

We collect or use the following personal information for dealing with queries, complaints or claims:

· Names and contact details

· Payment details

· Account information

· Purchase or service history

· Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

· Your right of access - You have the right to ask us for copies of your personal information. 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. Read more about the right of access.

· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

· Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.

· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.

· Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.

· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.

· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information for patient app or portal functionality are:

· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o To ensure their account is linked to the user so that the content can be customised to them. It also allows us to ensure that our app is accessible to a range of people and will allow us to understand how to develop it for future consumer benefit.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for information updates, marketing or market research purposes are:

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

o Collecting the information will allow us better be able to deal with complaints and understand any trends in queries, complaints or claims. This will allow us to improve the app functionality for users.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Where we get personal information from

· Directly from you

How long we keep information

We will keep your information for 7 years.

Who we share information with

Data processors

App design and developer

This data processor does the following activities for us: To manage and develop the app for improved user experience.

Duty of confidentiality

We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:

· you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);

· we have a legal requirement (including court orders) to collect, share or use the data;

· on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);

· If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or

· If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.

National data opt-out

We comply with England’s national data opt-out because we’re using confidential patient information for purposes beyond individual care. To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint