Your Personal Information

Purpose of Policy

RJ Health & Wellbeing needs to gather and use certain information about individuals.
These can include clients, suppliers, and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data will be collected, handled and stored to comply with the General Data Protection Regulation.

Policy Statement

RJ Health & Wellbeing is committed to a policy of protecting the rights and privacy of clients, staff and others in accordance with General Data Protection Regulation.
RJ Health & Wellbeing commits to:

  • Comply with both the law and good practice
  • Respect individuals’ rights
  • Be open and honest with individuals whose data is held
  • Register our details with the Information Commissioner’s Office (ICO)

Personal Data

RJ Health & Wellbeing may hold data for the following purposes:

  • Provision of direct healthcare
  • Marketing and newsletters
  • Case histories

Special categories of data include ethnic origin, medical conditions, and medical history. RJ Health & Wellbeing hold special category data for the purpose of provision of direct healthcare. 

Data Protection Principles

There are six data protection principles that are core to the General Data Protection Regulation. RJ Health & Wellbeing will always make every possible effort to comply with these principles in our information-handling practices. The principles are:

  1. Lawful, fair, and transparent: Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.
  2. Limited for its purpose: Data can only be collected for a specific purpose
  3. Data minimisation: Any data collected must be necessary and not excessive for its purpose.
  4. Accurate: The data we hold must be accurate and kept up to date.
  5. Retention: We cannot store data longer than necessary.
  6. Integrity and confidentiality: The data we hold must be kept safe and secure.

 

Key risks

The main risks lie in two key areas:

  1. Information about individuals getting into the wrong hands, through poor security or inappropriate disclosure of information
  2. Individuals being harmed through data being inaccurate or insufficient.

 

Responsibilities

Rebecca Healey is the data controller for all personal data held by us and is responsible for:

  • Analysing and documenting the type of personal data we hold
  • Checking procedures to ensure they cover all the rights of the individual
  • Identifying the lawful basis for processing data
  • Ensuring consent procedures are lawful
  • Implementing and reviewing procedures to detect, report and investigate personal data breaches
  • Storing data in safe and secure ways
  • Assessing the risk that could be posed to individual rights and freedoms should data be compromised

Data Recording, Security and Storage

Data accuracy and relevance

RJ Health & Wellbeing will ensure that any personal data we process is accurate, adequate, relevant, and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

Data security

RJ Health & Wellbeing will keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, we will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.

Storing data securely

RJ Health & Wellbeing collects personal medical data and other information necessary to fully assess your health status and to enable us to provide our services. Information is collected via a completed web form, or during telephone/ video consultation calls. We may also receive information from a third party such as a patient’s General Practitioner or other clinician/ specialist. Should this be the case, it is likely that the patient will have provided prior consent for this.

Any handwritten notes made during consultations will be scanned and uploaded to the practice management portal (Practice Better), and the hard copies destroyed.

Some personal contact information (name, address, email, and telephone number) is kept separately in our accounting software, Quickfile, to enable us to create invoices for our services and maintain our accounts.

  • In cases when data is stored on printed paper, it will be kept in a locked cabinet where unauthorised personnel cannot access it.
  • Printed data will be shredded when it is no longer needed.
  • Data stored on a hard drive will be encrypted and locked away securely when not being used.
  • Cloud services used to store personal data will be assessed for compliance with GDPR principles. All data stored on cloud services will be encrypted.
  • Data will be regularly backed up.
  • All possible technical measures will be put in place to keep data secure.

Data retention

RJ Health & Wellbeing will retain personal data for no longer than is necessary. This shall be in accordance with the guidelines of the Information Governance Alliance (IGA), which means we will hold health records for 8 years from the date of your most recent appointment with us. If R J Health & Wellbeing ceases to operate, they will be held in suitable electronic storage only accessible by the practitioner. Once a record passes the relevant regulatory time limit, it will be securely destroyed within one year.

Emailing us

If you send personal information to us via email, this may be stored in our email system temporarily, to enable us to access it. If you thereafter choose not to process with our service, your information will be deleted from the email system. Should you proceed with our services, your personal information will be transferred to our data systems to secure it, and deleted from our email system. We monitor all emails sent to us for viruses and malicious software.

Accountability and Transparency

RJ Health & Wellbeing will ensure accountability and transparency in all our use of personal data. We will keep written up-to-date records of all the data processing activities that we do and ensure that they comply with each of the GDPR principles. We will regularly review our data processing activities and implement measures to ensure privacy by design including data minimisation, pseudonymisation, transparency and continuously improving security and enhanced privacy procedures.

Consent

RJ Health & Wellbeing will ensure that consents are specific, informed and plain English such that individuals clearly understand why their information will be collected, who it will be shared with, and the possible consequences of them agreeing or refusing the proposed use of the data. Consents will be granular to provide choice as to which data will be collected and for what purpose. We will seek explicit consent wherever possible.

We will maintain an audit trail of consent by documenting details of consent received including who consented, when, how, to what, and if and when they withdraw consent. We will regularly review consents and seek to refresh them regularly or if anything changes.

You may withdraw your consent for any aspect of personal data processing at any time by contacting us. Once deleted, this process will be irreversible. We may, if required, arrange for data to be transferred to you or your general practitioner.

Direct Marketing

RJ Health & Wellbeing will comply with both data protection law and Privacy and Electronic Communication Regulations 2003 (PECR) when sending electronic marketing messages. PECR restricts the circumstances in which we can market people and other organisations by phone, text, email, or other electronic means.

We will seek explicit consent for direct marketing. We will provide a simple way to opt out of marketing messages and be able to respond to any complaints.

Subject Access Requests

What is a subject access request?

An individual has the right to receive confirmation that their data is being processed, access to their personal data and supplementary information which means the information which should be provided in a privacy notice.

What happens after a subject access request

RJ Health & Wellbeing will provide an individual with a copy of the information requested, free of charge. This will occur within one month of receipt. We endeavour to provide data subjects access to their information in commonly used electronic formats (as described in section 7.3).

If complying with the request is complex or numerous, the deadline can be extended by two months, but the individual will be informed within one month.

We can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data, we can request the individual specify the information they are requesting.

Once a subject access request has been made, we will not change or amend any of the data that has been requested. Doing so is a criminal offence.

Data portability requests

We will provide the data requested in a structured, commonly used, and machine-readable format. This would normally be a PDF file, although other formats are acceptable. We must provide this data either to the individual who has requested it, or to the data controller they have requested it be sent to within one month.

Transferring data internationally

There are restrictions on international transfers of personal data. We will not transfer personal data abroad without express consent.

 

Third Parties

Using third party controllers and processors

As a data controller and/or data processor, we will have written contracts in place with any third-party data controllers (and/or) data processors that we use. The contract will contain specific clauses which set out our and their liabilities, obligations and responsibilities.

As a data controller, we will only appoint processors who can provide sufficient guarantees under GDPR and that the rights of data subjects will be respected and protected.

As a data processor, we will only act on the documented instructions of a controller. We acknowledge our responsibilities as a data processor under GDPR and we will protect and respect the rights of data subjects.

Stripe

RJ Health & Wellbeing uses Stripe to securely process all our online payments. For more information on the privacy practices of Stripe, please visit the Stripe privacy policy here.

Practice Better

RJ Health & Wellbeing uses Practice Better, a GDPR and HIPAA compliant electronic practice management tool which stores health information, appointment information, and facilitates communication between practitioners and clients. For more information on the privacy practices of Practice Better, please visit the Practice Better privacy policy here.

When you make an appointment with RJ Health & Wellbeing, you will be asked to consent to data processing before being granted access to the Practice Better patient portal via email link. By using the portal, you consent to the storage and analysis of the data you provide, so that we may provide our services.

Reporting breaches

Any breach of this policy or of data protection laws will be reported as soon as practically possible. This means as soon as we become aware of a breach. RJ Health & Wellbeing has a legal obligation to report any data breaches to UK Supervisory authority which is the Information Commissioners Officer within 72 hours.

Changes & Updates

We keep our Privacy Policy under regular review. This Privacy Policy was last updated on 19 May 2020.