INTRODUCTION
Welcome to the Charing Cross Hospital Gestational Trophoblastic Disease Service privacy policy. Hereafter the Charing Cross Hospital Gestational Trophoblastic Disease Service will be referred to in this policy as the GTD Service. The GTD Service respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy policy is divided into sections set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how the GTD Service collects and processes your personal data through your use of this website, including any data you may provide through this website when you contact us. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
CONTROLLER
Imperial College Healthcare NHS Trust is made up of different entities. This privacy policy is issued on behalf of the GTD Service so when we mention ”GTD Service”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant service within Imperial College Healthcare NHS Trust responsible for processing your data. Imperial College Healthcare NHS Trust is the controller and the GTD Service is responsible for this website.
The Head of the GTD Service is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Head of the GTD Service using the details set out below.
CONTACT DETAILS
Full name of entity: Charing Cross Hospital Gestational Trophoblastic Disease Service
Email address: m.seckl@imperial.ac.uk
Postal address: Prof. Michael Seckl, Department of Medical Oncology, Charing Cross Hospital, Fulham Palace Rd, London W6 8RF
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. This version was last updated in January 2020. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Healthcare Data pertaining to your health.
We do not collect any Personal Data or Special Categories of Personal Data about you directly through this website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However if you interact with us in any way then we may collect Personal Data about you including Special Categories of Personal Data, this information may be added to your health record in order for us to meet our legal obligations to provide you with our healthcare services.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with healthcare services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• request us to promote your fundraising event;
• have given us permission to use your story on our website;
• give us feedback or contact us.
• Third parties or publicly available sources. We may receive personal Contact, Financial and Transaction data about you from providers of technical, payment and delivery services based inside or outside the EU.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To provide you with healthcare services | (a) Identity (b) Contact (c) Financial (d) Transaction | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Where you have asked us to promote your fundraising event (c) Where you have given us permission to use your story on our website | (a) Identity (b) Contact (c) Profile | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how patients use our products/services) |
| To administer and protect us and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | To administer and protect our charity and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our service, provision of administration and IT services, network security, to prevent fraud and in the context of a charity reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
COOKIES
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use cookies for the purposes of website administration specifically to access the WordPress admin area. These cookies expire after 48 hours or on browser close or 14 days if you check the “Remember Me” box. If you are a website administrator you may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access the admin parts of our site and/or the functionality of some parts of our website may be affected. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you login to our website.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to transfer or merge parts of our charity or our assets. Alternatively, we may seek to acquire other charities or merge with them. If a change happens to our charity, 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 do not transfer your personal data outside the European Economic Area (EEA).
7. DATA SECURITY
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. 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
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint 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.
We will retain the minimum amount of data required for us to supply you with relevant marketing content or in performance of a contract that we have entered into.
We may also retain your data to ensure you are no longer contacted if you wish to opt-out, or to record that your email address is no longer in operation.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with the law. We may not always be able to comply with your request of erasure for specific legal reasons, where this is the case we will inform you in our response.
• Object to processing of your personal data in situations where we are relying on a legitimate interest (or those of a third party) and you wish to object to processing on this ground as you believe it impacts on your fundamental rights and freedoms. You have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
10. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our charity in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
INTERNAL THIRD PARTIES
Other services with Imperial College Healthcare NHS Trust.
EXTERNAL THIRD PARTIES
Other healthcare service providers and other organisations which we work with to deliver our products and services.