1.1 Milo Clinic (“we”, “us” or “Milo Clinic”) take the privacy of your information very seriously. Our Privacy Notice (together with our Terms and any other documents referred to in it) is designed to tell you, our patient, our client or the direct or indirect user of our services (the “Services”) about our practices regarding the collection, use and disclosure of personal and other information about you, your enterprise or your organisation that may be provided to us by you personally, or by email or telephone communication or collected through other means such as via our website (the “Site”) and any other digital product we provide.
1.2 This notice applies to ‘personal data’ provided to us by our patients or otherwise. Personal data means any information relating to an identified or identifiable natural person, who may be identified, directly or indirectly by reference to an identifier such as a name, an identification number, location data, online information (e.g. an IP address) or to one or more factors relating to that person.
1.3 In this notice “you” refers to any individual whose personal data we hold or process (i.e: you may be a patient, or you may be a family member, employee or otherwise connected to a patient of ours and your data has been supplied to us).
1.4 This notice is governed by the EU General Data Protection Regulation (the “GDPR”).
2.1 Personal data we hold about you will be processed either because:
2.1.1 the processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security
2.1.2. the processing is necessary in order for us to comply with our obligations under a contract between you and us
2.1.3 you have consented to the processing for the specific purposes described in this notice.
3.1 We may collect and process the following personal data about you:
3.1.1 your name, date of birth, residential address, contact address and telephone numbers, email address(es), photos and other personal information you provide to obtain further information about our Services or as part of the process of discussing a potential engagement or becoming a patient
3.1.2 information you provide to us and/or our consultants/staff when becoming our patient such as personal identification information including copies and/or online access to your passport, driving licence, national insurance number, banks statements, utility bills or other proof of address
3.1.3 payment information that we may collect or receive
3.1.4 a record of any correspondence between you and us
3.1.5 details of your visits to the Site, the resources and pages that you access
3.1.6 any information we may require from you when you report a problem or complaint
3.1.7 information about your current mental and physical health, medical history, including your medical records, details of your GP, hospital or other health related appointments and details of your previous and current medication (if any)
3.18 information about your family members including your spouse, partner and children (if any) where you have given us that information to enable us to provide the Services
31.9 information relating to your professional or working life including details of your employer, your position and hours of work, Companies House information
3.1.10 information about your lifestyle and typical drinking/smoking/recreational drug-taking habits
3.1.11 information about your education such as the school, university or college you attend, the courses being studied or the exams you are taking
3.1.12 where you are a family member, colleague or employee of our patient, certain information (falling within one of the categories above) which our patient may have supplied to us.
3.2 We only collect such information when you choose to supply it to us but please note there may be instances where, upon your request, we process your personal data which has been provided to us by a third party.
Examples of such personal data and where we obtain such data are as follows:
3.3 You do not have to supply any personal information to us but we may not be able to provide our Services in practice without providing data to us. You may withdraw our authority to process your personal data (or request that we restrict our processing – see clause 9) at any time (but we may not be able to fully perform our Services should you do so).
4.1 In order for us to perform our contract with you, we will use your information to:
4.1.1 provide our Services to you, our patient, and to those individuals connected to you (such as your partner, spouse, children and siblings)
4.1.2 assist in the administration of our Services
4.1.3 carry out and administer any obligations arising from any agreements entered into between you and us
4.1.4 manage your patient relationship with us (if any) and with our consultants (if any) and provide you with patient support
4.2 It is sometimes necessary to process your information as we have a legitimate interest in:
4.2.1 providing information about our Services to you if you are a potential patient
4.2.2 providing information about you to our consultants or staff, for the purpose of discussing, negotiating or agreeing an engagement
4.2.3 making general improvements to our Services
4.2.4 contacting you to notify you about changes to our services or the services we offer, subject to the Privacy and Electronic Communications Regulations (except where you have asked us not to do this)
4.2.5 analysing how our Site is used and to identify trends
4.2.6 ensuring that the content of the Site is presented in the most effective manner for you and for your device
5.1 A cookie is a piece of data stored locally on your computer and contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to our Site.
5.3 Once you close your browser, our access to the cookie terminates. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To change your browser settings you should go to your advanced preferences.
5.5 If you choose not to accept the cookies, this will not affect your access to the majority of information available on our Site.
5.6 An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our Site, and to administer and improve the Site.
6.1 Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following:
|Category of personal data||Length of retention|
|Personal data including information about your physical and mental health and medical history, obtained in the provision of our Services to you||We will retain this information in accordance with the recommended minimum retention periods stated in Department of Health records management guidance or any other relevant code of practice. We will only delete or destroy such personal data if in our view it is no longer necessary to retain such personal data in order to facilitate the provision of any future services to you.|
|Personal data held for the purposes of marketing or business development||3 years from the last date on which a data subject has interacted with us|
6.2 For any category of personal data not specifically defined in this Notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data.
6.3 The retention periods stated in this Notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
6.4 We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
6.5 If you wish to request that data we hold about you is amended or deleted, please refer to clause 9 below, which explains your privacy rights.
7.1 We do not disclose any information you provide to any third parties other than as follows:
7.1.1 some of our consultants and staff are self-employed and we will need to share your personal information with them, in order for them to provide the Services to you (but we will enter into an agreement with them to ensure that they process your data in accordance with this notice and your privacy rights are protected)
7.1.2 where you have asked us to share your information with a third party as part of the performance of our Services
7.1.3 where information such as email addresses is passed to third party suppliers who provide technical support or other services to assist us in the provision of our Services
7.1.4 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime)
7.1.5 in order to enforce any terms and conditions or agreements for our Services that may apply
7.1.6 we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected
7.1.7 to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7.2 Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
8.1 We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
8.1.1 protecting our servers by both hardware and software firewalls
8.1.2 locating our data processing storage facilities in secure locations
8.1.3 encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered
8.1.4 when necessary, disposing of or deleting your data so it is done so securely
8.1.5 regularly backing up and encrypting all data we hold.
8.2 We will ensure that our employees and our consultants are aware of their privacy and data security obligations through compliance with our IT and security procedures. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.
8.3 This notice and our procedures for handling personal data will be reviewed as necessary.
8.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us by email; any transmission is at your own risk. Once we have received your information, we will use the strict procedures and security features referred to in this clause to try to prevent unauthorised access.
9.1 The GDPR gives you the following rights in respect of personal data we hold about you:
|The right to be informed||You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice.|
|The right of access||You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below.|
|The right to correction||Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month.|
We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information.
|The right to erasure (the ‘right to be forgotten’)||Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our Services without holding your personal data). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible.|
We will communicate the erasure to any third parties to whom we have passed the same information.
|The right to restrict processing||You can request that we no longer process your personal data in certain ways, whilst not requiring us to the delete the same data.|
|The right to data portability||You have right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible).|
|The right to object||Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing.|
|Right to withdraw consent||If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).|
9.2 All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to us at Milo Clinic 10 Harley Street London, W1G 9PF United Kingdom or [email protected].
9.3 We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
10.1 If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO) and follow the data breach procedure outlined in our IT and Security Guidelines.
10.2 If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
11.1 Our Site may contain links and references to other websites. Please be aware that this notice does not apply to those websites.
11.2 We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via the Site and/or any other service that is operated by us. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
11.3 In addition, if you accessed our Site via a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
12.1 We will not transfer any data in a systematic way outside of the EEA but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:
12.1.1 we may communicate with individuals or organisations outside of the EEA in delivering our services, those communications may include personal information (such as contact information)
12.1.2 we may have certain third party service suppliers who are based outside the EEA or who store data outside of the EEA
12.1.3 if you communicate with us while you are outside of the EEA there may be some data transfer to you or your device
12.1.4 from time to time your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our IT and security procedures)
12.2 If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and your privacy rights will continue to be enforceable against us as outlined in this notice.
If we update or change our policy in any way, we will provide our patients with an updated policy. We will also post details of any changes to our policy on the Site to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.
Our policy is not to intentionally or knowingly collect, process, maintain or use personal information from any individual under the age of 13 unless we have received consent to do so from the child’s parent(s).
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following address or email address: Milo Clinic 10 Harley Street London, W1G 9PF United Kingdom or [email protected].
If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.