Privacy Notice

Version: 0.4
Date: 27/08/2019
Author: Optindigo.com
Stored at: Online

Privacy Statement Summary:

Who will use my data?	Surrey Total Health Ltd is the Data Controller in respect to your data.
What for?	We will store and process your data in order to allow us to provide our medical consultancy and treatments services to our clients and to manage our relationships with our partners, suppliers, and other organisations involved in the provision of our services. We will also collect, store, and process your data if you choose to enter our competition, subscribe to our mailing lists, or interact with us in any way As an employee, contractor, volunteer, or where you work with us in any capacity you should refer to the Employee Privacy policy.
What will happen if I contact you?	If you contact us as a potential client, we will use your information to send you the information you have requested and other information that we think you will be interested in. If you contact us for any other reason, we will use your details to respond to your enquiry, process your competition entry, provide our services to you, add you to our mailing list, and meet any legal obligations or other commitments we have.
What data will be stored?	We will store only the details necessary to provide our services to our clients and to operate our business.We recognise that we store special categories of data including sensitive personal information and will take all necessary steps to store your data securely at all times.
What data will be shared?	We will not share your data with any third parties other than as described here and strictly as required to provide our services. In order to provide the best possible care we may need to share your information with other Health Care Professionals from within Surrey Total Healthcare Ltd and other organisations. Where this is necessary we will endeavour to obtain your consent however in some cases this may not be practical, and in these cases we will always act in your best interests. In certain situations we may be obliged to share your information with regulators or other legal body that request it. If we receive data from a third party for example as a referral, the principles of this Privacy Policy will apply.
How long?	Your data may be stored for a period after the end of our relationship, after which time, it will be deleted. This period will depend on the nature of the services offered. For more details please refer to our Date Retention and Erasure policy.
Who can access my data?	We take your privacy seriously and will strictly control access to your personal information at all times.Where we need to share your information, this will be with your explicit consent or where necessary to provide the care you need and always in your best interests. We will never sell, share or otherwise distribute your data to any other third party other than as required to provide our services to our clients and to operate our business. Your data may be accessed by other third parties such as our website development company and other service providers.
How is my data kept secure?	We will take the upmost precautions with your data.We will store your data on secure, dedicated UK based servers and only on secure devices. We will employ strict access control, encryption, password protection, and all appropriate Cyber Security measures as necessary. We will use secure file storage systems and dispose of all material in an appropriate manner.

About This Privacy Policy

This policy sets out how we will use and share the information that you give us. This policy describes your relationship with Surrey Total Health Ltd. The General Data Protection Regulation (GDPR) describes how organisations must collect, handle, process and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. GDPR is underpinned by eight important principals. These say that personal data must:

• Be processed fairly and lawfully
• Be obtained only for specific, lawful purposes
• Be adequate, relevant and not excessive
• Be accurate and kept up to date
• Not be held for any longer than is necessary
• Processed in accordance with the rights of the data subjects
• Be protected in appropriate ways
• Not be transferred outside the European Economic Area, unless that country or territory also ensures an adequate level of protection

We take these responsibilities seriously; this document describes our approach to data protection. This policy helps to protect us from data security risks, including:

• Loss of our clients personal sensitive data
• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
• Other loss and damage to Surrey Total Health Ltd, our partners, third parties, and data subjects as a result of a data breach or other data issue.

Who We Are And How To Contact Us

Surrey Total Health Ltd and is registered in UK with registration number: 11711369 and also with the Information Commissioner’s Office. The data controller can be contacted in any of the following ways:

Email: info@surreytotalhealth.co.uk

Phone: 07983 322 574

Website: http://www.surreytotalhealth.co.uk

Post: Nuffield Health Woking Hospital, Shores Road, Woking. GU21 4BY

Who this privacy policy applies to

Surrey Total Health Ltd is a medical consultancy company providing expert medical advice and treatment for a wide range of conditions. This policy relates to clients, third parties, and other data subjects that share their data with Surrey Total Health Ltd. Collection, processing, and storing of personal data is required in order to operate our business and provide our services.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:

• Names of Individuals
• Postal addresses
• Email Addresses
• Telephone numbers
• Sensitive personal information including medical information
• Information about treatments, consultations, tests, and other medical interventions
• Information about family members
• Company / employment information
• Video / photos of individuals
• Any other information relating to individuals

What this policy applies to

This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. This includes:

• Information you provide through our website when contacting us about using our services
• Information we collect when you enter our competitions, subscribe to our mailing list, sign-up to access our portal or interact with us in any way
• Information we collect about how you use the website using cookies, google analytics and other internet tracking technologies
• Information provided to us by a third party [individual or organisation] with your consent or where third party is acting in your interests as required to provide the best possible care for you. Including but not limited to; doctors, dentists, consultants, other HCPs, other professionals involved in healthcare, your medical records [from all sources] etc..
• When you visit us in order to discuss using these services
• Sensitive personal information you provide or collected as part of our consultation, tests, investigations, treatments, etc…
• Information relating to consultations and services we offer to you and other transactions including financial and other personal information required
• Information given and stored as part of our ongoing relationship
• Information from credit referencing agencies, debt collection companies, insurance companies, and others we use to manage our business
• All other personal information we collect as part of our relationship with you

We recognise that we collect and process sensitive data about you and that this information must be collected, processed, stored and then disposed of securely.

How your information will be used

We will only use your personal data for the purposes for which we collected it and as you would reasonably expect your data to be processed and only where there is a lawful basis for such processing, for example:

Purpose/Activity	Type of data	Lawful basis for processing
To register you as a new client	(a) Identity, (b) Contact (c) sensitive medical information	Performance of a contract with you, with your consent, and in our legitimate interest.
When you enter our competitions, surveys, other interact with us in anyway	(a) Identity, (b) Contact details (c) other personal information	With your consent, performance of a contract with you, and in our legitimate interest.
When you subscribe to our mailing list	(a) Identity, (b) Contact details (c) other personal information	With your consent, performance of a contract with you, and in our legitimate interest.
To provide our medical consultancy, treatments, and related services to you. Managing payments, fees and charges, and to collect and recover money owed to us.	(a) Identity, (b) Contact, (c) sensitive medical information (d) Financial, (e) Transaction, (f) Marketing and Communications	(a) Performance of a contract with you, (b) with your consent, (c) Necessary for our legitimate interests to recover debts owed to us, (d) Necessary to operate our business.
To manage our ongoing relationship with you which will include notifying you about changes to our terms, products and services, or privacy policy, to maintain our records	(a) Identity, (b) Contact, (c) Profile, (d) Marketing and Communications	(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 customers use our products/services
To administer and protect our business and our site (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 business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, (b) Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising	(a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications, (f) Technical information including analysis of visitor information / cookies / analytics / and other tracking technologies	Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy. To help target our social media campaigns.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical, (b) Usage, (c) Cookies / Analytics / tracking info	Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy.
In all other respects, to run our company, and provide our products and services to our clients.	(a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications (f) medical information	Necessary for our legitimate interest to run our business and provide our services to our customers. To complete clinical audits and reviews to improve our services. To establish, exercise, or defend my legal rights

As a potential client, client, supplier, or other third party may collect and process information about you, including your name, date of birth, address, contact details (including email address and mobile phone number), medical details, family and family history details, consultation history and treatmentinformation and data collected as part of any contract or provision of any service.Personal data we receive will be used for the purposes it was provided, including:

• To respond to enquires from you regarding our services
• To process your competition entry
• To add you to our subscription list and send you information about our services and selected information about services provided by other companies we think you might be interested in
• To provide our Medical Consultancy services and associated treatments to you
• To carry out our obligations arising from any contracts entered into between you and us including provision of services, and to respond to queries from you regarding those contracts
• To manage and administer the relationships between you and us
• To notify you about changes to our services and to otherwise communicate with you; for example, we will use your contact details in order to respond to any queries that you submit to us
• To track visitors to our website and analyse the effectiveness of adverts and other promotions.To maximise the effectiveness of our websites, promotions, and other marketing activity using cookies, analytics, and other internet technologies
• To obtain feedback from you regarding our services
• To manage our business and our relationship with you as a client, supplier, or other third party.

If you contact us as a potential client, and according to your preferences, we will use your personal information to provide you with information about services that may be of interest to you. This document explains how you can change whether to receive this information. Please note that, even if you choose not to receive this information, we may still use your personal information to provide you with important updates regarding your treatments and the services we provide to you, including communications in relation to any services you use or changes to how we operate.

We do not use any form of automated decision making.

How to change your preferences

We operate in line with EU GDPR (May 2018) data protection guidelines. Whether we collect, store, and process your data as a customer, employee, supplier, other third-party, we respect your rights and will respond to any request for access to personal information and requests to delete, rectify, transfer, data and to stop processing. We will also advise you on how to complain to the relevant authorities, namely the Information Commissioner’s Office. Any requests or objections should be made in writing to the Data Controller or you can visit our website, call, or email us to contact us to change your preferences at anytime.

Scope of Agreement

By contacting us as a client, supplier, or other third party and, submitting your personal data on this site or by supplying your data as required for us to provide our services to you, you are affirming your agreement for such information to be used in accordance with this privacy policy. You will be able to change your preferences at any time by the methods described as prescribed in this document.

We may from time to time use your information for marketing, account management or relationship management purposes. The main purpose of this is to provide you with information about goods and services which we think may be of interest to you and/or to maintain any existing relationship we may have with you.

Opting out at a later date

Where you give your consent for us to process your data, for example when you agree to us sending you marketing information or where you agree to us processing financial data, or where we reasonably operate in our legitimate interest, or when we have a contract with you, you can contact us to amend or withdraw your consent at anytime. You can also choose to object to processing and request deletion of your data. We respect all user rights as defined in GDPR. If you have any comments or wish to complain please contact us.

How we store and process your data

Your data will be collected stored and processed in the UK only, we do not transfer your data outside the EU. Your data will be stored for as long as necessary to provide the best care for you and for us to operate our business and to ensure we have records of service, payments, and other interactions we have with you and to enable us to meet our statutory duties. In some cases your data may be stored for longer periods of time, please check our Data Retention and Erasure policy for details.

Personal data, including your sensitive personal data, images [videos and photography], and other potentially identifiable data may be transferred outside the EU for processing. This will only be where necessary to provide the best care for you. Where this is the case, we will ensure appropriate controls are in place to protect this data.

In order to provide or services to you we use recognised third parties to take payment, conduct credit reports and other checks, manage our company accounts and provide banking services. We will store transactions, payment and order data for up to 7 years or for as long as required by UK financial and company regulations. These third parties may operate outside the EU, if this is the case, we will ensure precautions are in place to protect your data.

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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may be legally obliged to disclose your personal information without your knowledge to the extent that we are required to do so by law; in connection with any ongoing or prospective legal proceedings; in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

You will only receive marketing communications from us if you have:

• Requested information from us or used our services.
• If you provided us with your details on our website.
• Provided your contact details to us in the course of doing business, trade shows, events, and other circumstances
• Provided your details to a third party and given your consent for that third party to share your details with us sand for us to contact you regarding our servcies
• …and where you have not opted out of receiving marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Our obligations

We are a data controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the GDPR in the way we use and share your personal data. Among other things, this means that we will only use your personal data:

• Fairly and lawfully
• As set out in the legislation and this policy
• To the extent necessary for these purposes
• We will take steps to ensure your data is accurate and rectify data as necessary

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.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/

You will not normally have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

Third Parties

We may have to share your personal data with the parties set out below for the purposes described in this document. This will always be as required to provide the best care options for you and to ensure we act in your best interests.For example [but not limited to]:

• Our website is developed by a third-party company, this company does not have access to any email or other personal data.For more details including details of the company that hosts this site please refer to their Privacy Policy at: https://dontpanicdesign.co.uk/privacy-policy/
• This site is hosted on a large scale secure website hosting company, for more details please refer to their Privacy Policy at: https://www.vps.net/blog/gdpr-consent-and-you/
• Consultants and other members of Surrey Total Health Ltd in order to discuss your care and determine the best options for you.
• Other Health Care professionals outside of Surrey Total Health Ltd and organisations as required to provide the best care to you, including doctors, consultants, HCPs, and other medical professionals
• Other agencies and organisations that we determine able to help ensure you get the best treatment
• Service providers who provide IT and system administration services.
• Couriers, delivery companies, or other parties necessary to provide our products and services to you.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Other third parties we use to operate our business but only as required and as you would reasonably expect
• Our insurance company, legal representatives, and other professionals engaged by us
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.
• Under the GDPR, we are also permitted to share some information with third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

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 such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

Where we share your data with any third parties, we will take reasonable precautions to ensure that your data is protected including ensuring that any thirds party is GDPR compliant.

We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.

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 notice of every website you visit.

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose 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. This may prevent you from taking full advantage of the website.

As well as your ability to accept or reject cookies, we also require your permission to store cookies on your machine, which is why when you visit our site, you are presented with the ability to accept our terms of use, including the storage of cookies on your machine. Should you not accept then you are free to leave our website, at any time.

We also use Google Analytics to monitor activity on our site [see below], disabling cookies in your browser will stop Google Analytics from being able to track your journey and details on this website.

Social Media

If you share our content through social media, for example by liking us on Facebook, following or tweeting about us on Twitter, or giving us a ‘+1’ via Google Plus, those social networks will record that you have done so and may set a cookie for this purpose.

In some cases, where a page on our website includes content from a social network, such as a Twitter feed, or Facebook comments box, those services may set a cookie even where you do not click a button. As is the case for all cookies, we cannot access those set by social networks, just as those social networks cannot access cookies we set ourselves.

Log Files

Our systems automatically gather some anonymous information about visitors, including IP addresses, browser type, language, and the times and dates of webpage visits. The data collected does not include personally identifiable information and is used, as described above, for statistical analysis, to understand user behaviour, and to administer the site.

Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage for example:

• The number of people using it
• The pages users visit
• The journey users take through the site
• Where users enter the site
• Where users come from
• Where users exit
• The demographics of our users
• geographical location, device,
• internet browsers, and operating system.

Google Analytics does not personally identify you to us and though it records your device’s IP address which could be used to personally identify you. It does not grant us access to this. We consider Google to be a third party data processor. Google Analytics site uses cookies. Details about these can be found on Google’s developer guides.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. Further information about Google’s privacy policy may be obtained from http://www.google.com/privacy.html.

Legitimate Interests and DPIA

We have conducted a Legitimate Interest Assessment to ensure you are not adversely affected by our marketing activity. There is no requirement to conduct a DPIA.

Contacting us, exercising your information rights and Complaints

If you any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact us at the above address. We will process SARs within 30 days, SAR responses are usually free but we reserve the right to charge for excessive or unfounded requests. We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities. If you remain dissatisfied you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:

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

www.ico.org.uk

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