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Veincentre (“We”, “Us” or “Our”) and the clinicians who provide your treatment are committed to protecting and respecting your privacy.
Please can we strongly encourage you to read this policy.
If you are a patient of Veincentre, it is important to note that if you opt out of us contacting us for one or more of the reasons outlined below, we will still need to contact you regarding any clinical matters.
WE WILL NEVER SELL YOUR INFORMATION ONTO ANYBODY ELSE.
This policy is designed to provide you with a detailed overview of how we manage your data. It will outline the responsibilities Veincentre and our clinicians have with regards to collecting information from you and how that information may be used. In addition, it will outline your rights and how you can exercise them, in relation to personal information.
Depending on the relationship you have with us (e.g., whether or not you are/ become patient of ours) the personal information we collect from you will differ. Personal data refers to and relates to an individual.
Sensitive data, also referred to as Special Categories of personal information, may also be collected and used (e.g., information relating to your health, mental or physical). Examples include; if you are a patient, we will need to use information about your health in order to treat you; or prior to booking an appointment with us if you ask us specific questions we are unable to answer (regardless of whether or not you are currently a patient of ours) we may forward your questions and any associated images, reports etc. onto one of our clinicians for their advice so that we can respond accurately.
If you provide personal information to us about other individuals (this includes information regarded as a special category such as medical or financial information) you must inform the individual about the contents of this Privacy Notice, we will process their information in accordance with this Privacy Notice.
If you amend data which we already hold about you (e.g., information provided on registration, within the pre-consultation questionnaire etc.) please note that we will update our systems to reflect the amendments. We may keep records of past data.
As a Veincentre patient, we will hold personal information about you which may include, but not be limited to, the following:
As a Veincentre patient, we will hold information relating to your medical assessments and treatments. By law, this information is defined as a special category of personal data and as such it must be handled more sensitively.
Special categories of personal information we may hold about you include, but are not limited to, the following:
Details of your physical and mental health (current or past). This is not limited to the care you receive or need at Veincentre and may include information you, or someone on your behalf (e.g. GP) has provided to us regarding any care you have received/ are receiving from other healthcare providers such as GPs, dentists or hospitals (private and/or NHS).
The confidentiality of your medical information is of paramount importance. We make every effort to prevent unauthorised access to, and use of, information relating to your health, current or past, physical or mental.
Veincentre complies with UK data protection law, including the Data Protection Act 2018, and all applicable medical confidentiality guidelines issued by professional bodies (e.g. The GMC (General Medical Council) and NMC (Nursing and Midwifery Council).
The Data Protection Act 1998 was replaced by the EU General Data Protection Regulation (GDPR) and a new Data Protection Act on 25th May 2018.
Information may be collected directly from you when:
You correspond with us via email, letter, telephone (incoming and outgoing calls may be recorded) or social media.
You contact us via our website (including the Contact Us form, FAQ Ask a Question form, Blog post comments)
You complete one of our questionnaires (e.g. Pre/ Post Operative questionnaire, How was our service questionnaire) either online or in paper form.
You attend any appointment with us.
You enter into a contract with us for the provision of healthcare services.
You visit our website.
Personal information we hold may be collected from a number of different sources including, but not limited to:
From other healthcare organisations:
Our patients will usually receive healthcare from other organisations in addition to Veincentre, and so in order to provide you with the best treatment possible we may have to collect personal information about you from other organisations. These may include medical records which include information regarding your diagnosis, clinic and hospital visits and medicines administered from your GP, your Clinician (including their Medical Secretaries), your dentist, the NHS or any private healthcare organisation.
As detailed in the previous section, it may be necessary to seek information from other healthcare organisations. We may also collect information about you from third parties when:
We may communicate with you via telephone, SMS, email and post, providing you have provided us with these details. If we contact you via telephone and you are not available we may leave a message on your answerphone machine.
We may communicate with you by unencrypted email and/or SMS in order to provide you with updates and reminders in relation to your healthcare. These emails and SMS messages may include basic administration information and appointment information.
We may communicate with you by email to provide you with information regarding your medical records and/ or invoicing information.
If we have your mobile number and/or email address, we may contact you regarding patient surveys which are for the purpose of monitoring your clinical progress and improving our service. They are not a form of marketing.
Please note that, although providing your mobile number and email address and stating a preference to be communicated by a particular method will be taken as an affirmative confirmation that you are happy for us to contact you in that manner, we are not replying on your consent to process your personal data in order to correspond with you about your treatment. As set out further below, processing your personal data for those purposes is justified on the basis that it is necessary to provide you with healthcare services.
As detailed above, we may contact you requesting feedback or asking you to participate in surveys pre- and post-treatment at Veincentre. The requests will largely be sent via email or in the post. These requests are not a form of marketing and are not intended to sell you any further products or services. Their purpose is to gather information relating to your experience of Veincentre, for the purposes of improving the quality and safety of our services.
It is necessary for us to process your personal data in order to contact you with these surveys, on the basis of our appropriate business needs and to improve the quality of the healthcare services we offer.
Participation in the surveys is entirely voluntary.
In addition, we may also contact you requesting participation in questionnaires which aim to monitor the outcomes of your treatment. Again, these surveys are not a form of marketing. They are called Patient Reported Outcome Measures (PROMs). For private patients the results are shared with PHIN (see below for further information). A questionnaire will be sent to you prior to your initial appointment with us in order for us to gather pre-treatment information.
We may use your data, i.e. process your information, for a number of different purposes. If we use your data, we must have a legal justification to do so. The particular justification will depend on the purpose of the proposed use of your data. When the information that we process is classed as “special category of personal information”, we must have a specific additional legal justification in order to use it as proposed.
Generally, we will rely on the following legal justifications, or ‘grounds’:
Taking steps at your request so that you can enter into a contract with Veincentre to receive healthcare services from us.
For the purposes of providing you with healthcare pursuant to a contract between you and Veincentre. We will rely on this for activities such as supporting your medical treatment or care and other benefits, supporting other healthcare professionals and providing other services to you.
We have an appropriate business need to process your personal information and such business need does not cause harm to you. We will reply on this for activities such as quality assurance, maintaining our business records, developing and improving our products and services and monitoring outcomes.
We have a legal or regulatory obligation to use such personal information.
We need to use such personal information to establish, exercise or defend our legal rights
You have provided your consent to our use of your personal information.
Note that failure to provide your information further to a contractual requirement with us or a clinician may mean that we are unable to set you up as a patient or facilitate the provision of your healthcare on Veincentre’s system.
One legal ground for processing personal data is that we do this in pursuit of legitimate interest and those interest are not overridden by your privacy rights. Where we refer to use for our appropriate business needs, we are relying on this legal ground.
Special categories of personal information includes, but is not limited to, information about your:
You have a range of rights in respect of your personal data, as set out in detail in the section entitled “your rights”. This includes the right to object to Veincentre using your personal information in a particular way (such as sharing that information with third parties), and we must stop using it in that way unless specific exceptions apply. This includes, for example, if it is necessary to defend a legal claim brought against us, or it is otherwise necessary for the purposes of your ongoing treatment.
We have outlined our legal grounds for each of our processing purposes below.
As is common with most businesses, we have to carry out necessary checks in order for you to become a patient. These include standard background checks, which we cannot perform without using your personal information.
Legal ground: Taking the necessary steps so that you can enter into a contract with us for the delivery of healthcare.
Additional legal ground for special categories of personal information: The use is necessary for reasons of substantial public interest.
Legal Grounds: Providing you with healthcare and related services
Fulfilling our contract with you for the delivery of healthcare
Additional legal grounds for special categories of personal information:
We need to use the data in order to provide healthcare services to you
The use is necessary to protect your vital interests where you are physically or legally incapable of giving consent.
We will use your personal information in order to ensure that your account and billing is fully accurate and up-to-date
Providing you with healthcare and related services
Our having appropriate business need to use your information which does not overly prejudice you
The use is necessary in order for us to establish, exercise or defend our legal rights
Veincentre may process your personal data for the purposes of local clinical audit – i.e. an audit carried out by your direct team for the purposes of assessing outcomes for patients and identifying improvements which could be made for the future. We are able to do so on the basis of a legitimate interest and the public interest in statistical and scientific research, and with appropriate safeguards in place. You can however object to us using your personal data for this purpose by contacting our Data Protection Officer.
Veincentre participates in medical research and shares data with ethically approved third party research organisations. WE will share your personal data only to the extent that it is necessary to do so in assisting research and as permitted by law. Some research projects and/ or registries have received statutory approval such that consent may not be required in order to use your personal data. In those circumstances, your personal data will be shared on the basis that:
We have a legitimate interest in helping with medical research and have put appropriate safeguards in place to protect your privacy
The processing is necessary in the public interest for statistical and scientific research purposes
In the event that consent is required then either the research organisations will obtain this from you themselves, and so any questions in that regard should be directed to them, or we will take consent from you.
From time to time, patients may raise queries, or even complaints, with Veincentre and we take those communications very seriously. It is important that we resolve such matters fully and properly, and so we will need to use your personal information in order to do so.
Our providing you with healthcare and other related services
Our having an appropriate business need to use your information which does not overly prejudice you
The use is necessary for the provision of healthcare or treatment pursuant to a contract with a health professional
In addition, other healthcare professionals or organisations may need to know about your treatment in order for them to provide you with safe and effective care, and so we may need to share your personal information with them. Further details on the third parties who may need access to your information is set out in Purpose 10.
We have a legitimate interest in ensuring that other healthcare professionals who are routinely involved in your care have a full picture of your treatment.
Additional legal ground for special categories of personal information:
WE need to use the data in order to provide healthcare services to you
The use is necessary for reasons of substantial public interest under UK law
PHIN – New government requirement for private healthcare providers to share patient treatment records:
Under a new government initiative, all hospitals in the UK that offer privately funded healthcare are now required to send The Private Healthcare Information Network (PHIN) data regarding their patients. The data collected includes vital safety and quality indicators including any adverse incidents and patient feedback.
This initiative will give all patients considering private healthcare access to trustworthy, comprehensive information on both quality and price to help them make informed decisions on where to receive the best treatment.
As such, in line with our own values of quality and honesty we fully support the initiative and kindly ask our patients to assist us in providing PHIN with the data they request. The records that we share may contain personal information about patients, including you. Any information that is published will always be in anonymised statistical form.
We are only obliged to send your patient data to PHIN if you have undergone treatment at our clinic. i.e. if you only have a consultation then your information will not be sent.
The patient information we must provide PHIN includes, but is not limited to, the following:
Age, Sex, Diagnosis, NHS Number (or equivalent), Postcode, Country of Residence, Procedure/s undertaken. Veincentre may use an online NHS lookup service to locate your NHS number
We also participate in initiatives to monitor safety and quality, helping to ensure that patients are getting the best possible outcomes from their treatment and care. The Competition and Markets Authority Private Healthcare Market Investigation Order 2014 establish the Private Healthcare Information Network (PHIN), as an organisation who will monitor outcomes of patients who receive private treatment. Under Article 21 of that Order, we are required to provide PHIN with information related to your treatment, including your NHS number in England and Wales, CHI Number in Scotland Health and Care Number in Northern Ireland), the nature of your procedure, whether there were any complications such as infection or the need for readmission/ admission to an NHS facility and also the feedback you provided as part of any PROMs surveys. PHIN will use your information in order to share it with the NHS, and track whether you have received any follow-up treatment. We will only share this information with PHIN if you have provided your consent for us to do so.
The records that we share may contain personal and medical information about patients, including you. PHIN, like us, will apply the highest standards of confidentiality to personal information in accordance with data protection laws and the duty of confidentiality. Any information that is published by PHIN will always be in anonymised statistical form and will not be shared or analysed for any purpose other than those stated. Further information about how PHIN uses information, including its Privacy Notice, is available at phin.org.uk. We will be happy to print a copy for you if you prefer.
As a provider of healthcare, we are subject to a wide range of legal and regulatory responsibilities which is not possible to list fully here. We may be required by law or by regulators to provide personal information, and in which case we will have a legal responsibility to do so. From time to time, Veincentre and its clinicians are also the subject of legal actions or complaints. In order to fully investigate and respond to those actions, it is necessary to assess your personal information (although only to the extent that it is necessary and relevant to the subject matter).
The use is necessary in order for us to comply with our legal obligations
We need to use the data in order for others to provide informed healthcare services to you
The use is necessary for reasons of the provision of health or social care or treatment or the management of health or social care systems
The use is necessary for establishing, exercising or defending legal claims
As detailed above in Purpose 6, we participate in initiatives to ensure that patients are getting the best possible outcomes from their treatment and care. The records that we share may contain personal and medical information about patients, including you. With respect to PHIN, we will only share information with them with your consent. PHIN, like us, will apply the highest standards of confidentiality to personal information in accordance with data protection laws and the duty of confidentiality. Any information that is published by PHIN will always be in anonymised statistical form and will not be shared or analysed for any purpose other than those stated. Further information about how PHIN uses information, including its Privacy Notice, is available at phin.org.uk. We will be happy to print a copy for you if you prefer.
We are also required by law to conduct audits of health records, including medical information, for quality assurance purposes. Your personal and medical information will be treated in accordance with guidance issued by the Care Quality Commission (England), Health Inspectorate Wales and Healthcare Improvement Scotland.
Quality is one of Veincentre’s core values and as such we are always keen to learn from patients’ experiences in order to improve the experience for future patients. With that in mind, we will use your personal information to identify where such improvements can be made, such as reviewing phone calls to assess whether anything can be learnt and contacting you to seek your valuable thoughts on the Veincentre experience.
We need to use the data in order to manage the healthcare services we deliver, including carrying out surveys (which are not a form of marketing) in order to identify and carry out and necessary improvements.
In order to do this, we will not need to use your special categories of personal information and so we have not identified additional ground to use your information for this purpose
As a business, we need to carry out marketing but we are mindful of your rights and expectation in that regard. As a result, we will only provide you with marketing which is relevant to our business and only where you have specifically confirmed your consent to do so.
You have provided your consent
We may share encrypted portions of customer data with certain strategic partners to make our business more responsive to your position in your treatment pathway, your interests and/or those of like-minded consumers. For example, we may aggregate your email address together with the email addresses of other customers, locally encrypt such data, and transmit the resulting encrypted data to Facebook and/or Google for the purpose of creating “Lookalike Audiences” (where targeted ads are sent to people on those platforms who have similar characteristics to people on our encrypted data list) and “Exclusion Lists” (where those customers who have already completed their treatment are excluded from being targeted with advertising in future).
Our having an appropriate business need and therefore a legitimate interest to use your information which does not overly prejudice you.
We may disclose your information to the third parties listed below for the purposes described in this Privacy Notice. This might include:
We may communicate with these third parties in a variety of ways including, but not limited to, email, post, fax and telephone.
We may use your personal information to follow-up on an enquiry you’ve made or let you know of any promotions we have running. All emails are sent to you individually and tailored by a member of the Veincentre admin team according to the information you have provided to us.
If you no longer wish to receive these emails, you can click the unsubscribe link at the bottom of the email or alternatively contact our DPO.
We will NEVER provide your information to market research agencies.
We will only keep personal information for as long as reasonably necessary to fulfil the relevant purposes set out in the Privacy Notice and in order to comply with our legal and regulatory obligations.
If you would like further information regarding the periods for which your personal information will be stored, please contact our DPO.
We (or third parties acting on our behalf) may store or process information that we collect about you in countries outside the European Economic Area (“EEA”). Where we make a transfer of your personal information outside of the EEA we will take the required steps to ensure that your personal information is protected.
To the extent that it is necessary to do so, we may transfer your personal data outside of the EEA to the United States to the following specific types of third party:
Suppliers of medical devices eg heart monitoring equipment
Suppliers of bespoke prostheses eg 3D knee prosthesis suppliers
Suppliers of genomic testing eg we send pathology samples to a lab in the US who genetically map tumours to determine the effectiveness of immunotherapy drugs
We will only do so to the extent that it is relevant and necessary. The United States and the EEA have in place a framework, known as Privacy Shield, to facilitate compliance with data protection obligations when transferring personal data. Privacy Shield has been assessed by the EU Commission, and deemed to provide adequate protection to personal data.
If you would like further information regarding the steps we take to safeguard your personal information, please contact the DPO using the details at the top of the page.
Please note that we have listed above the current common transfers of personal data outside of the EEA but it may be necessary, in future, to transfer such data for other purposes. In the event that it is necessary to do so, we will update this Privacy Notice.
Under data protection law you have certain rights in relation to the personal information that we hold about you. These include rights to know what information we hold about you and how it is used. You may exercise these rights at any time by contacting us using the details set out above at the top of the page.
There will not usually be a charge for handling a request to exercise your rights.
If we cannot comply with your request to exercise your rights we will usually tell you why.
There are some special rules about how these rights apply to health information as set out in legislation including the Data Protection Act (current and future), the General Data Protection Regulation as well as any secondary legislation which regulates the use of personal information.
If you make a large number of requests or it is clear that it is not reasonable for us to comply with a request then we do not have to respond. Alternatively, we can charge for responding.
You are usually entitled to a copy of the personal information we hold about you and details about how we use it.
Your information will usually be provided to you in writing, unless otherwise requested. If you have made the request electronically (eg by email) the information will be provided to you by electronic means where possible.
Please note that in some cases we may not be able to fully comply with your request, for example if your request involves the personal data of another person and it would not be fair to that person to provide it to you.
You are entitled to the following under data protection law.
Under Article 15(1) of the GDPR we must usually confirm whether we have personal information about you. If we do hold personal information about you we usually need to explain to you:
The purposes for which we use your personal information
The types of personal information we hold about you
Who your personal information has been or will be shared with, including in particular organisations based outside the EEA.
If your personal information leaves the EU, how we make sure that it is protected
Where possible, the length of time we expect to hold your personal information. If that is not possible, the criteria we use to determine how long we hold your information for
If the personal data we hold about you was not provided by you, details of the source of the information
Whether we make any decisions about you solely by computer and if so details of how those decision are made and the impact they may have on you
Your right to ask us to restrict how your personal information is used or to object to our use of your personal information
Your right to complain to the Information Commissioner’s Office
We also need to provide you with a copy of your personal data.
We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you do not believe this is the case, you can ask us to update or amend it.
We may update this Privacy Notice from time to time to ensure that it remains accurate, and the most up-to-date version can always be found at https://www.veincentre.com/about/privacy-and-terms/. In the event that there are any material changes to the manner in which your personal information is to be used then we will provide you with an updated copy of this Privacy Notice.
In some circumstances, you have the right to request that we delete the personal information we hold about you. However, there are exceptions to this right and in certain circumstances we can refuse to delete the information in question. In particular, for example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercise or defending legal claims.
In some circumstances, we must “pause” our use of your personal data if you ask us to. We do not have to comply with all requests to restrict our use of your personal information. In particular, for example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercise or defending legal claims.
In some circumstances, we must transfer personal information that you have provided to us to you or (if this is technically feasible) another individual/ organisation of your choice. The information must be transferred in an electronic format.
You can ask us to stop sending you marketing messages at any time and we must comply with your request. You can do this by contacting the DPO.
You have a right to not be subject to automatic decisions (ie decisions that are made about you by computer alone) that have a legal or other significant effect on you.
Please see the section entitled “What marketing activities do we carry out?” for detail about when we may make automatic decisions about you.
If you have been subject to an automated decision and do not agree with the outcome, you can challenge the decision. More about this is explained in the section entitled “What marketing activities do we carry out?”.
In some cases we need your consent in order for our use of your personal information to comply with data protection legislation.
We have explained in the section entitled “What are the purposes for which your information is used?” where we rely on your consent in this way. Where we do this, you have the right to withdraw your consent to further use of your personal information. You can do this by contacting Veincentre’s DPO whose details at the top of the page.
You can complain to the Information Commissioner’s Office if you are unhappy with the way that we have dealt with a request from you to exercise any of these rights, or if you think we have not complied with our legal obligations.
More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/
Making a complaint will not affect any other legal rights or remedies that you have.
We collect this information in a way which does not personally identify anyone.
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Unit 5, Lyme Vale Court
If your details change or are incorrect, please let us know.
We may update this Privacy Notice from time to time to ensure that it remains accurate. In the event that these changes result in any material difference to the manner in which we process your personal data then we will provide you with an updated copy of the Policy.
This Privacy Notice was last updated on 10 March 2021.
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