Privacy Policy for MyClinic Rooms

Welcome to the MyClinic’s privacy policy. MyClinic is a trading brand of MyClinic.com Ltd.

MyClinic 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 provided in a layered format so you can click through to the specific areas set out below.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how MyClinic collects and processes your personal data through your use of this website, including any applications associated with it.

This website is not intended for unaccompanied children.

It is important that you read this privacy policy together with any other privacy policy or fair processing 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. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

MyClinic.com Ltd (the legal entity of MyClinic) is the data controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

We have an appointed data protection officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact [email protected].

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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 on 22nd May 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 Clinicians

We collect data about clinicians who register and create virtual clinic waiting rooms. 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 clinicians which we have grouped together as follows:

● Identity Data including title, first name, last name, username or similar identifier.

● Contact Data including email address, physical address and telephone numbers.

● Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

● Profile Data including your username and password, preferences, feedback and survey responses. 

● Usage Data including information about how you use our website, products and services.

● Marketing and Communications Data including your preferences in receiving marketing from us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (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.

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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. The data we collect about Patients

We collect data about patients who register to enter a virtual clinic waiting room. 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 patients which we have grouped together as follows:

● Identity Data including title, first name, last name, or similar identifier.

● Contact Data including email address and telephone number.

● Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

● Profile Data including your preferences, feedback and survey responses. 

● Usage Data including information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (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.

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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

4. 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 data by filling in forms or by corresponding with us by phone, email, live chat or otherwise. This includes personal data you provide when you:

● register for a clinician account;

● join a virtual waiting room;

● subscribe to our service or publications;

● enter a competition, promotion or survey; or

● give us feedback or contact us.

● Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

● Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

(a) analytics providers such as Google based outside the EU;

(b) advertising networks such as search marketing outside the EU; and

(c) search information providers such as Google, Bing, Facebook based outside the EU.

● Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

5. 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 (or those of a third party) 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.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity(b) Contact Performance of a contract with you
To process and deliver your order including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us (a) Identity(b) Contact(c) Financial(d) Transaction(e) Marketing and Communications (a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or take a survey (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 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 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 website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical 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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical(b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity(b) Contact(c) Technical(d) Usage(e) Profile(f) Marketing and Communications Necessary for our legitimate interests (to develop our products/services and grow our business)

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://myclinic.com/cookie-policy/

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 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. Clinician Data retention

How long will you use clinician data for?

We will only retain clinician personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including maintaining access to our online services. We may retain clinician 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.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Patient Data retention

How long will you use patient data for?

We will only retain patient personal data for as long as reasonably necessary to fulfil the purposes of a virtual consultation. After such consultation, the data is deleted as soon as reasonably possible, usually within 24 – 48 hours. We may retain patient 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.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have 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 local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also 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:

●               If you want us to establish the data’s accuracy.

●               Where our use of the data is unlawful but you do not want us to erase it.

●               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.

●               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 in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

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.

11. Data Sharing with the NHS.

Applicable for NHS GP practices in the UK

Under the Notice issued by the Secretary of State on 20th March 2020 made under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI) which was addressed to GP Practices, NHS England and NHS Improvement are collating practice level data on the utilisation of online and video consultation systems. This is to support service delivery including implementation, resourcing, planning and research to respond appropriately during the pandemic. The information is being collected directly from online consultation and video consultation suppliers.

This practice level information on the availability and use of online and video consultation services will be shared with the department of health and social care, national NHS, regional, system, CCG, PCN and practice teams.

12. Specific Policies in relation to how data is processed regarding the DFOCVC Framework

MyClinic will act as a Data Processor on behalf of our customers (such as GP Practices, or other such Data Controllers) using the MyClinic Video Consultation solution under the DFOCVC framework. In such cases, we will only act as a processor of the data, in line with the directions set out by Data Controllers themselves (our customers) and not act in a Data Controller capacity over any personal data collected or otherwise processed in the provision of the MyClinic service to our customers.

If you wish to exercise any of the rights set out above, please contact [email protected].

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