Privacy and Cookie Policy

Introduction

Haemorrhoid centre (“we“, “our“, or “us“) understands that your personal data is entrusted to us and appreciates the importance of protecting and respecting your privacy. This Privacy and Cookie Policy explains how we collect, use, and protect your information when you visit our website or use our services.

As a medical clinic providing haemorrhoid treatment services, we are committed to maintaining the highest standards of data protection and confidentiality in accordance with UK data protection laws and medical confidentiality requirements.

Scope: This privacy policy applies to anyone who interacts with us regarding our products and services in any way (including by email, telephone conversation or post). It sets out the basis on which we collect, hold and process personal data about you.

Important: By using our website, providing your personal data to us or by using our services, you are accepting or consenting to the practices as described in this Privacy Policy.

Legal Framework and Data Controller

We comply fully with the General Data Protection Regulation (GDPR) and with the Data Protection Act in force in the UK (“Data Protection Laws“). We also adhere to relevant clinical and medical guidelines including those published from time to time by the General Medical Council, specified Royal Colleges and the Nursing and Midwifery Council.

Data Controller: For the purpose of Data Protection Laws, the data controller is Haemorrhoid centre, 93 Wardour St, London, W1F 0UD. We are registered with the Information Commissioner's Office (ICO).

When we refer to 'we', 'us' and 'our', we mean Haemorrhoid Centre Clinic. Where we refer to 'you' or 'your' we mean anyone who interacts with us regarding our products and services.

Information We Collect

Personal Information

Within this policy, we refer to personal data, by which we mean information that can or has the potential to identify you as an individual. We may collect this information from you or from a third party (which could include family members, guardians, insurance companies, doctors or other medical professionals, clinical referrers, etc.)

We may collect the following types of personal information:

• Name, address, and contact details (email, phone number)
• The name and contact details of your next of kin
• Details of referrals, quotes and other contact information and correspondence
• Details of services and/or treatment you have received from us or from doctors to whom we have referred you
• Information obtained from customer surveys, promotions and competitions
• Recordings of phone calls with you that we receive or make
• Notes and reports about your health and any treatment and care you have received and/or need
• Patient feedback and treatment outcome information you provide
• Information about complaints and incidents
• Information you give us when you make a payment to us, such as financial or credit card information

Information from Third Parties

We may also collect information about you from:

• A family member, or someone else acting on your behalf
• Doctors, other clinicians and health-care professionals, hospitals, clinics and other health-care providers
• NHS organisations who are commissioning us or doctors to whom we refer you to provide your care
• Any service providers who work with us in relation to your treatment, i.e. your insurance company or referring GP/Consultant
• Fraud-detection and credit-reference agencies
• Sources which are available to the public, such as the edited electoral register or social media

Patients Under 18 Years

There are occasions when we will need to gather and process personal data regarding a child under 18 years of age, if we are asked to provide treatment to that child by their parent or guardian. In gathering such personal data we will ensure that we obtain consent from the parent or guardian of the child and will only obtain and process the personal data relevant and necessary to assist us in providing the treatment.

Website Usage Information

When you visit our website, we may automatically collect personal data about you including:

• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
• Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page

Legal Basis for Processing

We process your personal information based on the following legal grounds:

• Contract: We will generally process Personal Data regarding customers and people that we provide our services to when we are under contract and/or in the process of entering into a contract. The processing of such Personal Data is necessary for the contract or when we have been asked to take specific steps before entering into a contract.
• Legitimate Interest: We may also process limited Personal Data of contacts for the purposes of the legitimate interests of the Company. We have a legitimate interest in keeping in touch with our customers and contacts which may include sending targeted emails regarding news about our business. We have balanced this legitimate interest of the Company against the rights of the individual and do not conclude this is unreasonable, as at all times the data subject has a right to be forgotten and their Personal Data to be deleted.
• Legal Obligation: To comply with healthcare regulations and laws
• Consent: For marketing communications and certain data processing activities

Categories of Personal Information

We process 2 categories of personal information and data about you:

• Standard personal demographic information: Your name, contact details, address
• Special categories of information: Gender, date of birth, medical history, clinical information and ethnicity which helps us tailor our care and also information about credit financing and crime which enable checks for anti-fraud and credit ratings

When Do We Collect Personal Data?

We may collect personal data about you if you:

• Visit our website
• Enquire about our services or treatments (please note in the interests of training and continually improving our services, calls to Haemorrhoid centre and its agents may be monitored or recorded)
• Register to be a customer or patient with us or book to receive any of our services or treatments
• Fill in a form or survey for us
• Carry out a transaction on our website
• Participate in a competition or promotion or other marketing activity
• Make online payments
• Contact us, for example by email, telephone or social media
• Participate in interactive features we provide through websites and digital media
• Are referred to us for treatment from a third party referrer (insurance company, NHS organisation, medical consultant or GP)

Health Information and Medical Data

Sensitive personal data (including information relating to your health) will only be disclosed to third parties involved with your treatment or care if you consent to this. You will be asked to consent to our exchanging information with doctors, other medical staff and insurance companies if you become a patient.

Where applicable, it may be disclosed to any person or organisation who may be responsible for meeting your treatment expenses or their agents. It may also be provided to external service providers and regulatory bodies (unless you object) for the purpose of clinical audit to ensure the highest standards of care and record keeping are maintained.

Medical Professionals Working With Us

We share clinical information about you with our medical professionals as we think necessary for your treatment. Medical professionals working with us might be our employees, or they might be independent consultants in private practice or consultants and clinical staff employed by the NHS. In the case of independent consultants and other doctors or medical practitioners, they are the data controller of your personal data, either alone or jointly with us and will be required to maintain their own records in accordance with Data Protection Laws and applicable clinical confidentiality guidelines and retention periods.

Your GP

If the practitioners treating you believe it to be clinically advisable, we may also share information about your treatment with your GP. You can ask us not to do this, in which case we will respect that request if we are legally permitted to do so, but you should be aware that it can be potentially very dangerous and/or detrimental to your health to deny your GP full information about your medical history, and we strongly advise against it.

Your Insurer

We share with your medical insurer information about your treatment, its clinical necessity and its cost, only if they are paying for all or part of your treatment with us. We provide only the information to which they are entitled. If you raise a complaint or a claim we may be required to share personal data with your medical insurer for the purposes of investigating any complaint/claim.

The NHS

If you are referred to us for treatment by the NHS, we will share the details of your treatment with the part of the NHS that referred you to us, as necessary to perform, process and report back on that treatment.

Medical Regulators

We may be requested – and in some cases can be required – to share certain information (including personal data and sensitive personal data) about you and your care with medical regulators such as the General Medical Council or the Nursing and Midwifery Council, for example if you make a complaint, or the conduct of a medical professional involved in your treatment is alleged to have fallen below the appropriate standards and the regulator wishes to investigate.

How We Use Your Information

Your personal data will be kept confidential and secure and will, unless you agree otherwise, only be used for the purpose(s) for which it was collected and in accordance with this Privacy Policy, applicable Data Protection Laws, clinical records retention periods and clinical confidentiality guidelines.

We process your personal information for a number of legitimate interests which include:

• Managing your care and treatment
• Communications in our relationship with you
• Marketing analysis
• Clinical research and product/service development
• Ability to exercise rights in order to handle claims
• To enable us to carry out our obligations to you arising from any contract entered into between you and us
• To provide you with information, products or services that you request from us
• To provide you with information about products or services we offer that we feel may interest you
• To notify you about changes to our products or services
• To manage our relationship with you, our business and third parties who provide products or services for us
• To provide health-care services on behalf of a third party (for example, your employer)
• To make sure that claims are handled efficiently and to investigate complaints
• To keep our records up to date
• To provide you with marketing information as allowed by law
• To develop and carry out marketing activities and to show you information that is of interest to you
• To monitor how well we are meeting our clinical and non-clinical performance expectations
• To enforce or apply our website terms of use, our policy terms and conditions or other contracts
• To exercise our rights, to defend ourselves from claims and to keep to laws and regulations that apply to us
• To respond to requests where we have a legal or regulatory obligation to do so
• To check the accuracy of information about you and the quality of your treatment or care
• To support your doctor, nurse or other healthcare professional
• To assess the quality and/or type of care you have received
• To ensure that content from our website is presented in the most effective manner for you and for your computer

Data Security and Protection

We protect all personal data we hold about you by ensuring that we have appropriate organisational and technical security measures in place to prevent unauthorised access or unlawful processing of personal data and to prevent personal data being lost, destroyed or damaged.

Any personal data you provide will be held for as long as is necessary having regard to the purpose for which it was collected and in accordance with all Data Protection Laws.

Data Transfer Security: Data protection legislation is harmonised throughout the European Economic Area ('EEA') which comprises the EU member states, Norway, Iceland and Liechtenstein. Countries outside the EEA do not generally have the same level of protection for personal information as those within the EEA. We do not anticipate the need to transfer your data outside Europe and it is unlikely we will need to transfer data outside the EEA. If there is an occasion we need to do this for any reason, we will keep you informed and ensure we have procedures in place to do so.

Payment Security: All information you provide to us is stored securely. Any payment transactions on our website will be processed securely by third party payment processors. We will not retain any form of your personal finance or payment information ourselves.

Email Security: At your request, we may occasionally transfer personal information to you via email, or you may choose to transfer information to us via email. Email is not a secure method of information transmission; if you choose to send or receive such information via email, you do so at your own risk.

Data Sharing and Disclosure

In the usual course of our business we may disclose your personal data (to the extent necessary) to contracted organisations that we use to support the delivery of our services. This may include the following:

• Contracted medical and clinical practice staff, business partners and suppliers and sub-contractors for the delivery of any contract we enter into with you
• Organisations providing IT systems and support and hosting in relation to the IT systems on which your information is stored
• Third party debt collectors for the purposes of debt collection
• Third party service providers for the purposes of storage of information and confidential destruction
• Third party marketing companies for the purpose of delivering digital and non-digital marketing but only concerning products and services we provide

Where a third party data processor is used, we ensure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under Data Protection Laws.

We may also disclose your personal data to third parties in the event that we sell or buy any business or assets or where we are required by law to do so. We also reserve the right to disclose information, to the legal authorities in the case of any claim or requirement to provide evidence to support formal legal proceedings.

Data Retention Periods

We keep your personal information in line with set periods calculated using the following criteria:

• How long you have been a customer with us and the number of treatments and level of advice we have provided
• How long it is reasonable to keep records to show we have met the obligations we have to you
• Any time limits for making a claim
• Any periods for keeping information which are set by law or recommended by regulators, professional bodies or associations
• Any relevant legal proceedings

Specific Retention Periods

Patients: We need to keep your Personal Data to allow us to ensure compliance with the contract. We keep a record of your Personal Data for at least 6 years after the contract has ended to ensure compliance with that contract. We will keep limited Personal Data of customers to include contact details and brief transactional history for longer than this 6 years period, as we have a legitimate business interest to keep such records, as many of our patients return to us several years later for our services and this assists our business to ensure that our patients are provided with the best possible service.

Enquiries: We will keep limited Personal Data to include your name, title and contact details when you make an enquiry about a treatment with us for up to six months in order to answer any follow up questions with you directly if you call back to discuss treatments.

Marketing: We will ask you at the time when you make an enquiry about our treatments and/or when you become a patient with us whether you consent to receiving targeted emails and/or phone messages from us regarding relevant treatment. We will only send you information if you agree to receiving it from us and can choose which is the best way to contact you. Of course, you have the right to unsubscribe at any time.

Recruitment: If you apply for a job with us, we may use your information for the purposes of recruitment and selection, corresponding with you and equal opportunities monitoring. We will not store your Personal Data for more than 12 months if you are not successful.

Cookies and Website Tracking

When on our website, cookies enable you to search and access features and information. From these cookies information may be collected to enable us to understand our customers and make improvements to how we present information and describe/provide our services.

What Are Cookies?

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user's device.

Types of Cookies We Use

Essential Cookies: These cookies are necessary for the website to function properly and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

Analytics Cookies: We use analytics cookies to understand how visitors use our website, including Google Analytics for website usage statistics, performance monitoring and improvement, and user experience optimization.

Marketing Cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.

Managing Cookies

You can control and manage cookies through your browser settings. However, disabling certain cookies may affect the functionality of our website. You can also opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.

Other Websites

Our Website may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of those websites, please note that those websites have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit any Personal Data to those websites.

Marketing Communications

In accordance with this Privacy Policy, we may send you information (via mail, email, phone or SMS) about our products and services which we consider may be of interest to you if you have agreed to receive such information.

You have the right to ask us not to process your information in this way at any time. If you no longer wish to receive web based marketing information you can unsubscribe by emailing us. For non-web based marketing information please write to us at our registered address. We would ask you to give us a reasonable amount of notice to give us time to update our systems. While the precise timings vary by department we generally ask that you give us at least 30 days' notice.

Your Rights Under GDPR

You have the right to access your information and to ask us to correct any mistakes and delete and restrict the use of your information. You also have the right to object to us using your information, to ask us to transfer information you have provided, to withdraw permission you have given us to use your information and to ask us not to use automated decision-making which will affect you.

You have the following rights (certain exceptions apply):

• Right of access: The right to make a written request for details of your personal information and a copy of that personal information
• Right to rectification: The right to have inaccurate information about you corrected or removed
• Right to erasure ('right to be forgotten'): The right to have certain personal information about you erased
• Right to restriction of processing: The right to request that your personal information is only used for restricted purposes
• Right to object: The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party's legitimate interest
• Right to data portability: The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable formats
• Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal information
• Right in relation to automated decisions: You have the right not to be subject to a decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you

Important Note: Other than your right to object to the use of your data for direct marketing, your rights are not absolute: they do not always apply in all cases and we will let you know in our correspondence with you how we will be able to comply with your request.

If you make a request, we will ask you to confirm your identity if we need to, and to provide information that helps us to understand your request better. If we do not meet your request, we will explain why.

Changes to This Policy

We keep our Privacy Policy under regular review and as a result it may be amended from time to time without notice. As a result, we encourage you to review this Privacy Policy regularly.

Contact Us and Complaints

If you have any questions about this Privacy and Cookie Policy or our data practices, please contact us:

Data Protection Officer

If you have any questions in relation to our privacy policy, please email us or write to our Data Protection Officer at the address above.

Right to Complain

You also have a right to make a complaint to your local privacy supervisory authority. Haemorrhoid centre is in the UK, where the local supervisory authority is the Information Commissioner: