Data Protection Privacy Notice for Patients

Introduction:
This privacy notice lets you know what happens to any personal data that you give to us, or any information that we may collect from you or about you from other organisations.
This privacy notice applies to personal information processed by or on behalf of the practice.
This Notice explains:
Who we are and how we use your information
Information about our Data Protection Officer
What kinds of personal information about you we hold and use (process)
The legal grounds for our processing of your personal information (including when we share it with others)
What should you do if your personal information changes?
For how long your personal information is retained / stored by us?
What are your rights under Data Protection laws
 
The UK General Data Protection Regulation (UKGDPR) and the Data Protection Act 2018 (DPA 2018) became law on 25th May 2018, and 1st January 2021 when the UK exited the EU.
For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (UK) 2016/679) (the “UKGDPR”), and the Data Protection Act 2018 Longevity Clinics Europe (UK) Limited is responsible for your personal data.
This notice describes how we collect, use and process your personal data, and how in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

How we use your information and the law.
Longevity Clinics Europe (UK) Ltd will be what’s known as the ‘Controller’ of your personal data.
We collect basic personal data about you and location-based information.  This does include name, address and contact details such as email and mobile number etc.
We will also collect sensitive confidential data known as “special category personal data”, in the form of health information, religious belief (if required in a healthcare setting), ethnicity and sex life information that are linked to your healthcare, we may also receive this information about you from other health providers or third parties.
Why do we need your information?
The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously.  These records help to provide you with the best possible healthcare and treatment.
Our health records are electronic in nature.  We use a combination of working practices and technology to ensure that your information is kept confidential and secure.
Records about you may include the following information:
Details about you, such as your address, your carer or legal representative and emergency contact details.
Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments.
Notes and reports about your health.
Details about your treatment and care.
Results of investigations such as laboratory tests, x-rays etc.
Relevant information from other health professionals, relatives or those who care for you.
Contact details (including email address, mobile telephone number and home telephone number).
To ensure you receive the best possible care, your records are used to facilitate the care you receive, including contacting you. Information held about you may be used to help protect the health of the public and to help us manage the services we provide. Limited information may be used within the GP practice for clinical audit to monitor the quality of the service we provided.
How do we lawfully use your data?
We need your personal, sensitive and confidential data in order to provide you with healthcare services as a CQC registered healthcare provider, under the General Data Protection Regulation we will be lawfully using your information in accordance with: –
Article 6, e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;”
Article 9, (h) processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems
This Privacy Notice applies to the personal data of our patients and the data you have given us about your carers/family members.
We use your personal and healthcare information in the following ways:
when we need to speak to or contact other doctors, consultants, nurses, or any other medical/healthcare professional or organisation during your diagnosis or treatment or ongoing healthcare; this includes the use of telephone or video consultation.
when we are required by law to hand over your information to any other organisation, such as the police, by court order, solicitors, or immigration enforcement.
In a de-identified form to support planning of our services and to improve our services.
We will never pass on your personal information to anyone else who does not need it, or has no right to it, unless you give us consent to do so.
Legal justification for collecting and using your information
The law says we need a legal basis to handle your personal and healthcare information.
Contract: We have a contract with you to deliver healthcare services to you. This contract provides that we are under a legal obligation to ensure that we deliver those services to you.
Consent: Sometimes we also rely on the fact that you give us consent to use your personal and healthcare information so that we can take care of your healthcare needs.
Please note that you have the right to withdraw consent at any time if you no longer wish to receive services from us.
Necessary care: Providing you with the appropriate healthcare, where necessary. The Law refers to this as ‘protecting your vital interests’ where you may be in a position not to be able to consent. 
Law: Sometimes the law obliges us to provide your information to an organisation (see above).
Special categories
The law states that personal information about your health falls into a special category of information because it is very sensitive. Reasons that may entitle us to use and process your information may be as follows:
Public Interest: Where we may need to handle your personal information when it is considered to be in the public interest. For example, when there is an outbreak of a specific disease and we need to contact you for treatment, or we need to pass your information to relevant organisations to ensure you receive advice and/or treatment.
Consent: When you have given us consent.
Vital Interest: If you are incapable of giving consent, and we have to use your information to protect your vital interests (e.g. if you have had an accident and you need emergency treatment).
Defending a claim: If we need your information to defend a legal claim against us by you, or by another party.
Providing you with medical care: Where we need your information to provide you with medical and healthcare services.
 
Meddbase
Longevity Clinics Europe (UK) Ltd uses Meddbase by Cority as our core electronic record keeping platform.
 
Heidi AI
In order to give our patients the best possible experience during consultations Longevity Clinics Europe (UK) Ltd uses a product known as ambient scribe technology provided by Heidi AI.
The primary purposes include improving clinical documentation, aiding healthcare professionals in notetaking, and generating consult summaries. Heidi technology enables clinicians to focus on patients during the consultation, contributing to improved patient care. It also acts as a valuable tool for medical practitioners, saving them hours of administrative time per week.
Heidi works by transcribing speech into text from a healthcare encounter such as conversations between clinicians and patients or by clinicians dictating their clinical findings, impression and/or management plans before, during and after the healthcare encounter. The clinician can also add additional contextual notes about the healthcare encounter.
This system is designed to alleviate the administrative burden on healthcare professionals, allowing them to focus more on patient care rather than paperwork. The Heidi Scribe will leverage natural language processing (NLP), speech recognition technology, and machine learning algorithms to understand and interpret complex medical dialogue, identify key health information, and categorise data into the appropriate sections of an Electronic Health Record (EHR).
Our clinicians use this tool by default and we will obtain your consent for using it.  Heidi also uses aggregated de-identified information from these consults to improve its models and outputs, ultimately improving both patient care and clinician experience.
All Data that identifies you stays within the practice and its servers which are UK based, no identifiable data is used by the Heidi tool for machine learning.
Heidi AI will not make decisions about your care, it only transcribes verbal interactions with the practice, with your consent.
More information about the model can be found on the Heidi website here: –
https://www.heidihealth.com/uk
 
Patient Communication
Because we are obliged to protect any confidential information, we hold about you and we take this very seriously, it is imperative that you let us know immediately if you change any of your contact details.
We may contact you using SMS texting to your mobile phone if we need to notify you about appointments and other services that we provide to you involving your direct care, therefore you must ensure that we have your up-to-date details. This is to ensure we are sure we are contacting you and not another person. As this is operated on an ‘opt out’ basis we will assume that you give us permission to contact you via SMS if you have provided us with your mobile telephone number. Please let us know if you wish to opt out of this SMS service. We may also contact you using the email address you have provided to us. Please ensure that we have your up-to-date details.
There may be occasions where authorised research facilities would like you to take part in research. Your contact details may be used to invite you to receive further information about such research opportunities.
 
Safeguarding
The Practice is dedicated to ensuring that the principles and duties of safeguarding adults and children are holistically, consistently and conscientiously applied with the wellbeing of all, at the heart of what we do.
Our legal basis for processing For the General Data Protection Regulation (GDPR) purposes is: –
              Article 6(1)(e) ‘…exercise of official authority…’.
For the processing of special categories data, the basis is: –
Article 9(2)(b) – ‘processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law…’
 
Categories of personal data
The data collected by Practice staff in the event of a safeguarding situation will be as much personal information as is possible that is necessary to obtain in order to handle the situation. In addition to some basic demographic and contact details, we will also process details of what the safeguarding concern is. This is likely to be special category information (such as health information).
Sources of the data
The Practice will either receive or collect information when someone contacts the organisation with safeguarding concerns, or we believe there may be safeguarding concerns and make enquiries to relevant providers.
Recipients of personal data
The information is used by the Practice when handling a safeguarding incident or concern. We may share information accordingly to ensure duty of care and investigation as required with other partners such as local authorities, the police or healthcare professionals (i.e. their GP or mental health team).
will use the data for the benefit of health and care and for the agreed purposes only
will handle and store the data securely
We only share data which can identify you (identifiable data) if this is absolutely necessary and the organisation who has made an application for data cannot achieve their purpose without it.  Where possible we remove information from the data which identifies you, or we replace it with a unique reference number (this is known as pseudonymisation).
Each organisation we share data with must sign a Data Sharing Framework Contract and a Data Sharing Agreement and we carry out audits to check they are using the data as agreed.
 
Practice Third party processors
In order to deliver the best possible service, the practice will share data (where required) with NHS bodies such as other GP practices and hospitals or other private sector providers. In addition, the practice will use carefully selected third party service providers. When we use a third party service provider to process data on our behalf then we will always have an appropriate agreement in place to ensure that they keep the data secure, that they do not use or share information other than in accordance with our instructions and that they are operating appropriately. Examples of functions that may be carried out by third parties include:
Companies that provide IT services & support, including our core clinical systems; systems which manage patient facing services (such as our website and service accessible through the same); data hosting service providers; systems which facilitate appointment bookings or electronic prescription services; document management services etc.
Delivery services (for example if we were to arrange for delivery of any medicines to you).
Payment providers (if for example you were paying for a prescription or a service such as travel vaccinations).
Further details regarding specific third-party processors can be supplied on request to the Data Protection Officer as below.

How do we maintain the confidentiality of your records? 
We are committed to protecting your privacy and will only use information collected lawfully in accordance with:
Data Protection Act 2018
The General Data Protection Regulations 2016
Human Rights Act 1998
Common Law Duty of Confidentiality
Health and Social Care Act 2012
NHS Codes of Confidentiality, Information Security and Records Management
Information: To Share or Not to Share Review 
 
Every member of staff who works for Longevity Clinics Europe (UK) Ltd has a legal obligation to keep information about you confidential. 
We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.” This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles.
Our Clinic policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the General Data Protection Regulation (GDPR) and all UK specific Data Protection Requirements. Our policy is to ensure all personal data related to our patients will be protected.
 
All employees and sub-contractors engaged by Longevity clinics Europe (UK) Ltd are asked to sign a confidentiality agreement. The practice will, if required, sign a separate confidentiality agreement if the client deems it necessary.  If a sub-contractor acts as a data processor for Longevity Clinics Europe (UK) Ltd an appropriate contract (art 24-28) will be established for the processing of your information.
 
In certain circumstances you may have the right to withdraw your consent to the processing of data. Please contact the Data Protection Officer in writing if you wish to withdraw your consent.  If some circumstances, we may need to store your data after your consent has been withdrawn to comply with a legislative requirement.
There are times that we may want to use your information to contact you or offer you services, not directly about your healthcare, in these instances we will always gain your consent to contact you.  We would however like to use your name, contact details and email address to inform you of other services that may benefit you.  We will only do this with your consent.  There may be occasions where authorised research facilities would like you to take part on innovations, research, improving services or identifying trends, you will be asked to opt into such programmes if you are happy to do so.
At any stage where we would like to use your data for anything other than the specified purposes and where there is no lawful requirement for us to share or process your data, we will ensure that you have the ability to consent and opt out prior to any data processing taking place.
This information is not shared with third parties or used for any marketing and you can unsubscribe at any time via phone, email or by informing the practice DPO as below.
 
Where do we store your information electronically?
All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information may be located on servers within the European Union.
No 3rd parties have access to your personal data unless the law allows them to do so and appropriate safeguards have been put in place such as a Data Processor as above).  We have a Data Protection regime in place to oversee the effective and secure processing of your personal and or special category (sensitive, confidential) data.
Who are our partner organisations?
We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations:
Randox Health
Independent Contractors such as dentists, opticians, pharmacists
Private Sector Providers
Voluntary Sector Providers
Ambulance Trusts
Multi Agency Safeguarding Hub (MASH)
Local Authorities
Fire and Rescue Services
Police & Judicial Services
Other ‘data processors’ which you will be informed of
 You will be informed who your data will be shared with and in some cases asked for consent for this to happen when this is required.

Computer System
This practice operates a Clinical Computer System (Meddbase by Cority) on which our Staff record information securely.  This information can then be shared with other clinicians so that everyone caring for you is fully informed about your medical history, including allergies and medication.
 
Sharing your information without consent
We will normally ask you for your consent, but there are times when we may be required by law to share your information without your consent, for example:
where there is a serious risk of harm or abuse to you or other people;
Safeguarding matters and investigations
where a serious crime, such as assault, is being investigated or where it could be prevented;
notification of new births;
where we encounter infectious diseases that may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS);
where a formal court order has been issued;
where there is a legal requirement, for example if you had committed a Road Traffic Offence.
 
How long will we store your information?
We are required under UK law to keep your information and data for the full retention periods as specified by the NHS Records management code of practice for health and social care and national archives requirements.
More information on records retention can be found online at:
https://transform.england.nhs.uk/information-governance/guidance/records-management-code/
 
How can you access, amend move the personal data that you have given to us?
Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to object: If we are using your data and you do not agree, you have the right to object. We will respond to your request within one month (although we may be allowed to extend this period in certain cases). This is NOT an absolute right sometimes we will need to process your data even if you object.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example for a research project, or consent to send you information about us or matters you may be interested in), you may withdraw your consent at any time.
Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within one month (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data but will need to keep a note of your name/ other basic details on our register of individuals who would prefer not to be contacted. This enables us to avoid contacting you in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this with a GP-to-GP data transfer and transfer of your hard copy notes.
 
Access to your personal information 
Data Subject Access Requests (DSAR): You have a right under the Data Protection legislation to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. To request this, you need to do the following:
Your request should be made to Longevity Clinics Europe (UK) Ltd.
There is no charge to have a copy of the information held about you
We are required to provide you with information within one month 
You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified, and your records located information we hold about you at any time.

What should you do if your personal information changes?
You should tell us so that we can update our records please contact the Practice Manager as soon as any of your details change, this is especially important for changes of address or contact details (such as your mobile phone number), the practice will from time to time ask you to confirm that the information we currently hold is accurate and up-to-date.
 
Online Access
You may ask us if you wish to have online access to your medical record. However, there will be certain protocols that we have to follow to give you online access, including written consent and the production of documents that prove your identity.
Please note that when we give you online access, the responsibility is yours to make sure that you keep your information safe and secure if you do not wish any third party to gain access.
 
Third parties mentioned on your medical record
Sometimes we record information about third parties mentioned by you to us during any consultation, or contained in letters we receive from other organisations. We are under an obligation to make sure we also protect that third party’s rights as an individual and to ensure that references to them which may breach their rights to confidentiality, are removed before we send any information to any other party including yourself.
 
Our website
The only website this Privacy Notice applies to is the Longevity Clinics Europe (UK) Ltd website. If you use a link to any other website from the Surgery’s website then you will need to read their respective Privacy Notice. We take no responsibility (legal or otherwise) for the content of other websites.
The Surgery’s website uses cookies. For more information on which cookies we use and how we use them, please see our Cookies Policy.
 
Video Consultations
The practice may use video consultations to see patients who may not need to attend the surgery in person, all such systems are fully compliant with best practice information governance and digital/cyber security checked. Longevity clinic Europe (UK) Ltd has statutory powers to process your data via this method of communication, are as above for direct care.
 
Medical Examiner Service
Following the death of any patients of Longevity Clinics Europe (UK) Ltd we are now obliged to inform the local NHS Trust Medical Examiner NHS Trust, Medical Examiner Service and the Care Quality Commission (CQC).
Medical examiner offices at acute trusts now provide independent scrutiny of non-coronial deaths occurring in acute hospitals.  The role of these offices is now being extended to also cover deaths occurring in the community.
Medical examiner offices are led by medical examiners, senior doctors from a range of specialties including general practice, who provide independent scrutiny of deaths not taken at the outset for coroner investigation. They put the bereaved at the centre of processes after the death of a patient, by giving families and next of kin an opportunity to ask questions and raise concerns. Medical examiners carry out a proportionate review of medical records and liaise with doctors completing the Medical Certificate of Cause of Death (MCCD).
 
Objections / Complaints
Should you have any concerns about how your information is managed at Longevity Clinics Europe (UK) Ltd, please contact us directly. If you are still unhappy following a review by Longevity Clinics Europe (UK) Ltd , you have a right to lodge a complaint with a supervisory authority: You have a right to complain to the UK supervisory Authority as below.
Information Commissioner:
Wycliffe house
Water Lane
Wilmslow
Cheshire 
SK9 5AF
Tel:       01625 545745
https://ico.org.uk/
If you are happy for your data to be used for the purposes described in this privacy notice, then you do not need to do anything.  If you have any concerns about how your data is shared, then please contact the Practice Data Protection Officer. 
If you would like to know more about your rights in respect of the personal data we hold about you, please contact the Data Protection Officer as below.
 
Data Protection Officer:
The Data Protection Officer is Paul Couldrey of PCIG Consulting Limited. Any queries regarding Data Protection issues should be addressed to him at:
Email: Couldrey@me.com
Postal:               PCIG Consulting Limited
                             7 Westacre Drive
                             Quarry Bank
                             Dudley
                             West Midlands
                             DY5 2EE
 
Changes:
It is important to point out that we may amend this Privacy Notice from time to time.  If you are dissatisfied with any aspect of our Privacy Notice, please contact the Practice Data Protection Officer.