In line with the new General Data Protection Regulation (effective from 25.5.18) require you to read the below Privacy Notice which clearly outlines how we use and store your personal data, in order to provide you with our services.
ANGELIS MEDICAL LTD (trading as GOLD ANGELS AESTHETICS LTD)
Data Privacy Notice Created: May 2018 V1
The purpose of this Data Privacy Notice is to outline ANGELIS MEDICAL LTD approach to responsibilities regarding the legal protection of data collected, handled and stored throughout the course of the Company’s business activities. It is also to ensure compliance to the European General Data Protection Regulations (GDPR).
ANGELIS MEDICAL LTD strive to ensure accountability and transparency with regards to the handling of personal data at all times.
The Company’s policies and procedures are designed to ensure that we provide data subjects with easily accessible and meaningful information to ensure that they know what personal data is collected about them, as well as why and how it is being processed, their rights in connection with that processing and the exercising of those rights. The Company is committed to the continuous improvement of the management of personal data.
Personal data means any information relating to an identified or identifiable natural person – known as a “data subject” – and can include, for example, names, ID numbers, location data, online identifiers and factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of a data subject. The data protection legislation also recognizes ‘special categories’ of personal data, the processing of which are subject to stricter regulation than other forms of personal data. This category of personal data includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data used to uniquely identify natural persons, data concerning health or data concerning an individual’s sex life or sexual orientation.
All activities relating to personal data (e.g. collection, structuring, alteration, storage, retrieval, consultation, use, adaptation, disclosure, erasure or destruction), whether using automated means or not, are known as “processing” for the purposes of the data protection legislation.
The data protection legislation makes a distinction between those who process data as “controllers” and those who process it as “processors” and imposes different obligations on controllers and processors. “Controllers” are individuals or organizations that determine the purposes and means of the processing of personal data. “Processors” are individuals or organizations that process personal data on behalf of a controller.
THE IDENTITY AND CONTACT DETAILS OF THE CONTROLLER (defined as ANGELIS MEDICAL LTD)
A data controller is a person or organization who determines the purposes for which and the way any personal data is to be processed. In the case of ANGELIS MEDICAL LTD the company acts as a controller. The contact details are as follows:
CONTACT DETAILS OF THE DATA PROTECTION OFFICER
Name: CHRISTOS ANGELIS
Tel: 0775 9461 298 / 020 3488 2014
Address: ANGELIS MEDICAL Limited, Southgate Office Village, 286a Chase Road, London, N14 6HF
PURPOSE OF THIS NOTICE
ANGELIS MEDICAL LTD provide medical services and is trading as GOLD ANGELS AESTHETICS LTD providing consultation, advice and aesthetic treatments to its clients and patients. The company collects and processes clients and patient’s personal data in order to enable appropriate care and treatment to assist with ongoing care and refer to other healthcare practitioners according to the clients and patients’ needs and to maintain the follow relationship and service provision following the securing of a role. You may give your personal details to the company directly, when enquire online via our website, or when you book an appointment for consultation, occasionally limited data are collected through social media.
Our process is to contact clients and patients and to discuss potential treatments and establish clients and patients interest and availability for a face to face consultation. Clients and patient’s details are retained on our database system and filed manually following strict security processes. Our database is paper based safely stored in secure protected area, and there is no clients and patient’s information being held on any online server. Access to the databased is only available to the doctor providing the consultation and consequently the treatment. Clients and patient’s details are retained on this databased for a reasonable time for as long as treatment is provided, for follow up and reminders of appointments and reviews of the effectiveness of treatment. These activities are recorded on the database to ensure accuracy of information and ongoing patient care.
This notice is to explain what ANGELIS MEDICAL LTD do with personal data – how we collect, use and process the data. It also outlines what our legal obligations are and what rights data subjects have.
This notice covers the personal data of ANGELIS MEDICAL LTD, clients, suppliers and website visitors and anyone that the Company may contact for any legitimate reasons required to carry out our business.
1. THE LEGAL BASIS FOR THE PROCESSING
ANGELIS MEDICAL LTD lawful Basis for the processing of your personal data is to pursue our legitimate business interests, described in more detail below, although we will also rely on the Lawful Basis of legal obligation and the Lawful Basis of consent for specific uses of data. We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
We will rely on consent for use of your data and in these circumstances, you will be asked for your express consent, whenever legally is required. Examples of when consent may be the lawful basis for processing include Special Category (sensitive information).
1. OUR LEGITIMATE BUSINESS INTERESTS
Our legitimate interests in collecting and retaining your personal data are described below:
The company provides aesthetic medical treatments and consultations to clients and patients and has a legitimate interest to process personal data in order to be able to provide these services – in doing so, the Company acts as a Data controller.
The Company needs to check the identity of clients and patients, accuracy of the information provided, as well as process payments and manage certain statutory rights. It is therefore in the legitimate interests of all parties involved (the clients and patients, the doctor providing treatment, advice or consultation and ANGELIS MEDICAL LTD to be able to process personal data.
3. PERSONAL DATA COLLECTED
Data is mainly collected directly from Data subjects – either by direct contact to us by phone or email, or web enquiry. Data may also come from third parties such as online or offline media research or referees. The following list is not exhaustive but includes personal data that may, dependent on specific circumstances, be needed to allow ANGELIS MEDICAL LTD to undertake its activities The company will only collect and process data that is deemed necessary and only in jurisdictions where there are no restrictions imposed, and will vary depending on which services you engage us to deliver and the payments process.
The personal information we collect:
- Date of birth
- Marital status
- Contact details (address, email, telephone number/s)
- National Insurance number
- General Medical Practice registration details
- Past Medical History details
- Employment details
- Diversity information
- Interview notes
- Proof of address
- Proof of ID (UK/Eu Passport/ID Card, non-EU Visa, birth/adoption certificate, marriage/civil partnership certificate, HMForces ID card, Firearms licence)
- Financial information including bank details (for background checks and/or payment)
- The dates, times and frequency with which you access our services – including notes on progress of treatment, consultations arranged feedback, treatments offered
- Notes regarding your treatments requirements and needs
- Any additional information as required by Health regulations (CQC for Healthcare practitioners)
- Digital Photographs of the before and after treatment areas
- Your IP address, which pages you may have visited on our website and when you accessed them.
- Any additional information you choose to provide
4. IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
If you do not provide certain information when requested, we may not be able to proceed with your treatments.
5. DATA STORAGE AND USE
When personal data is stored on paper or has been printed out for business reasons, it is always kept in a secure place with only authorized personnel having access. ANGELIS MEDICAL LTD apply the following business practices:
- When not required, the paper or files must be kept in a locked drawer or filing cabinet.
- Employees must ensure that paper and printouts are not left where visible to unauthorizedpeople.
- Data printouts should be shredded/disposed of securely when no longer required.
When data is stored electronically, it must be protected from unauthorized access, accidental deletion and malicious hacking attempts:
- Data is protected by strong passwords that are changed regularly and never shared.
- If data is stored on removable media (like a CD or DVD), these are locked away securely when not being used.
- Data is only stored on designated drives, and only be uploaded to approved cloud computing services.
- Drivers containing personal data are sited in a secure location, away from general office space.
- Data is backed up frequently and are tested regularly, in line with the company’s standard backup procedures.
- Where data is kept on laptops or other mobile devices like tablets or smart phones due to the requirement to provide services out of office hours, this will be removed as soon as there is no longer a legitimate business need to store it.
- All servers and computers containing data are protected by approved security software and a firewall.
Recognize that personal data if accessed could cause risk of loss, corruption or theft and apply the following:
- When working with personal data, employees must ensure that their computer screens are always locked when left unattended.
- Personal data should not be shared informally and never be sent by email.
6. WEBSITE USERS
ANGELIS MEDICAL LTD automatically collect data from the company website via cookies, as deemed useful to help improve user experience and manage the services provided.
This information includes:
- The frequency which individuals access our website
- The dates and times which individuals access our website
- Times when traffic is at its highest and lowest
- What information is viewed
- Browser types and locations viewed from
7. USE OF PERSONAL DATA
Personal details of clients and patients are collected and are generally used in the following ways:
Marketing activities: Processing personal data to ensure the receipt of relevant and targeted marketing materials and information
Invoicing and payment processes: Collecting bank details, or keep payment details in order to process payments for treatments and consultations provided
To assist in establishing, exercising or defending potential legal claims
8. CHANGE OF PURPOSE
We will only use your personal information for the purpose for which it was collected unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will advise you of this and explain the Lawful Basis for us doing so.
You should be aware that we may process your personal information without your knowledge or consent where this is required or permitted by law.
9. YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal information we hold about you is accurate and current. Please be sure to keep us informed if your iformation changes during your treatments or follow up with us.
We use sensitive personal information, these are special categories of personal data, and include information about your general health and medical conditions, these informationa are held by as because is by law obligations for healthcare service providers for health and safety purposes.
10. RECIPIENTS OF PERSONAL DATA
ANGELIS MEDICAL LTD use the services of a number of third party providers which may involve the processing of clients and patient’s personal data in the legitimate interests of conducting a safe medical treatment.
These may include:
- Our Company’s accountant and auditors
- Our Doctors and treatments or consultations providers
- Regulators such as the National Office of Statistics, Care Quality Commission
- Secure data storage centers
- Indemnity Insurance providers
- Medical Regulatory Organizations
- NHS England / Wales / Scotland / Northern Ireland
- NHS Regulatory bodies and frameworks as specified by contractual requirements
- Various suppliers of checking and vetting services as required for prescribed medications
Should we want or need to rely on consent to lawfully process your data we will request your consent by asking you to sign a Consent Form for the specific activity we require consent for and record your response on your file. Where consent is the lawful basis for us to provide our services, you have the right to withdraw your consent to this particular processing at any time, by completing a Withdrawal of Consent Form, which can be requested from our Data Protection Officer.
12. YOUR RIGHTS
The GDPR provides you with the following rights.
You have the rights to:
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information the company hold about you corrected
- Request to erase of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for the company continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below)
- Object to processing of your personal information where the company is 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
- Request the restriction of processing of your personal information. This enables you to ask the company to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in certain formats, if practicable.
13. ACCESS TO INFORMATION
The GDPR gives you the right to access and obtain the personal information held about you. This is known as a “data subject access request”. Your right of access can be exercised in accordance with the GDPR. A data subject access request should be submitted to firstname.lastname@example.org (No fee will apply under the terms of the GDPR.)
14. RIGHT NOT TO BE SUBJECT TO DECISION MAKING BASED SOLELY ON AUTOMATED PROCESSING
ANGELIS MEDICAL LTD recognize the data subject’s right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. However, this does not apply where the decision is:
- Necessary for the entering into or the performance of a contract between the data subject and a data controller
- Authorized by law and suitable safeguards are in place to protect the data subject’s rights and freedoms and legitimate interests; or
- Based on the data subject’s explicit consent
- Regarding (a) and (b), the data subject also has the right to obtain human intervention by the controller to express his or her views and to contest the decision
ANGELIS MEDICAL LTD providing of clients or patients treatments always involves human decision making and is never based solely on automated process. In order to analyses or predict suitability of the treatment offered or requested to meet the requirements of the client or patient we use medical evidence-based approach and decision making that involve both parties (practitioner – patient)
15. BREACH REPORTING
A personal data breach is a breach that results in the destruction, alteration or unauthorized disclosure or access to personal data.
ANGELIS MEDICAL LTD will make every effort to contain any personal data breaches identified and will also undertake an immediate assessment of any potential risks resulting from the breach in line with our data breach incident process. Should it be considered that there is a high risk to an individual because of the breach, then ANGELIS MEDICAL LTD will endeavor to inform the individual as soon as possible.
In such situations where you feel that a breach may have taken place then you must notify our Data Protection Officer immediately.
It is also the responsibility of our data controller to ensure that ANGELIS MEDICAL LTD has in place the necessary insurance provision in the event of a personal data breach or a cyber-attack.
16. RETENTION PERIOD AND CRITERIA USED TO DETERMINE THIS
ANGELIS MEDICAL LTD is registered with the Information Commissioner’s Office and all records retained by the company are done so in accordance with data protection laws. It is the policy of ANGELIS MEDICAL LTD to retain personal data where there is legitimate reason to do so; this reason is to assess and provide medical aesthetic treatments.
All hard copies of personal data are securely stored and then disposed of in confidential waste bins.
ANGELIS MEDICAL LTD mandate that no personal data is to be held for longer than necessary on company laptops, phones desktop computers or any other electronic devices and that all personal data received must be transferred to the company’s database system as soon as possible. All original records received via Outlook or any other electronic method, or paper-based documents received must be deleted or destroyed securely as soon as reasonably possible. Employees who fail to comply will be subject to disciplinary action.
The exception to this is data held by the ANGELIS MEDICAL LTD Compliance and Finance teams under the terms of the GDPR. This is defined as personnel and financial records that are required to run the company efficiently and to comply with statutory requirements. The company is not required to keep the original of all documents – copies can be stored but they must be stored in writing, including in electronic format.
The type of record will determine the length of time the record must be kept for and will be assessed in line with the legitimate business needs of the business, including the requirements of various client contracts in place from time to time.
17. CHANGES TO OUR PRIVACY NOTICE
This notice may be updated, revised, replaced and re-issued from time to time, to ensure it continues to meet all legislative requirements and relevant developments in data management and security techniques. Any changes to ANGELIS MEDICAL LTD data processing processes or this privacy notice will be brought to the attention of all data subjects.
Questions, comments and requests regarding this privacy notice are welcomed and should be sent to ANGELIS MEDICAL LTD in writing at email@example.com or ANGELIS MEDICAL LTD Address: ANGELIS MEDICAL Limited, Southgate Office Village, 286a Chase Road, London, N14 6HF Tel: 0775 9461 298 / 020 3488 2014
You also have the right to raise concerns or make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office.
The ICO can be contacted on 0303 123 1113 or at https://ico.org.uk/concerns/