Thermalogica Health Screening customer privacy notice

Registered name: Thermalogica Ltd

This privacy notice tells you what to expect us to do with your personal information.

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Where we get personal information from
• How long we keep information
• Who we share information with
• Sharing information outside the UK
• How to complain

Contact details

Telephone – 01392 691 696 / 020 3745 1750
Email – clinic@thermalogicahealthscreening.co.uk

What information we collect, use, and why

We collect or use the following information to provide patient care, services, pharmaceutical products and other goods:

• Name, address and contact details
• Gender
• Date of birth
• Health information (including medical conditions, allergies, medical requirements and medical history)
• Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)

We also collect the following information to provide patient care, services, pharmaceutical products and other goods:

• Health information

We collect or use the following personal information to comply with legal requirements:

• Name
• Contact information
• Health and safety information

We also collect the following information to comply with legal requirements:

• Health information

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Address
• Account information
• Purchase or service history
• Information relating to health and safety (including incident investigation details and reports and accident book records)

We also collect the following information for dealing with queries, complaints or claims:

• Health information

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
  You can read more about this right here.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
• Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
• Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object.

To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object.

To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object.

To be clear, you do have the right to withdraw your consent at any time.

Where we get personal information from

• Directly from you

How long we keep information

We store information for 8 years after the last contact with the client, the conclusion of treatment or being notified of the patient’s death as prescribed by the British Medical Association.

Who we share information with

Data processors

Google Analytics - This data processor does the following activities for us: Google Analytics store some data about every visitor to our website, we can then view this data to see, for example, which blog posts are most popular with our readers. Google Analytics does not store any personal information, for example, it is impossible for it to know your name or address – the data we can see about who visited the website is anonymous.

Joint data controller

We have a joint controller relationship with Electronic Medical Interpretations (EMI). We process your personal information with that joint controller for the following reason:
Information collected is shared with EMI for the purpose on interpreting the thermal images to provide a report back the client.

Others we share personal information with

• Other health providers (eg GPs and consultants) at your request.
• Other professional consultants at your request.

Duty of confidentiality

We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:

• you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
• we have a legal requirement (including court orders) to collect, share or use the data;
• on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
• If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
• If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.

Sharing information outside the UK

Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name: Electronic Medical Interpretations
Category of recipient: Health Screening
Country the personal information is sent to: United States
How the transfer complies with UK data protection law: The country or sector has a UK data bridge (also known as Adequacy Regulations)

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to
us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you
can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint