Privacy Policy

UKS Privacy Notice

Who we are

UKS Health Group Limited t/a UKS Health Group ("we", "our", "us", “UKS”) is committed to protecting and respecting your privacy.  

For the purposes of data protection legislation, UKS and the healthcare providers who are responsible for your treatment (the “Clinicians”) are data controllers. UKS and the Clinicians are independent data controllers. This notice does not cover how the Clinicians process your personal data – the Clinicians should each provide you with a privacy notice setting out how they process your personal data.

This notice sets out details of the information that UKS may collect from you, how that information may be used, how the information will be stored and what your rights are in relation to this. We are required under data protection legislation to notify you of the information contained in this Privacy Notice.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

How to contact us

Our Data Protection Lead (“DPL”) is the Quality Manager and can be contacted via:

• Telephone: 0161 876 0016
• Email: dataprotection@uks-hg.com
• Post: FAO Data Protection Lead, 61 Washway Road, Sale, Cheshire, M33 7SS

If you would like further information about any of the matters in this Privacy Notice or have any other questions about how we collect, store or use your personal data, please contact the DPL using the details above.

Clinicians

If you are a patient of UKS, your treatment may be provided by a Clinician who is a medical practitioner, healthcare provider, part of a recognised medical facility or organisation or holds a recognised qualification to provide the required treatment.

The Clinicians make decisions about what information is collected about you, and may maintain their own set of medical records in relation to the treatment that they provide. They are the data controller in respect of the personal information they process, meaning that they must comply with the data protection legislation and relevant guidance when handling your personal data.

Where we collect your information from

We may collect information from you whenever you contact us or have any involvement with us, for example when you:

• visit our website;
• enter into a contract with us for the provision of healthcare services;
• use those services;
• complete an enquiry form on the our website, or submit a query to us by email or social media;
• correspond with us by letter, email, telephone or social media, including where you reference UKS in a public social media post; or
• take part in our marketing activities.

We may sometimes collect information from third parties, for example Clinicians (if you are a patient), your employer, insurance companies, solicitors or other legal representatives, medical agencies, occupational health companies and other referring professionals. If you are a patient, we collect information from these third parties to enable us to refer you to the Clinicians to conduct consultations, and to recommend and/or undertake treatments which may include clinical assessments, diagnostic investigations, pain management therapies, medical and surgical interventions.

This personal data may include identifiers such as names, contact details, and your date of birth. It may also include special category data such as medical information, including any healthcare you have received or need (either from the Clinicians or other healthcare providers).

How we use your personal information

We will use your personal information in a number of ways which reflect the legal basis applying to processing of your data. Most commonly, we will use your personal information in the following circumstances: 

• the processing is necessary for the performance of a legal obligation to which we are subject.
• you have provided your consent to our use of your personal information.

If you are a patient, we will use your personal information in the following circumstances in addition to the above:

• taking steps, at your request, so that you can enter into a contract with us to receive healthcare services from us.

• the processing is necessary for the performance of the contract between you and UKS.
• for the purposes of providing you with healthcare pursuant to a contract between you and UKS. We will rely on this for activities such as supporting your medical treatment or care and other benefits, supporting your Clinician, doctor, nurse, carer or other healthcare professional and providing other services to you.
• the processing is necessary to protect your vital interests.

If you are a patient and fail to provide your information further to a contractual requirement with us, we may be unable to set you up as a patient or facilitate the provision of your healthcare on UKS’s systems.

We will only use your personal information for the purposes for which we collected it, 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 notify you immediately and will seek your specific consent to use or disclose data for this new purpose. For further detail on the purposes we rely on to process your personal data, please see below.

Please note that we may process your personal information without your knowledge or consent, in compliance with the GDPR, where this is required or permitted by law.

If we rely on consent as the lawful basis to process your personal information, you may withdraw your consent at any time by contacting the Data Protection Lead. This will not affect the lawfulness of processing of your information prior to your withdrawal of consent being received and actioned.

Who do we share your information with?

We will not share information about you with third parties without your consent, unless the law allows us to.

From time to time, we may share your personal information with third parties in line with this notice. We require third parties to respect the security of your data and to treat it in accordance with the law.

We may disclose your information to the third parties listed below for the purposes described in this notice. This might include:

• Clinicians.
• A doctor, nurse, carer or any other healthcare professional involved in your treatment.
• Members of our support staff involved in the delivery of your care, for example receptionists or administrative staff.
• Anyone that you ask us to communicate with or provide as an emergency contact, for example your next of kin or carer.
• Other private sector healthcare providers.
• Your GP.
• Your dentist.
• Third parties who assist in the administration of your healthcare, such as insurance companies.
• Private Healthcare Information Network.
• Government bodies, including the NHS and HMRC.
• Regulators, like the Care Quality Commission, Health Inspectorate Wales and Healthcare Improvement Scotland.
• The police and other third parties where reasonably necessary for the prevention or detection of crime.
• Our insurers.
• Debt collection agencies.
• Credit referencing agencies.
• Our third-party services providers such as IT suppliers, actuaries, auditors, lawyers, marketing agencies, document management providers and tax advisers.

How long do we keep personal information for?

We only keep your information for as long as we need it or for as long as we are required by law to keep it. In respect of patient information we will retain this for 8 years (or until a patient’s 25^th birthday if a patient is a minor at the time of being our customer). In respect of all non-patient information we will retain this for a period of 6 years. Thereafter such information is automatically deleted.

How we keep your information safe

We understand the importance of keeping your personal information secure and take appropriate steps to safeguard it.

We always ensure only authorised persons have access to your information, which means only our employees and contractors, and that everyone who has access is appropriately trained to manage your information.

No data transmission over the internet can be guaranteed to be completely secure. So whilst we strive to safeguard your information, we cannot guarantee the security of any information you provide online and you do this at your own risk.

International data transfers

We (or third parties acting on our behalf) may store or process information that we collect about you in countries outside the European Economic Area ("EEA"). Where we make a transfer of your personal information outside of the EEA we will take the required steps to ensure that your personal information is protected.

We will only do so to the extent that it is relevant and necessary. The United States and the EEA have in place a framework, known as Privacy Shield, to facilitate compliance with data protection obligations when transferring personal data. Privacy Shield has been assessed by the EU Commission and deemed to provide adequate protection to personal data. 

If you would like further information regarding the steps we take to safeguard your personal information, please contact the DPL using the details at the top of the page.

Please note that we have listed above the current common transfers of personal data outside of the EEA, but it may be necessary, in future, to transfer such data for other purposes. In the event that it is necessary to do so, we will update this Privacy Notice.

Your rights

Under data protection law you have certain rights in relation to the personal information that we hold about you. You may exercise these rights at any time by contacting us using the details set out above at the top of the page.

Your rights include:

• The right to access your personal information
• The right to rectification
• The right to erasure (also known as the right to be forgotten)
• The right to restriction of processing
• The right to data portability
• The right to object to marketing
• The right to object to other uses of your personal data
• The right to withdraw consent

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.  You can do so by contacting the Data Protection Lead.

There will not usually be a charge for handling a request to exercise your rights. However, if you make a large number of requests, or it is clear that it is not reasonable for us to comply with a request, then we reserve the right to not respond. Alternatively, we may impose a charge for responding.

If at any time you are not happy with how we are processing your personal information, you may raise the issue with our Data Protection Lead. If you are not happy with the outcome, you may raise a complaint with the Information Commissioner’s Office, whose details are below:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.

How will we communicate with you?

In order to communicate with you, we are likely to do this by telephone, SMS, email, and/or post. We will only communicate with you via methods you have expressed preference for. We will communicate with you for the follow reasons:

• to provide you with timely updates and reminders in relation to your healthcare (including basic administration information and appointment information).  
• to provide you with your medical information (including test results and other clinical updates) and/or invoicing information.
• to send you patient surveys which are for the purpose of improving our service or monitoring outcomes.

Surveys

As detailed above, we may contact you to ask you to participate in surveys regarding your treatment with UKS and its Clinicians (where you have opted in for this). The surveys will be sent post-treatment by email or SMS. The survey is solely to gather information relating to your experience of UKS for the purpose of improving the quality and safety of the services we offer to our patients.

Participation in surveys is entirely voluntary, and you are under no obligation to reply to any survey you receive from us. Should you choose to do so, we will treat the information you provide with the same high standard of care as all other customer information.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time to ensure that it remains accurate. In the event that these changes result in any material difference to the manner in which we process your personal data then we will provide you with an updated copy of the Privacy Notice. We recommend that you read this notice each time you consider giving your personal information to us.

Last updated: November 2019

Date of next review: November 2020