CARE Privacy Notice

About this privacy policy

CARE Fertility Ltd (“CARE”) is committed to protecting the privacy of its users. This privacy policy explains how CARE will control and process any information that you supply to us or that is collected from you or is received about you.

If we change this Privacy Policy we will post an updated version of this Privacy Policy on the website to keep you aware of what Information is collected, how it is used and under what circumstances we may disclose it.

The Zita West Clinic is part of the CARE Fertility group, so all references to ‘CARE’ throughout our Privacy Policy also apply to the Zita West Clinic.

  

Why is this important?

We have a lot of information about you, and we need to look after it. We have both a legal and moral background to do our best to make sure the information we have is protected and used only when necessary, and only by the right people at the right time. We sometimes use the word “data” instead of information, but we mean the same thing.

CARE will always use your information in accordance with the permissions granted by you (your consent) and in accordance with GDPR and the Data Protection Act 2018.

Please note this Privacy Policy does not apply to communications you may have with a third party or if we use a third party to help provide a service (e.g. video conferencing).

 

Does CARE share your information with anyone else?

Yes. CARE works with a number of authorised third-party partners (blood testing laboratories for example), in order to deliver the services described on the Website. When we share your data with them, they are known as “data processors” and we have a written agreement in place explaining what we are sharing, why and what their obligations are. We also do background checks on their company history

 

What is a Data controller?

The organisation, which holds the information, and asks a data processor to do something with that data, is known as the Data Controller. CARE Fertility Group Ltd is the data controller for the purposes of the Act and can be contacted at John Webster House, 6 Lawrence Drive, Nottingham Business Park, Nottingham NG8 6PZ. 

As Data Controller, we are registered with the Information Commissioners Office, the ICO

Our ICO Registration Number is Z2170927

We have been registered with them continuously since 7 April 2010

 

What information do we collect about you?

CARE does need Information about you for a variety of reasons, including providing the treatment services that you request. These come from a variety of sources. For example, when you visit this website, we may collect certain information about your computer hardware and software, this includes:

  • Your IP address;
  • Browser type;
  • Operating system;
  • Access times; and
  • Referring website addresses

We do not store nor collect personal information from other sources, such as public records or private organisations.

We also collect information from the technology that is used to view our site which we use to analyse trends and administer the site. The data collected to enable us to do this is anonymous and does not identify you as an individual. This is done automatically, without asking you for the information.

 

What information might we be asking about you? 

You may send us, or we may ask you for information, or we may be sent information by a third party or we may create information as follows:

  • Your full name;
  • Your address and postcode;
  • Your contact information (such as your email address, telephone number and mobile telephone number);
  • General information about yourself (such as your personal or professional interests, your experience of our services and products or other services and products and your contact preferences);
  • Proof of Identification
  • In the event that you apply for a job with CARE, we will require further professional Information about you by way of a job application or your Curriculum Vitae; and
  • Special category data which is more sensitive, and can include your health, ethnicity, religion, sexual orientation, disability and biometric data including images.
  • As a patient, we will require all relevant information necessary for your treatment

CARE may, in limited circumstances, disclose your Information to third parties. These third parties may be other health care providers who will assist with your care;

  • In the event that you apply for a job with the CARE we may share your Information with third-party agents whom we use to assist us in the recruitment process; 
  • A third party or parties may be involved if CARE is under a duty to disclose or share your Information
    • to comply with any legal obligation (if directed by a court order for example)
    • or in order to enforce or apply CARE’s terms and conditions and other agreements (when collecting debts for example)
    • protect the rights, property, or safety of our patients, staff, or others. This includes exchanging information with other companies and organisations for fraud protection.

 

What will we use your information for?

CARE and/or our partners may use your Information in the following ways:

  • To provide a health care service where necessary including safeguarding;
  • To ensure that the content on our website is presented in the most effective manner for you and your computer;
  • To enable you to use the interactive features of our website;
  • For our internal record keeping;
  • To contact you to answer any queries you may have;
  • In the event that you apply for a job with CARE we will use any Information you submit by way of a job application or your Curriculum Vitae solely to assess your suitability for employment by us and to carry out any subsequent interview process. 

 

On what legal basis is CARE allowed to have (control) and process your information? 

In order for us to be allowed to have your data, we need to determine how we are allowed to use your information. This is known as a “legal basis”, and any organisation has a choice of six. If the organisation cannot use one of the six, it must not have the information. we have six to choose from: 

  • Consent
  • Provision of a Contract
  • Under a Legal Obligation
  • In your Vital Interests
  • Performance of a public task
  • Our legitimate interests

 

 

1)  Where you have provided CONSENT

We may use and process your personal information where you have consented for us to do so for the following purpose:

  • to supply information about CARE, its activities, reports and news, and for any marketing purposes.

 

Using Consent means we will be asking you beforehand, and recording your decision.  Regardless of your decision, your information will not be passed, sold or given to any third parties for the purposes of marketing. You may change or withdraw your consent for us to use your information in any of these ways at any time. Please see the “Withdrawing your consent” section.

 

2)   Where required to perform a CONTRACT with you 

There are times when we need your personal information to process where it is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract with you including for the following purposes:

  • As members of staff;
  • As contractors and sub-contractors

 

For example, you ask us for a brochure, we need your name and address in order to fulfil this part of the contract (ie send you the brochure)

 

3)  Where required to comply with our LEGAL OBLIGATIONS

At times, another Law requires us to collect, use, or share information- which manes we have a legal obligation to do so and do not have a choice. In this instance, examples include:

  • to assist HMRC, to prevent and detect fraud, for benefits and tax administration and as part of an appeal.
  • to fulfil our legal obligations under the Human Fertilisation and Embryology Act 1990 (HFE Act 1990) when providing fertility treatment to patients.
  • to identify you when you contact us; and
  • to verify the accuracy of data that we hold about you.

 

With CARE Fertility, your Health data will be processed by CARE using this legal basis once you become a patient- we are required by the HFE Act 1990 to do so.

 

4)  Where it is in your VITAL INTEREST

We may use your personal information without your consent if we consider it in your vital interests to do so. In other words, using your information in this way will prevent or reduce any potential harm to you.

 

5)  Where we are performing a PUBLIC TASK

Whilst this is one of the legal bases available to us, CARE will not be using public task as a basis for using your personal information

 

6)     Where there is a LEGITIMATE INTEREST

CARE will be using legitimate interest as a basis for using your personal information when you make contact with us or request information from us, and will be used until you become a patient of ours. Once you become a patient, we have a LEGAL OBLIGATION to process your information to provide patient services.

 

How we look after your “special category” of information

In addition to the six legal bases above, we recognise that the information we have about your health is known as “special category” information” and we need to take even more care over it then if we just had your personal information.

The law states that we have to choose one of nine legal bases. As a patient, we will be using “medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems” when providing treatment. 

 

CARE will also use your personal information about your health for reasons including:

  • Activity monitoring
  • Local clinical audit
  • Production of datasets for NHS commissioning purposes and national collections
  • Responding to a public health emergency.

 

CARE might also use special categories of personal information for research. This might include medical data, ethnicity, faith, gender and biometric information.  For this we will use part 9(2)(j) of the law which allows us to conduct proportionate research or for statistical purposes.

 

When using your special category personal data we will use it in accordance with UK law and provide suitable and specific measures to safeguard your fundamental rights and interests.

 

How we use your information to Support direct care

We use your personal information to provide healthcare to you, and to help with that healthcare (for example, booking and managing your appointments). Your information may be used for clinical audit, where the team involved in your care will check the quality and results of the treatment provided. Your information may also be used to investigate incidents and complaints. 

 

How we use your information to Support other medical uses 

We may use information about you, and the healthcare that you have received, to improve the care that we provide to all patients. This includes medical research, monitoring and improving our services, and for medical purposes where we believe the public will benefit.

When information is shared outside the team that cared for you, we take out any details that would identify you, unless we have your permission. 

 

 

What are your rights as a data subject?

You have a number of rights in relation to your personal information under the data protection laws. In relation to these rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received this information or, where no such information is required, after we have received your request. 

What about accessing your personal information? 

You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information. 

 

7)   What about correcting and updating your personal information?

The accuracy of your information is important to us and if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the contact details in this policy.

Please note that while CARE  will endeavour to make the updates as promptly as possible, communications may be sent using the original details until the changes have been processed.

 

8)    What about withdrawing your consent? 

Where we rely on your consent as the legal basis for processing your personal information, as set out under “How your information is used”, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to which you previously opted in, you can also do so by contacting us either by telephone, post or e-mail. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

 

9)   What about objecting to our use of your personal information and automated decisions made about you? 

Where we rely on our public task as the legal basis for processing your personal information for any purpose(s), as mentioned in the “How we use your personal information” section, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.  Your right to object will not apply where the information is being used for research or statistical purposes. 


You may also contest a decision made about you based on automated processing by contacting the data protection department.

 

10)  What about erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal information in the following situations:

  • where you believe it is unlawful for us to do so;
  • where you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.

 

In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for your health, for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

 

11)What about transferring your personal information in a structured data file 

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under “How we use your personal information”, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV file. 

You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

 

Do we use your information for Marketing?

From time to time, and where you have given your permission to do so, CARE may wish to contact you about marketing.

We will only contact you if you have consented. If you decide you do not want to receive those marketing communications, you can unsubscribe using the following methods: 

By writing to the Data Controller at our registered office address:

John Webster House, 6 Lawrence Drive, Nottingham Business Park, Nottingham NG8 6PZ.

On each marketing communication there will also be an opportunity for you to unsubscribe.

 

How long do we hold onto your data?

CARE follows a Corporate retention and destruction Policy which is in line with our legal obligations under the HFE Act 1990.

 

How do we store your information? 

The Information that CARE collects from you may be transferred to and stored at a destination outside CARE by a third party. CARE has taken all steps reasonably necessary to ensure this data is stored and processed in line with GDPR and this Privacy Policy.

 

Website security/cookies

Our website may contain links to other websites run by other organisations which we do not control. This policy does not apply to those other websites and apps‚ so we encourage you to read their privacy statements. We are not responsible for the privacy policies and practices of other websites and apps (even if you access them using links that we provide) and we provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.

Similarly, we may offer you services which are hosted by a third party (such as webinars, live social Q&A events and others). These are provided by a third party which we do not control. This policy does not apply to those other websites and apps‚ so we encourage you to read their privacy statements. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.

In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

 

Cookies

We use cookies on our Website for analysis and to help administer the site. The data collected to enable us to do this is anonymous and does not identify you as an individual.

 

How do you report fraud to us?

We are committed to ensuring your Information is secure. As part of our efforts to protect your Information, CARE will never send you emails asking for your personal Information. 

If you do receive such an email or are asked to disclose this information by someone claiming to work for CARE please report the communication to our Data Controller using the following methods:

Using the ‘contact us’ page or

By writing to the Data Controller at our registered office address: John Webster House, 6 Lawrence Drive, Nottingham Business Park, Nottingham NG8 6PZ.

 

Will we make changes to this policy?

We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy when you visit our website. If you do not agree with any aspect of the updated policy, you must promptly notify us and cease using our services.

 

How do you request information or make a complaint?

If you have any questions, suggestions or complaints about the processing of your personal information or wish to contact us to amend/update your information or if you wish to access the information we hold about you, please contact us using the details below:

 

Data Protection Officer

John Webster House,

6 Lawrence Drive,

Nottingham Business Park,

Nottingham

NG8 6PZ

dpo@carefertility.com

 

If you have any queries or concerns about how we use your information, please speak to the staff involved in your care. More detailed questions about how we use your information which cannot be discussed or resolved by a member of staff can be discussed with the Clinic Director at your chosen CARE clinic

 

How do I Complain to the UK data protection regulator?

You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details or use the contact details below. 
Information Commissioner’s Office
Wycliffe House
Wilmslow
SK9 5AF
Email: www.ico.org.uk/global/contact-us/email 
Website: www.ico.org.uk/