ICO Registration Theorem Health Ltd ZA314942
Companies House 08116105
GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
Theorem Health Ltd is committed to protecting and respecting your privacy.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person Categories of data: Personal data and special categories of personal data
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
Theorem Health Ltd Managing Director is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: [email protected] 01789 400999, For all data matters contact (https://ico.org.uk/for-organisations/guide-to-data-protection/)
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- Recording your booking on our secure online appointment system
- Recording your email address to contact you about your appointment
- Recording your telephone no. to contact you about your appointment
- Recording you name, date of birth as identification for your medical notes
- Recording your email address for quarterly news or clinic updates
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal data [name, date of birth, telephone no. and email address]
5. What is our legal basis for processing your personal data?
a. Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
✓ Consent of the data subject; ( GDPR CONSENT FORM COMPLETED IN CLINIC )
✓ Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract – As required by law Theorem health Ltd and Service user company or Client Contract.
✓ Processing necessary for compliance with a legal obligation – as required by Law
✓ Processing necessary to protect the vital interests of a data subject or another person – Process of medical notes which may be required by other Health Professionals More information on lawful processing can be found on the ICO website.
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with parties that in conjunction with your health or personal needs.
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for a period of 5 years in order to conform to ICO data protection, Examples include: in case of any legal claims/complaints; for safeguarding purposes etc.
8. Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will have the following consequences that Theorem health Ltd would not be able to provide any health or therapy matters to yourself.
We require your personal data as it is a statutory requirement necessary to enter into a contract, that involves the recording of your medical pathway onto medical notes.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- [The right to withdraw your consent to the processing at any time, WHERE CONSENT WAS YOUR LAWFUL BASIS FOR PROCESSING THE DATA];
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
10. The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
11. Transfer of Data Abroad
[we do not transfer personal data outside the eea.]
12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our DATA PROTECTION OFFICER/OUR DATA REPRESENTATIVE on [email protected]
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.