Privacy notice for General Practitioners
- Why do we use your data? We typically use your personal information for purposes related to your relationship with Ramsay.
- Sharing data: We may share your data with third parties, including third-party service providers and other entities in the group and regulators.
- Security: We respect the security of your data and treat it in accordance with the law.
What is the purpose of this privacy notice?
- Under data protection legislation, Ramsay is required to explain why we collect information about you, how we intend to use that information and whether we will share your information with anyone else.
- It is important that you read this statement so that you know how and why we use information about you. It is also important that you inform Ramsay of any changes to your personal information so that the information which we hold is accurate and current.
- This privacy notice sets out information about the personal information that we, and third parties working in collaboration with Ramsay, may collect and hold about you, how that information may be used and your legal rights.
- This statement does not form part of any contract of employment or other contract to provide services.
Who are we?
- We are Ramsay Health Care UK Operations Limited, a company registered in England and Wales under company number 1532937 and with our registered office at Tower 42, Level 18, 25 Old Broad Street, London, EC2N 1HQ (“Ramsay”).
- We may be processing your Personal Data in accordance with applicable data protection legislation.
Our Data Protection Officer
- Our Data Protection Officer is responsible for overseeing what we do with your personal information and monitoring our compliance with data protection laws.
- Our Data Protection Officer is Geoff Cross. If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing at DataProtectionOfficer@ramsayhealth.co.uk
Who has access to my personal information?
- The following Ramsay’s legal entities and health care providers may process your personal information if necessary for a specified purpose and subject to the necessary safeguards being in place:
- The Westbourne Centre Birmingham Limited, with registered address Level 18, Tower 42, 25 Old Broad Street, London, United Kingdom, EC2N 1HQ, and with registration number 06558306;
- Independent British Health Care (Doncaster) Limited, with registered address Level 18, Tower 42, 25 Old Broad Street, London, United Kingdom, EC2N 1HQ, and with registration number 03043168;
- Clifton Park Hospital Limited, with registered address Level 18, Tower 42, 25 Old Broad Street, London, United Kingdom, EC2N 1HQ, and with registration number 11140716;
- Heath care providers providing health care services to Ramsay’s patients in our hospitals through services agreements. Those services include physiotherapy services, cosmetic surgery services, ophthalmology services, MRI services, and X-ray services; and
- The National Health Services (“NHS”).
What personal information do we hold about you?
The personal information we hold about you includes your name and contact details (postal and email addresses, phone numbers), your qualifications, and professional registrations. We may also hold more sensitive information about you in extremely limited circumstances, such as your physical or mental health, your religion, nationality, race and/or ethnicity. This special category of data is referred to as ‘more sensitive information’ in this Privacy Notice.
When will we use your personal information?
- We will request your consent to collect your personal information and possibly more sensitive information for marketing purposes in the following instances:
- Where you have indicated that you wish us to send marketing communications to you using your personal email address
- You have directly advised us you are registered as a sole trader or traditional partnership (not including corporate subscribers such as a corporation sole; a limited liability partnership or a company incorporated pursuant to a royal charter)
We may use your personal information to send marketing communications to you under legitimate interests to your NHS email address as a corporate subscriber. Ramsay may send relevant marketing communications to you for your legitimate interest such as educational events and CPD, new consultants and services and general newsletter updates. This information may be collected by our GP Liaison Officers or via a purchased database from Wilmington Healthcare. You may unsubscribe from these updates at any time using the opt-out link on any communications.
The necessary safeguards will be put in place at all times when handling any of your personal information. We may also use your sensitive information to ensure equal opportunity monitoring and reporting.
- We do not carry out automated decision making or profiling with any of your personal information.
Sharing your personal information with third parties
Our staff and third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our staff, or our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. Those specified purposes include:
- IT services;
- Management of units;
- Risk management system.
- Sharing information with professional advisors
- We may share your personal information with external lawyers, auditors, financial, tax and public relations advisors.
- Other companies in the Ramsay Group
- We may share your personal information with other entities in our group, for system maintenance support and hosting of data.
Storing your information and deleting it
- We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer for Ramsay, we will retain and securely destroy your personal information in accordance with our data retention policy.
- Under certain circumstances, by law you have the right to:
- Withdraw your consent with regard to a processing activity by Ramsay you originally agreed to;
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us 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 we are 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us 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.
- Request to not be subject to automatic decisions (ie decisions that are made about you by computer alone). We do not use profiling and/or make decisions about you based on wholly automated processing of your personal information.
Complaint to the ICO
- You also have the right to complain to the Information Commissioner's Office ("ICO") if you are not satisfied with the way we use your information. You can contact the ICO by writing to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Changes to this privacy statement
- We reserve the right to update this privacy statement at any time, and we will provide you with a new privacy statement when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.