General Data Protection Regulation (GDPR)

What is GDPR?

GDPR is a regulation which is intended to strengthen, unify and safeguard data for all individuals.

At Fitzwilliam Clinic, we are committed to ensuring the protection of your personal information. In accordance with GDPR guidelines, our aim is to have safeguards in place to protect your privacy and ensure that you feel confident about the security of the personal data which you provide to us.

Data Protection Privacy Notice – Patient Information

This privacy notice is to let you know how our clinic will look after your personal information. If we provide you with a medical or nursing service, then we will use your personal information in the ways set out in this privacy notice. Under data protection legislation, we can only process your personal information where we have a proper reason for doing so, such as:-

• it is in our legitimate interests to do so – for example a legitimate interest is when we have a reason to use your information to enable your consultant to provide treatment or care and order medical tests
• we are required to do so by law i.e a legal obligation
• you have entered a contract with us for a service – for example processing credit card payment
• in the public interest – where this has a clear basis in law
• vital interests – for example protection of life in a medical emergency

What Personal Data Do We Collect?

Personal data collected may include:-

• Patient’s name
• Title
• Date of birth
• Address
• Email address
• Emergency contact or next of kin information
• Information relative to your health i.e. allergies and past or present conditions
• Health + Care Number
• Contact telephone number
• Bank details
• GP name & address
• Private health insurance company, account number and authorisation code
• Medical records of your appointment/s and/or treatments at Fitzwilliam Clinic

Personal data is any information that is identifiable as belonging to you.

Fitzwilliam Clinic will request personal data from patients attending the clinic for an outpatient or theatre appointment, for the sole purpose of creating a medical file on the individual patient.

The personal information held on file may be shared with:

• The Consultant with whom the patient is attending
• The Medical Insurance Company with whom the patient is insured
• The Private Healthcare Information Network – we have a legal requirement under CMA Private Healthcare Market Investigation Order 2014 to provide data on some theatre procedures – when you attend the clinic, you have the option of anonymising this.

Why Do We Collect Data & Who Are The Recipients Of Data?

We collect data to provide details to the Consultant in charge of your care and to enable the Consultant to provide continuing care via the NHS / your General Practitioner.

Financial and health insurance data is collected for the purposes of payment for the services received.

Individual Rights Under GDPR

You have a number of rights under the data protection legislation in relation to the way we process your personal data, which are set out below:

• Right to be Informed – This is provided through the privacy notice on our website or is available via the Receptionist.
• Right of Access – You have the right to access your personal data and supplementary information. We will aim to respond to any request received from you within one month from your request, although this may be extended in some circumstances in line with data protection legislation.  If you wish to obtain access to your file, you must write to us at the address below.  Access to your data may incur a charge dependant on the volume of information requested to be copied as we are entitled to do so under data protection legislation.
• Right to Rectification – The right to ask us to correct your information if you think the information that we hold about you is wrong or incomplete. We will respond within one month.
• Right to Erasure – The right to object to our use of your information, or to ask us to delete, remove or stop keeping it if there is no need for us to keep it. This is known as the ‘right to object’, the ‘right to erasure’ or the ‘right to be forgotten’. There may however be legal or regulatory reasons why we need to keep or use your information.
• Right to Restrict processing – We may sometimes be able to restrict the use of your information so that it is only used for legal claims or to exercise legal rights. In these situations, we would not use or share your information while it is restricted.
• Right to Data Portability – The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services.
• Right to Object – Individuals have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority. There is a contractual requirement when patients attend Fitzwilliam Clinic for their personal data to be processed in order to provide medical care and treatment. You may object to the use of your personal data being given to the Public Healthcare Information Network (PHIN) – this can be anonymised and is provided for in the theatre admission process.
• Right not to be evaluated on the basis of automated processing – patients who attend Fitzwilliam Clinic will not be evaluated on the basis of automated processing nor is any decision making automated.

How long will the data be retained?

Data will not be retained for any longer than is required.

We will retain your medical records for 7-10 years, as required by our insurance provider and as required by regulations (Access to Health Records Legislation (NI) Order 1993 and Records Management – Good Management Good Records. DHSS revised October 2015).

Cookies & Links From Our Website

We may also collect information from you through the use of cookies. Cookies are small files which are stored on your computer browser. The cookie law is a piece of privacy legislation that requires websites to get consent from visitors to store or retrieve any information on a computer, smartphone or tablet for example, you may have a pop-up message informing you that this site uses cookies in combination with an acceptance/decline box, and it will be your decision whether you wish to accept or decline the use of the cookie.

Our website may contain links to other websites.  If you provide personal/sensitive data to a website to which we are linked to, we are not responsible for its protection and privacy. This privacy statement only applies to www.fitzwilliamclinic.com.

Contact details

If you wish to exercise any of the above, please write to:-

The Data Protection Officer
Fitzwilliam Clinic
70-72 Lisburn Road
Belfast
BT9 6AF

Data Protection Privacy Notice – Website

This website www.fitzwilliamclinic.com, and associated apps is owned and operated by Fitzwilliam Clinic.

In this Privacy Policy, when we refer to  the “Site”, we mean the digital network operated by Fitzwilliam Clinic.

Fitzwilliam Clinic is fully compliant with The General Data Protection Regulation (GDPR) (EU) 2016/679, which came into effect on May 25th 2018.

Right to Privacy

Fitzwilliam Clinic  respects your right to privacy and are transparent on what data we collect & how we use it. Any information we collect, be it non-personalised or personalised, will be treated with the highest standards of security and confidentiality, strictly in accordance with The General Data Protection Regulation. Fitzwilliam Clinic strictly only works with fully GDPR compliant partners.

Advertising Change of Consent

Fitzwilliam Clinic respects your right to choose. Consent revocation is the process by which EEA (European Economic Area) visitors who consented to personalized ads can revoke that consent.

Click here to revoke your choice

Collection and Use of Personal Information

Fitzwilliam Clinic uses some third party software and systems to carry out tasks related to the operation of the website – for example Google. A Data Protection Impact assessment has been carried out prior to any third party software being utilised, and data processing agreements have been entered into with all such service providers. The Fitzwilliam Clinic strictly only uses GDPR compliant service providers.

Fitzwilliam Clinic collects non-personalised and personalised data in three main ways:

Information that you actively volunteer or opt into, such as email newsletter registration, contacting us via digital methods.

Analytics: This allows Fitzwilliam Clinic to measure the number of visits to the website, how content is consumed and helps inform us as to how to improve the website for visitors.

Advertising: Fitzwilliam Clinic may use cookies or similar technologies to inform, optimise and serve ads based on your browsing activities and interests across our website & other digital platforms.

We never share first party / personally identifiable information from the Fitzwilliam Clinic website or associated apps with any third parties without your explicit consent.

The Information We Collect:

Advertising

The information collected by us for analytical and advertising on other platforms helps us to gauge the effectiveness of their campaigns, provide you with more relevant advertisements and may limit the number of times you see an advertisement. Upon visiting Fitzwilliam Clinic for the first time, you will have the choice to opt in for personalised or non personalised retargeting of marketing messages. You may change this choice at any time by visiting our Advertising Change of Consent in our Privacy Policy.

Email Contact by You

If you email Fitzwilliam Clinic with feedback or questions, we will respond to you as quickly as possible. Any details you send to us, including email and name, are stored for as long as is necessary to deal with your query. All contacts are deleted once we have satisfactorily answered your question or comment.

Services We Use

We use selected third party services on our website. We only use GDPR compliant services and partners.

Analytics Services

These services help us build a better website experience. We use Google Analytics, Firebase, Hotjar, for this purpose. Hotjar anonymises your IP and does not contain any personally identifiable information. Google Analytics and Firebase does capture some personal information, such as location information. Read their Privacy Policies & options on how to opt out by clicking on the links above. These companies do not share your data with any other companies. No personal data collected by any of the analytics services we employ will be disclosed to any other third party, unless obliged to do so by a rule of law or directly opted in to allow so by the user.

Advertising

When visiting our site, we offer the option to opt in for personalised or non personalised tracking for advertising purposes across third party platforms, such as Meta and Google. Any information collected and stored can be personalised or non-personalised; you have the option to choose your preference when visiting our website for the first time and you can change your preferences in our Privacy Policy. Some cookies are used for non personalised ads.

External Links

Fitzwilliam Clinic does provide links to other websites. Whilst we do check the validity of other websites and never link to any bogus websites, you should always check other website’s own Privacy Policies and Terms of Use.

Data Protection

We update our Privacy Policy from time to time as legislation and internal operating procedures change. Please keep an eye on this page for any updates or changes.

For further information, personal data access requests or if you have any queries please write to us at:

The Data Protection Officer
Fitzwilliam Clinic
70-72 Lisburn Road
Belfast
BT9 6AF

Whilst we aim to address any questions or queries as soon as possible, please allow up to 30 working days for a response.

For more information on data protection, please visit www.dataprotection.ie & https://ec.europa.eu/info/law/law-topic/data-protection_en

Last updated: 18/06/2024