Physiokinetic Limited (“us”, “we”, or “our”) operates the www.physiokinetic.co.uk website (the “Service”).
This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service.
Physiokinetic Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Physiokinetic Limited collects and processes your personal data, including any data you may provide through this website.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Physiokinetic Limited (Company Registration Number: 4843582) is the data controller and is responsible for your personal data (collectively referred to as Physiokinetic Limited, “we”, “us” or “our” in this privacy notice).
If you have a complaint about the way we are handling your personal data, please contact Michael Gosling by writing to Physiokinetic Ltd, Ground Floor, Crosby Court, 28 George Street, Birmingham, B3 1QG or by emailing: email@example.com or by calling 0121 440 7736.
If you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk).
CHANGES TO PRIVACY NOTICE
This version was last updated on 25/05/2018. Historic versions can be obtained by contacting us.
YOUR DUTY TO INFORM US OF CHANGES TO YOUR PERSONAL DATA
The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer the following kinds of personal data about you
- Identity Data includes first name, last name, marital status, title, date of birth and gender.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Aggregated Data We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
- Medical Data includes information about patients’ health and wellbeing which is classed as Special Category Personal Data. We use this information to provide treatment to you.
- We use a session cookie to keep track of user data across different requests. We may store personal information for a period where provided (e.g. submitted via a form) for the necessary function of the website.
- CSRF_TOKEN: This cookie protects against Cross Site Request Forgery (CSRF). A CSRF attack forces a logged-on victim’s browser to send a forged HTTP request, including the victim’s session cookie and any other automatically included authentication information, to a vulnerable web application. This allows the attacker to force the victim’s browser to generate requests the vulnerable application thinks are legitimate requests from the victim.
- __cfduid: The __cfduid cookie is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis. For example, if the visitor is in a public place where there are several infected machines, but the specific visitor’s machine is trusted (e.g. because they’ve completed a challenge), the cookie allows us to identify that client and not challenge them again. It does not correspond to any user ID in your web application and does not store any personally identifiable information.
- We use Google Analytics - Please see these links for details:
SPECIAL CATEGORY DATA
Additional protections are afforded to particularly sensitive personal data i.e. relating to persons’ race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sexual orientation.
We process data concerning our patients’ health and wellbeing. This is defined as special category data. In respect of this special category data we are required in addition to having a lawful basis for processing such data, to satisfy a separate condition for processing special category data. There are 10 of these additional conditions available under the GDPR itself, including where the processing is necessary for the purposes of medical diagnosis or providing healthcare. We are relying on this provision of healthcare condition and we have set out when it is relied on in Table A.
FAILURE TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel our services you have with us but we will notify you if this is the case at the time.
HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Medical, Identity, Contact and Financial Data by filling in our patient registration forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- complete our patient registration forms and apply for our services
- subscribe to publications
- sign up for tickets to our events via Eventbrite
- request marketing to be sent to you
- enter a competition, promotion or survey
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you to provide medical treatment.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below (Table A), a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so, including our legitimate interests. We have also set out our satisfaction of the condition for processing special category data where applicable.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Type of data
Lawful basis for processing, and condition for processing special category data
To register you as a new customer
To provide healthcare treatment services to you including:
To manage our business function including:
To manage our relationship with you which will include:
To enable you to partake in a prize draw, competition or complete a survey
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
To make suggestions and recommendations to you about goods or services that may be of interest to you
We want to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which information, newsletters and services for ease of reference, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased from us and you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing firstname.lastname@example.org directly.
CHANGE OF PURPOSE
We will only use your personal data 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 data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURE OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in Table A above.
- Other healthcare professionals and institutions who will be providing you with further care or managing your care including your GP, your private medical insurance company, your occupational health department, case management companies or solicitors who may be dealing with a claim on your behalf.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions, or in accordance with medical standards and practices.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data 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. A patients’ file will be retained for a period of eight years from the date of last treatment for adult records, and for children eight years after their 18th birthday or until 25 years of age.
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.
Your legal rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
INFORMATION WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIMESCALE FOR RESPONSE
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.