Privacy Notice for Website Visitors

Newson Health Limited      

Privacy Notice for Website Visitors

The following information forms part of our Privacy Notice. It sets out what personal information we may collect from you and how that information may be used when you make an enquiry to us or use Newson Health’s websites, www.newsonhealth.co.uk and www.menopausedoctor.co.uk.

Links to other Websites

Our websites may contain 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 Notices. When you leave our website, we recommend that you read the Privacy Notice of any website you visit.

The Personal 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). The extent of the information that we collect, and use will partially  depend on what information you choose to provide to us or what information is provided to us on your behalf.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data: includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
  • Contact Data: includes billing address, delivery 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 products and services you have purchased from us;
  • Technical Data: includes internet protocol (IP) address, your 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;
  • Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
  • Usage Data: includes information about how you use our website, products and services.
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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.

Special Categories of Personal Data

Special Category Personal Data specifically means personal data relating to your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.

When you interact with us via our website, such as when you send us an enquiry or request a prescription or consultation,  we may collect Special Categories of Personal Data about you.  In this context we are likely to collect the following special categories of personal data relating to you:

  • Information about your health such as details of medical conditions, medication, weight, lifestyle and other information that may be relevant to your health e.g. employment history, family conditions; race; ethnicity; sex life or sexual orientation, religious or philosophical beliefs.
  • in limited circumstances, we may process other sensitive personal information including details of your political opinions; and trade union membership, for example, where it is relevant to your health or social history

We do not routinely collect any information about criminal convictions (including offences and alleged offences and any court proceedings or sentence) unless you give this sort of information to us.

 

If you provide us with personal information about others

If you provide personal information to us about other individuals (including medical or financial information) you should inform the individual about the contents of this Privacy Notice. We will process such information in accordance with this Privacy Notice.

 

If you fail 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 goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

 

Where do we collect your Personal Data from?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your personal data when you fill in and submit our online enquiry form by corresponding with us by email or otherwise. This includes personal data you provide when you:
    • Send us a message via our website or any of our social networking channels;
    • apply for our products or services, including requesting a prescription, booking a consultation or therapy appointment;
    • subscribe to our service or publications, including submitting a request to join our mailing list;
    • request marketing information to be sent to you;
    • take part in an online promotion, competition or survey;
    • give us feedback; or
    • contact us.

 

  • Automated technologies, interactions and cookies. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. We use Google Analytics and cookies in order to improve our websites, service and user experience and to understand how our websites are used. Aside from the approximate location (IP address), the information collected by Google Analytics is anonymous traffic data including browser information, device information, and language. The collected information is used to provide an overview of how people are accessing and using our websites. Further information about how our cookies collect and use personal information can be found at https://menopausedoctor.co.uk
  • Third parties and publicly available sources. In most cases, the personal data we collect will come directly from you. However, in limited circumstances we may receive information about you provided by a third party on your behalf, such as a family member or other health professional.

 

How we Use your Personal Data

We will process your personal information in accordance with this Privacy Notice and only where we are legally permitted to do so. Data protection law requires us to have a legal basis to justify using your personal data. The legal basis we use will vary, depending on why we are using your personal data. If we process  "special categories of personal information", we must have an additional legal basis to justify using it.

The information  below identifies the various purposes for using your personal data and the legal basis for doing so.

 

Purpose: Providing Healthcare and Related Services

Legal Bases:

  • Where the use is necessary to fulfil our contractual obligations for the delivery of your healthcare or in order to take steps at your request prior to entering into a contract.
  • Where the use is necessary for our legitimate interests including running our business and delivering our goods and services,  providing theses interests are not overridden by your privacy rights and freedoms.

Additional legal bases for special categories of personal data:

  • Where the use is necessary for the purposes of preventative medicine, medical diagnoses, the provision of healthcare or treatment or the management of healthcare systems and services.
  • Where the use is necessary to protect your vital interests where you are physically or legally incapable of giving consent.
  • Where the use is necessary for reasons of substantial public interest based upon law. For example, to deal with insurance-related matters or fraud prevention and detection.

 

Purpose: Administration and management of our products and services including taking external professional advice, insurance, management of fees, recovery of unpaid fees and use of third party service providers to help deliver our products and services.

Legal Bases:

  • Where the use is necessary to fulfil our contractual obligations for the delivery of your healthcare or in order to take steps at your request prior to entering into a contract.
  • Where the use is necessary for our legitimate interests including the administration, protection and development of our business, providing these interests are not overridden by your privacy rights and freedoms.
  • Where the use is necessary in order for us to comply with a legal obligation.

Additional legal bases for special categories of personal data:

  • Where the use is necessary for the purposes of preventive medicine, medical diagnosis, the provision of healthcare or treatment or the management of healthcare systems and services.
  • Where the use is necessary in order for us or a third party to establish, exercise or defend our legal rights.
     

Purpose: Improving our services including reviewing and auditing our services

Legal Bases:

Additional legal bases for special categories of personal data:

  • Where the use is necessary for the purposes of preventive medicine, medical diagnosis, the provision of healthcare or treatment or the management of healthcare systems and services.
     

Purpose: Communicating with you (or another person you have asked us to communicate with about your healthcare) including handling a complaint.

Legal Bases:

  • Where the use is necessary for us to comply with a legal obligation.
  • Where the use is necessary to fulfil our contractual obligations for the delivery of your healthcare or in order to take steps at your request prior to entering into a contract.
  • Where the use is necessary for fulfilling our legitimate interests including communicating with you and others regarding your healthcare and for the resolution of queries and complaints,  providing those interests are not overridden by your privacy rights and freedoms.
  • Where you have given us your explicit consent.

Additional legal bases for special categories of personal data:

  • Where the use is necessary for the purposes of preventive medicine, medical diagnosis, the provision of healthcare or treatment or the management of healthcare systems and services.
  • The use is necessary in order for us or a third party to establish, exercise or defend our legal rights.
  • You have given us your explicit consent.
     

Purpose: Complying with our legal obligations and regulatory requirements

Legal Bases:

  • Where the use is necessary for us to comply with a legal obligation.
  • Where the use is necessary for fulfilling our legitimate interests including compliance with relevant statutory, regulatory or legal requirements, providing those interests are not overridden by your privacy rights and freedoms.

Additional legal bases for special categories of personal data:

  • Where the use is necessary for the purposes of preventive medicine, medical diagnosis, the provision of healthcare or treatment or the management of healthcare systems and services.
  • Where the use is necessary in order for us to establish, exercise or defend our legal rights.
     

Purpose: Safeguarding 

Legal Bases:

  • Where the use is necessary for us to comply with a legal obligation.
  • Where the use is to protect your vital interests or the vital interests of a third party.

Additional legal bases for special categories of personal data:

  • Where the use is to protect your vital interests or the vital interests of a third party and you or the third party are physically or legally incapable of giving consent.
  • Where the use is necessary for reasons of substantial public interest on the basis of law. For example, where it is necessary for health and safety purposes or to protect any individual from neglect or harm.

 

Purpose: Preventing and investigating fraud. This might include sharing your personal information with third parties such as the police or fraud prevention agencies, or carrying out fraud, credit, anti-money laundering and other checks

Legal Bases:

Additional legal bases for special categories of personal data:

  • Where the use is necessary for reasons of substantial public interest on the basis of law. For example, where we are legally required to process your personal data for the purposes of the prevention and detection of crime.

 

Purpose: Marketing our products and services to you including sending you marketing information by post, email and telephone. To enable you to take part in competitions and surveys.

 Legal Bases:

  • Where the use is necessary for fulfilling our legitimate interests including carrying out marketing campaigns, competitions and surveys, providing those interests are not overridden by your privacy rights and freedoms.
  • You have given us your consent. We will not process your personal data for the purposes of any unsolicited direct marketing carried out electronically, without your specific consent.

Additional legal bases for special categories of personal data:

  • You have given us your explicit consent

 

Purpose: To administer and protect our business and websites including troubleshooting, data analysis, testing, system maintenance and updates, system support, reporting and hosting of data

Legal Bases:

  • Where the use is necessary for fulfilling our legitimate interests such as running our business, providing and maintaining our IT services and network security and to prevent criminal attacks on our systems,  providing those interests are not overridden by your privacy rights and freedoms.

 

Purpose: To use data analytics to improves our websites, products and services, marketing initiatives, relationships with our clients and customer experience.

Legal Bases:

  • Where the use is necessary for fulfilling our legitimate interests such as running and improving our business, identifying our clients and potential clients, keeping our websites and other platforms updated and relevant and to develop and inform our business and marketing strategy,  providing those interests are not overridden by your privacy rights and freedoms.

 

Marketing Communications

We will use your personal information to send you our marketing communications only in the following circumstances:

  • Where you have specifically asked us to send you the marketing information in question
  • Where you have consented to us sending you our marketing communications.

You can alter the channels through which we send you marketing such as email, post and telephone by emailing info@newsonhealth.com

If we are sending you marketing communications based on your consent, you have the right to withdraw your consent at any point in time by . To withdraw your consent please follow the opt-out links on any marketing message sent to you or contact info@newsonhealth.co.uk

Withdrawal of consent to receive our marketing communications will not affect the processing of personal data for the provision of our services.

We will never share your personal information with a third party for their own marketing.

 

Who Do We Share Your Personal Data With?

We may share your personal data with third parties listed below for the purposes set out  above (Purposes/Legal Bases). Where your personal data is shared, it is shared securely and strictly in accordance with the law.

  • Our clinicians or other healthcare professionals involved in your care or treatment;
  • Other members of our staff involved in your care or treatment such as a Practice Manager, administrators, secretaries and receptionists;
  • With your consent or other legal ground, we may securely share your medical information and other personal data with doctors, consultants and other professionals, who are not employed by us. These individuals will be subject to their own statutory duty of confidentiality and your data will be shared strictly in accordance with data protection laws;
  • External companies providing services such as blood tests, analysis of tissue samples, such as biopsies. This information will be shared only with your express consent or other lawful basis.
  • Other healthcare service providers within the private sector;
  • NHS organisations and their private sector service providers such as your GP, NHS Resolution, NHS England, Clinical Commissioning Groups, NHS Trusts, or the Department of Health;
  • HM Revenue and Customs, regulators such as the Care Quality Commission and the Information Commissioner’s Office (ICO) and other authorities based in the UK and other relevant jurisdictions who require us to report processing activities in certain circumstances.
  • The police and other regulatory third parties in connection with the prevention and detection of crime or for safeguarding purposes;
  • Our third party service providers such as our IT services provider, document storage providers, digital dictation service, marketing and email providers (Mailchimp and Microsoft). These third party service providers are required to process your personal data only on our instructions, securely and in accordance with relevant EU or UK data protection laws;
  • Third party professional advisors including lawyers, accountants, auditors and  insurers.
  • Debt recovery agencies and credit reference agencies;
  • Anyone that has been appointed  you have asked to communicate with us on your behalf such as your insurer,  individuals you have named as an emergency contact, such as your next of kin;
  • Third parties to whom we may sell, transfer or merge parts of our business or assets.

 

Other General Information About How We Process Your Personal Data

For general information about we collect and process your personal data including for example, how we keep it secure,  how long it is retained, your legal rights and who to contact if you have any questions about this Privacy Notice or your personal data, please click here.