1. IMPORTANT INFORMATION AND WHO WE ARE
Dementech Neurosciences is committed to safeguarding the privacy of our website visitors and this policy sets out how we will treat your personal information. Our policy complies with UK law accordingly implemented including that required by the EU General Data Protection Regulation (GDPR).
The Dementech Neurosciences privacy notice sets out the legal basis for processing special category health data gathered from Dementech Neurosciences Ltd. Article 9 (2) exemption for processing the health data applies in this instance, as the processing falls within the Data Protection Act 2018 Schedule 1, Part 1, s 2 (1) and (2) (c), (d) and (f) processing for ‘Health and social care purposes’. Dementech Neurosciences will ensure the processing of any data must be ‘necessary’ to fall within this exemption and will be targeted and proportionate.
In relation to the special category personal data (i.e., the health data) for customers who are part-way through treatment programmes, or who are within the scope of follow up aftercare following their initial consultation and treatment, the personal data will be shared with Dementech Neurosciences on the legal bases of (i) performing a contract and (ii) legitimate interests and (iii) the ‘Health and social care purposes’ exemption mentioned above.
Where the personal data relates to customers who have completed their consultation/treatment and where there has been a reasonable lapse of time since they have been dealt with by Dementech Neurosciences ltd i.e., historic customer data, Dementech Neurosciences will only access this data where it is; “necessary” to assist the patient with ongoing care, for other health-related reasons, requested for legal purposes or requested by the patient themselves.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Dementech Neurosciences collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.
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.
Dementech Neurosciences Limited is the controller and responsible for this website.
We have appointed a Registered Manager who is accountable for the management of all Information assets and any associated risks and incidents, and acts as a Caldicott Guardian who is responsible for the management of patient information and patient confidentiality. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Registered Manager using the details set out below.
Our full details are:
Full name of legal entity: Dementech Ltd, which is a company registered in England and Wales under the company number 10367905 and whose registered address is Lister House, 11 Wimpole Street,, London, W1G 9ST
Contact email address: firstname.lastname@example.org
Postal address: Dementech Neurosciences, Lister House, 11 Wimpole Street,, London, W1G 9ST
Telephone number: 0203 848 4500
Opening Hours: The office opening hours are between 8.00am to 8.00pm Monday to Sunday
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES CONCERNING YOUR PERSONAL DATA
This version was last updated on November 2019.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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 and their website terms and conditions. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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.
2. THE 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 different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, surname, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes a 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, 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 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.
We do collect Special Categories of Personal Data about you which includes information about your health, genetic and biometric data but only as required in order to offer you our services.
We do collect any information about criminal convictions and offences.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Make an enquiry about our services;
- Subscribe to our service;
- Request marketing to be sent to you;
- Enter a survey; or
- Give us some feedback.
- Automated technologies or interactions.
- Web beacons: We also include web beacons (also known as clear gifs) in our emails to track the success of our marketing campaigns. This means that if you open an email from us we can see which pages of the websites you visit. Our web beacons do not store additional information on your computer but by communicating with our cookies on your computer they can tell us when you have opened our email. If you object to web beacons, we recommend you follow the instructions for deleting existing cookies and disabling future cookies above. We will still know how many of our emails are opened and we will automatically receive your IP address, a unique identifier of your computer or other access device, but we will not identify you as an individual.
- Third parties or publicly available sources. We may receive personal data about you from various third parties:
- Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU; they may provide us with special categories of personal data.
4. HOW WE USE YOUR PERSONAL DATA
Dementech Neurosciences collects and stores large amounts of personal data every day, such as medical records.
We take our duty to protect your personal information and confidentiality very seriously and are committed to taking all reasonable and required measures to ensure the confidentiality and security of personal data for which we are responsible, whether computerised or on paper.
At Dementech Neurosciences, we have appointed a Registered Manager who is accountable for the management of all Information assets and any associated risks and incidents, and acts as a Caldicott Guardian who is responsible for the management of patient information and patient confidentiality.
The healthcare professionals caring for you keep records about your health and any care you receive from them at Dementech in order to ensure that the highest standard of care is delivered. These records may include
- Basic details about you such as name, address, date of birth, next of kin, etc.
- Contact we have had with you such as appointments or visits and/or notes about your health, treatment and care
- Test/Exam results
- Relevant information from people who care for you, look after you and know you well, such as health professionals and/or
It is essential that your details are accurate and up to date. Always check that your personal details are correct when you visit us and please inform us of any changes as soon as possible.
Your records are used to direct, manage and deliver the care you receive and ensure that:
- The healthcare professionals involved in your care have accurate and up to date information to assess your health and decide on the most appropriate care/treatments for you
- Healthcare professionals have the information they need to assess and improve the quality and type of care you receive
- Your concerns can be properly investigated if a complaint is raised
- Appropriate information is available if you see another doctor or are referred to another specialist at Dementech
Your information may also be used to help us improve Dementech’s services by:
- Reviewing the care we provide to ensure it is of the highest standard and quality
- Ensuring our services can meet patient’s needs in the future
- Investigating patient queries, complaints and/or legal claims
- Preparing data/statistics on Dementech’s performance Audit, Dementech’s accounts and services
- Undertaking research and development (with your consent and you may choose whether or not to be involved)
- Helping to train and educate healthcare professionals (with your consent and you may choose whether or not to be involved).
Everyone working within Dementech Neurosciences has a legal duty to keep information about you confidential. Similarly, anyone who receives information from us has a legal duty to keep it confidential. We will share information with the following main organisation:
- Other NHS and private organizations and hospitals involved in your care (Alliance Medical, The Wellington Hospital and others. For full list of our collaborators, please get in touch with us on 020 3848 4500)
- Clinical Commissioning Groups (CCGs), Strategic Health Authorities and other NHS bodies such as Ambulance Services
- General Practitioners
You may be receiving care from other people, for example social services, who we might need to share your information with so we can work together for your benefit – if they have a genuine need for it and only after we have your permission.
We will not disclose your information to any other third parties without your permission unless there are exceptional circumstances, such as if the health and safety of others is at risk or if the law requires us to pass on inform.
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
To respond to your enquiry or request for a consultation:
(a) Necessary steps to enter into a contract with you
(b) Necessary for our legitimate interests (to contact individuals who have made an enquiry or requested a consultation
To provide you with our services:
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how individuals use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data):
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, or to prevent fraud)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you:
Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences:
Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you:
Necessary for our legitimate interests (to develop our services and grow our business)
The lawful basis for processing data in accordance with GDPR includes Consent of the Data Subject, Contractual Necessity, Compliance with a legal obligation, Vital Interests, Public Interest, Legitimate Interest, Explicit Consent, Employment Law, Charity or not for Profit Bodies, Data Manifestly made public by the data subject, Legal Claims, Reason of Substantial Public Interest, Medical Diagnosis and Treatment, Public Health and Historical, Statistical and Scientific purposes.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms: you may unsubscribe from marketing emails at any time by clicking on the unsubscribe link on the email; you can contact us via telephone 0203 848 4500, email us at email@example.com write to us at: Dementech Neurosciences, Lister House 11 Wimpole Street, London, W1G 9ST or send us a message via our website contact page. You can unsubscribe to our marketing via the email unsubscribe link or by contacting us directly.
The General Data Protection Regulations (GDPR) provides rights for individuals, the right to be informed, the right of access, the right to rectification, the right to erasure, the right to restrict processing, the right to data portability and the right to object.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage 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 products, services and offers may be relevant for you for marketing purposes.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Dementech Neurosciences group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, warranty registration, product or service experience or other transactions.
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 you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you to obtain your consent 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.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, auditors and insurers who provide consultancy, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- 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 UK legislation. 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.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
7. DATA SECURITY
We have put in place appropriate security measures and take reasonable precautions to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Of course, data transmission over the internet is inherently insecure and we cannot guarantee the security of the data sent over the internet. We will store all personal information you provide on our secure servers.
We have put in place procedures to deal with any suspected personal data breach, a Data Breach Investigation Policy and we will notify you and any applicable regulator of a breach where we are legally required to do so.
The material on this website is protected by law including but not limited to UK copyright law. The copyright in the content of the Website is owned by Dementech Neurosciences. Details of the Copyright, Designs and Patents Act 1988 can be found on the Office of Public Sector Information website: www.opsi.gov.uk. All trademarks are the property of Dementech Neurosciences.
Service Availability and Limitation of Liability
We aim to ensure the continuous 24/7 availability of this website and its services. However, Dementech Neurosciences accepts no responsibility for direct, indirect, special, incidental, consequential or punitive loss or damage caused by interruptions, delays or inability to use or access any part of the website, however, caused or under any circumstances, in respect of claims or damages. You understand and agree that Dementech Neurosciences will not be liable for any direct, indirect, incidental, special, consequential or exemplary damages including but not limited to damages for any loss of profits, goodwill, use, data or other tangible losses (even in the event that we have been advised of the possibility of such damages), resulting from the use or inability of use of the Website Services, the unauthorised access to or alteration of your transmission of data, statements of conduct of any third party on the service or any other matter relating to the Service. Access to the site may be suspended temporarily and without notice in the case of system failure, maintenance or repair work beyond the company’s control. The office opening hours are between 8.00am to 8.00pm Monday to Sunday.
8. DISCLOSURE OF INFORMATION
You have the right to restrict how and with whom we share the personal information from your records. This must be noted explicitly within your records so all healthcare professionals and staff treating you are aware of your decision. Disclosure of your information is always done through encrypted means of communication and in accordance with GDPR guidelines.
By choosing this option, it may make the provision of treatment or care more difficult or unavailable. You can also change your mind at any time about a disclosure decision.
How you can access your health records:
- The Data Protection Act 1998 gives you a right to access the information we hold about you on our records.
- Your request must be in writing by completing a Subject Access Request form and sending it to the clinic’s Information Governance Manager
- There will be a charge to have a printed copy of the information held about you, which is in accordance with the Data Protection Act. This fee includes the time taken to locate the record and the printing costs involved.
- For copies of records requested by patients/patient’s representatives: £30
- For copies of records requested by Solicitors: £50
We are required to respond to you within 30 working days
You will need to provide adequate information (i.e. full name, address, date of birth, etc) so that your identity can be verified and your records