We are CB1 Medical Ltd, company number 13910422. Registered office address 184 Coleman Road Leicester England LE5 4LJ
The Company and personal information: We are committed to lawful, fair and transparent processing of all personal information about our employees, clients, suppliers and other third parties during our business activities. We will always comply with any applicable data protection legislation, and we will ensure that collection and use of personal information is carried out in accordance with applicable data protection laws. The main law governing data protection is the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) known as the “GDPR”.
What this policy is: This policy (and any other documents referred to in it, together with any privacy notice displayed on our website) sets out the basis on which we will process any personal information about you or individuals generally – whether it’s information we collect from those individuals or that is provided to us from other sources. This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer or store personal information.
Notification: We comply with current requirements to notify our data processing activities to the Information Commissioner’s Office and are registered under number ZB318453
Controlling and processing information: We are the controller of all personal information used in our business for our own commercial purposes. Sometimes though, we will process personal information on behalf of another data controller – and when this is the case, we will do so only in accordance with the instructions of that data controller and otherwise in accordance with the GDPR.
Why you should read this policy: it is important that you read this policy, together with any other documents referred to in it, so that you are aware of how any personal information relating to you will be dealt with by us.
We are accountable for demonstrating compliance with the GDPR’s six principles of processing personal information. These provide that personal information we deal with must be:
(a) processed fairly, lawfully and in a transparent manner.
(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
(c) adequate, relevant and limited to what is necessary.
(d) accurate and, where necessary, kept up to date.
(e) not kept for longer than necessary; and
(f) processed securely, maintaining integrity and confidentiality.
Personal information: In this policy, when we use the term“personal information” we mean any information relating to an identified or identifiable human being. (An “identifiable natural person” is one who can be identified, directly or indirectly, for example, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, biometric, mental, economic, cultural or social identity of that person).
Sensitive personal information: In this policy, when we use the term “sensitive personal information” we mean special categories of information which are personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying someone, data concerning health or data concerning someone’s sex life or sexual orientation.
We may collect, record, organise, structure, store, adapt, alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, erase or destroy the following types of personal information about you:
Details of transactions you carry out through our website or by other means, the fulfilment of your instructions and any subsequent communications with you about any of these
Details of your visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own administrative purposes or otherwise and the resources that you access
We may also collect, store and use: Information about your health, including any medical condition, health and sickness records
During our business, we may collect personal information directly from an individual:
when you provide information in relation to services, we might provide to you.
We may also collect personal information about individuals from other sources such as Doctors and/or other medical professional who refer you to us
We will only collect personal information to the extent that it is required for the specific purpose notified to individuals about whom we are collecting – and we will keep it as long as is necessary.
We will only use personal information when the law allows us to do so and relying on a relevant basis for lawful processing in each instance. We will use your personal information in the following circumstances, relying on the basis of processing indicated:
Basis of processing: Where we need to perform a contract we are about to enter or have entered with you.
Basis of processing:
Where it is necessary for our legitimate interests (or those of a third party) and we have undertaken an assessment to determine that processing for those interests (listed below) does not outweigh your interests and fundamental rights, considering the nature and impact of the processing and any relevant safeguards we can put in place.
Basis of processing: Where you have consented to the processing.
Other issues about how we use personal information:
Please note that we may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact the clinic if you need details about the specific legal basis, we are relying on to process your personal information –contact details are below.
We will only use your personal information 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. Please contact us if you would like further details of any additional purposes of processing. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
Where we need to collect personal information 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 services). If this happens, we may have to cancel, or be unable to provide, any services you have requested.
Please note that we may process your personal information without your knowledge or consent where required or permitted by law.
We may collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal information 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 website usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy policy.
If you provide us with any personal information relating to relatives, partners or other individuals it is your duty to make such persons aware that their personal information may be shared with us and to provide them with appropriate information about how their personal information may be processed by us.
As indicated above, we may use your personal information to provide you with information about goods and services which may be of interest to you and we may contact you about these by email, text message, post or telephone call. This is known as direct marketing.
Examples of direct marketing may include:
We will only process personal information for the above purposes as permitted by law, which usually means with your specific consent. You have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below.
We may also disclose your information to third parties (including our subsidiaries, our ultimate holding company and its subsidiaries for the purpose of direct marketing. Again, we will only do this with your explicit consent, and you have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below. Please see “Data Sharing” below for further details.
In this policy, where we have referred to needing your consent for any processing, we will make sure that the consent:
Protection for sensitive personal information: Processing of sensitive personal information requires higher levels of protection. We may process sensitive personal information about an individual in the following circumstances:
Automated decision-making takes place when an electronic system uses personal information to decide relevant to you without human intervention.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
Transfer of personal information outside of the EEA: We may. transfer certain personal information that we hold on to individuals living in the European Union to a country outside the European Economic Area (“EEA“), provided that one of the following conditions applies:
– the country to which the personal information is transferred ensures an adequate level of protection for that individual’s rights and freedoms.
– an individual has given their explicit and informed consent having had the risks explained to them.
– the transfer is covered by one of the derogations set out in the GDPR, including the performance of a contract between us and that individual, or to protect the vital interests of individuals.
– the transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims; or
– the transfer is authorised by the relevant data protection authority where we have checked adequate safeguards exist with respect to the protection of the individual’s privacy, their fundamental rights and freedoms, and the exercise of their rights.
Subject to the requirements set out above, the personal information we hold may also be processed by individuals operating outside the EEA who work for us or for one of our suppliers. Those individuals may be engaged in, among other things, the fulfilment of contracts with the relevant individual, the processing of payment details and the provision of support services.
Safeguards: If we use a third-party data processor to process personal information on our behalf, we will obtain contractual commitments to safeguard the security of the personal information to ensure that the third party only acts on our instructions when using that personal information and that the third party has in place appropriate technical and organisational security measures to safeguard the personal information. Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
– we may transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
– where we use service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
– where we use service providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal information shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information outside the EEA.
Why we might share your personal information with third parties: We may share personal information we hold with: (i) any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries; and/or (ii) in the event that we sell or buy any business or assets, or sell the Company, we will disclose your personal data to the prospective seller or buyer of such business or assets. We may also disclose personal information we hold to third parties if we are under a duty to disclose or share an individual’s personal information in order to comply with any legal obligation, or in order to enforce or apply any contract with that individual or other agreements; or to protect our rights, property, or safety of our employees, clients or others. This includes exchanging personal information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We may share personal information with other members in the group as part of our regular reporting activities on company performance, such as when considering in which fields there is more demand for services and therefore what additional resource we might need to cater for clients’ needs. When appropriate, we will anonymise personal information when used for performance reviewing and reporting activities.
We may also share personal information we hold with selected third parties for the purposes set out below. We do not allow 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.
Third party service providers who may process your personal information: When we use the term “third party”, we mean any entity who is not the Company, including third party service providers, contractors and designated agents and any member of our group. The following third party service providers may process personal information for the following purposes:
We may use third-party service providers to monitor and analyse the use of our service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms webpage: http://www.google.com/intl/en/policies/privacy/
Google Ads re-marketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on –https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Twitter re-marketing service is provided by Twitter Inc. You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy
Facebook re-marketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance.
You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA: http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canadian Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
We may provide paid products and/or services within the service. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors, whose use of your personal information is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
We will always take appropriate technical and organisational measures to protect personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, where he processing involves the transmission of data over a network, and against all other unlawful forms of processing (including taking reasonable steps to ensure the reliability of employees who have access to personal information). Our employees may only process personal information in accordance with this privacy policy, and any employee who breaches this privacy policy may be subject to disciplinary action, up to and including dismissal.
We have put in place internal procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will not keep personal information in a form which permits identification of individuals for longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of personal information, the purposes for which we process information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will only keep personal information for as long as is necessary for the purpose or purposes for which that personal information is processed; and we will let anyone about whom we process data know how long that is or the criteria that go into deciding how long that is.
We may sometimes anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Our website may, from time to time, contain links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or the security of these websites. Please check the relevant policy before you submit any personal information to these websites.
Under certain circumstances, you have rights under data protection laws in relation to your personal information, as summarised below.
You have the right to:
If you wish to exercise any of the rights set out above, please contact us at anabel.sharma@nhs.net We aim to respond to all legitimate requests within one month (and if we are only processing the data in question on behalf of another party, the response may come from that other party as the relevant data controller). 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.
You will not have to pay a fee to access your personal information (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. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device if you agree. Cookies contain information that is transferred to your computer or device. We use the following cookies:
As the steps for controlling your settings can vary for each browser, we’ve included links to the official instructions for the most common browsers below:
for further info please see all about cookies https://www.allaboutcookies.org/
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you block cookies, you may not be able to access all or parts of our website.
We reserve the right to change this policy at any time. Where appropriate, we will notify individuals of those changes by post or email. Each time you enter or use our website, you agree that the privacy policy current at that time shall apply to all information we hold about you.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Questions, comments and requests to anabel.sharma@nhs.net
You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (https://www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office, so please contact us in the first instance.
