Patient GDPR Policy - Castle Craig

Castle Craig Hospital – Privacy, Data Protection and Cookie Policy

An introduction to our Privacy, Data Protection and Cookie Policy

INTRODUCTION

In this policy, “Company”, “We”, “Us” and “Our” refer to Castle Craig Hospital. Our Patients are “Patients”, “You”, “Your” and “Yours”
As a Company We are committed to safeguarding the privacy of Our Patients.
This policy applies where We are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and data platform, we will ask you to consent to our use of cookies when you first visit our website.

THE PERSONAL DATA THAT WE COLLECT

In this Section 2 We have set out the general categories of personal data that We process and in the case of personal data that We did not obtain directly from You, information about the source and specific categories of that data.
We may process data enabling Us to get in touch with You (“contact data”). The contact data may include Your name, email address, telephone number and postal address. The source of the contact data is obtained through You, if You fill in an admissions form You will be asked for this personal information, this information will be necessary for Us to carry out Our treatment. And any other services we may supply to You.
We may process data to manage Your account with Us (“account data”). The account data may include Your account identifier, name, email address, name, account creation, payment and any other options. The primary source of the account data is You.
We may process the information You provide in Your personal profile on the admissions form (“profile data”). The profile data may include Your name, location, telephone number, email address, profile pictures, gender, age, details about Your requirements for treatment(s).
We may process information relating to Our relationship (“relationship data”). The relationship data may include Your name, the details of your treatment(s) Your contact details, within Our admissions system and information contained in or relating to communications between Us and You.
We may process Your personal data that is provided in the course of the use of Our treatment and services (service data). The service data may include information about Your profile data, account data, relationship data, information including, any insurance held You hold and any previous medical history.
We may process information relating to transactions, including method of payment that You use (“transaction data”). The transaction data may include Your name, Your contact details, Your payment card details or other payment details and the transaction details. The source of the transaction data is You and/or Our payment services provider.
We may process information contained in or relating to any communication that You send to Us or that We send to You (“communication data”). The communication data may include the communication content and metadata associated with the communication.
We may process data about Your use of Our Services, including any treatments (“usage data”). The usage data may include Your IP address, geographical location, browser type and version, operating system, referral source, length of visit, as well as information about the timing, frequency and pattern of Your use of Our services. The source of the usage data is You.
Please do not supply any other person’s personal data to Us, the data You supply must only be Your own.
Any special category data (“special category data”) provided such as Data concerning your health, You expressly give Your permission under this clause. The Data collected will be necessary for the purpose and We are satisfied there is no other reasonable and less intrusive way to achieve that purpose.

PURPOSES OF PROCESSING AND LEGAL BASIS

In this Section 3, We have set out the purposes for which We may process personal data and special category and the legal bases of the processing.
Operations – We may process Your personal data and special category data for the purposes of the information required so that We can process Your Admissions information, providing our Services including treatments, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is the performance of a contract between You and Us and/or taking steps, at Your request, to enter into such a contract.
Relationships and communications – We may process contact data, account data, relationship data, transaction data and/or communication data for the purposes of managing Our relationships, communicating with You by email, SMS, web chat and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with Our Patients, the maintenance of Our relationships, enabling the use of Our Services, and treatments and the proper administration of our Services and treatments and business.
Research and analysis – We may process usage data, service data and/or transaction data for the purposes of researching and analysing the use of Our Services, as well as researching and analysing other interactions with Our business. The legal basis for this processing is Our legitimate interests, namely monitoring, supporting, improving Services and business generally. This data is anoymised.
Record keeping – We may process Your personal data for the purposes of creating and maintaining Our databases, back-up copies of Our databases and Our business records generally. The legal basis for this processing is Our legitimate interests, namely ensuring that We have access to all the information We need to properly and efficiently run our business in accordance with this policy.
Security – We may process Your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of Our Website, services and business, and the protection of others.
Insurance and risk management – We may process Your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is Our legitimate interests, namely the proper protection of Our business against risks.
Legal claims – We may process Your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is Our legitimate interests, namely the protection and assertion of Our legal rights, Your legal rights and the legal rights of others.
Legal compliance and vital interests – We may also process Your personal data where such processing is necessary for compliance with a legal obligation to which We are subject or in order to protect Your vital interests or the vital interests of another natural person.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register You as a new Patient	(a) Identity	Performance of a contract with You
To register You as a new Patient	(b) Contact	Performance of a contract with You
To process Your account details including:	(a) Identity	(a) Performance of a contract with You

(a) Manage payments, fees and charges	(b) Contact	(b) Necessary for Our legitimate interests (to recover debts due to Us)
(b) Collect and recover money owed to Us	(c) Financial
	(d) Transaction
	(e) Marketing and Communications
To manage Our relationship with You which will include:	(a) Identity	(a) Performance of a contract with You
	(b) Contact	(b) Necessary to comply with a legal obligation
(a) Notifying You about changes to Our terms or Privacy policy	(c) Profile	(c) Necessary for Our legitimate interests (to keep Our records updated and to study how customers use Our Treatments/Services)
(b) Asking you to leave a review or take a survey	(d) Marketing and Communications
To enable You to complete a survey	(a) Identity	(a) Performance of a contract with You
	(b) Contact	(b) Necessary for Our legitimate interests (to study how customers use Our Treatments/Services, to develop them and grow Our business)
	(c) Profile
	(d) Usage
	(e) Marketing and Communications
To administer and protect Our business and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity	(a) Necessary for Our legitimate interests (for running Our business, provision of administration and IT Services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
	(b) Contact	(b) Necessary to comply with a legal obligation
	(c) Technical
To deliver relevant content to You and measure or understand the effectiveness of the content We serve to You	(a) Identity	Necessary for Our legitimate interests (to study how customers use Our treatments/services, to develop them, to grow Our business)
	(b) Contact
	(c) Profile
	(d) Usage
	(e) Marketing and Communications
	(f) Technical
To use data analytics to improve Our Website, Treatments/Services, marketing, customer relationships and experiences	(a) Technical	Necessary for Our legitimate interests (to define types of customers for Our products and services, to keep our Website updated and relevant, to develop Our business and to inform You of Our treatments and Services)
	(b) Usage

To make suggestions and recommendations to You about Treatments or Services that may be of interest to You	(a) Identity	Necessary for Our legitimate interests (to develop our Treatments/Services and grow Our business)
	(b) Contact
	(c) Technical
	(d) Usage
	(e) Profile
	(f) Marketing and Communications

AUTOMATED DECISION MAKING

We will use Your personal data for the purposes of automated decision-making in relation to sending You follow-up correspondence, new services and providing you with content that You may find interesting, in line with Our Service.
This automated decision-making will involve automated process flows that trigger interactions following engagement with Our treatments, articles, or Services.
The significance and possible consequences of this automated decision-making are that You may from time to time receive information that You do not find useful or relevant to You. If this is the case you can either immediately delete, close or opt out of further messages by using Our opt out steps as mentioned in section 1.3.

PROVIDING YOUR PERSONAL DATA TO OTHERS

We may disclose Your personal data to Our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
Your personal data held in Our database will be stored on the servers of our hosting services.
Financial transactions relating to Our Services are handled by Our payment services providers. We will share transaction data with Our payment services providers only to the extent necessary for the purposes of processing Your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at payment providers website.
In addition to the specific disclosures of personal data set out in this Section 5, We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person. We may also disclose Your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

In this Section 6, We provide information about the circumstances in which Your personal data may be transferred to a third country under UK and/or EU data protection law.
We may transfer Your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit Our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and We may transfer Your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this Policy, and may permit Our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
The hosting facilities for Our website are situated in the UK only and our website hosting facilities are situated in the UK. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.

RETAINING AND DELETING PERSONAL DATA

This Section 7 sets out Our data retention policies and procedures, which are designed to help ensure that We comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that We process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
Notwithstanding the other provisions of this Section 7, We may retain Your personal data where such retention is necessary for compliance with a legal obligation to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person. This may entail Your data being retained for longer period. See also our Terms and Conditions which detail other provisions of how we deal with Your personal and special category data, this Terms and Conditions are an integral part of this policy.

SECURITY OF PERSONAL DATA

We will take appropriate technical and organisational precautions to secure Your personal data and to prevent the loss, misuse or alteration of Your personal data.
We will store Your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
Data relating to Your enquiries and financial transactions that is sent from Your web browser to Our web server, or from Our web server to Your web browser, will be protected using encryption technology.
You acknowledge that the transmission of unencrypted or inadequately encrypted data over the internet is inherently insecure, and We cannot guarantee the security of data sent over the internet.
You should ensure that Your device password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping Your password confidential at all times.

YOUR RIGHTS

In this Section 9, We have summarised the rights that You have under data protection law. Further information can be found at https://ico.org.uk/
Your principal rights under data protection law are:

the right to access – You can ask for copies of Your personal data;
the right to rectification – You can ask Us to rectify inaccurate personal data and to complete or incomplete personal data;

the right to erasure – You can ask Us to erase Your personal data;

the right to restrict processing – You can ask Us to restrict the processing of Your personal data;
the right to object to processing – You can object to the processing of Your personal data;
the right to data portability – You can ask that We transfer Your personal data to another organisation or to You;

the right to complain to a supervisory authority – You can complain about Our processing of Your personal data; and
the right to withdraw consent – to the extent that the legal basis of Our processing of Your personal data is consent, You can withdraw that consent.
- You have the right to confirm as to whether or not We process Your personal data and, where We do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, We will supply to You with a copy of Your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
- You have the right to have any inaccurate personal data about You rectified and, taking into account the purposes of the processing, to have any incomplete personal data about You completed.
- In some circumstances You have the right to the erasure of Your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; You withdraw consent to consent-based processing; You object to the processing under certain rules of applicable data protection law; and the personal data has been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
- In some circumstances You have the right to restrict the processing of Your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but You oppose erasure; We no longer need the personal data for the purposes of Our processing, but You require personal data for the establishment, exercise or defence of legal claims; and You have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, We may continue to store Your personal data. However, We will only otherwise process it: with Your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
- You have the right to object to Our processing of Your personal data on grounds relating to Your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in Us; or the purposes of the legitimate interests pursued by Us or by a third party. If You make such an objection, We will cease to process the personal data unless We can demonstrate compelling legitimate grounds for the processing which override Your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
- You have the right to object to Our processing of Your personal data for scientific or historical research purposes or statistical purposes on grounds relating to Your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
- To the extent that the legal basis for Our processing of Your personal data is:

consent; or
that the processing is necessary for the performance of a contract to which You are party or in order to take steps at Your request prior to entering into a contract, and such processing is carried out by automated means, You have the right to receive Your personal data from Us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
- If you consider that Our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In relation to complaints under EU data protection law, you may do so in the EU member state of your habitual residence, Your place of work or the place of the alleged infringement; in relation to complaints under UK data protection law, You should do so in the UK.
- To the extent that the legal basis for Our processing of Your personal data is consent, You have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
- You may exercise any of Your rights in relation to Your personal data by emailing haden@castlecraig.co.uk in addition to the other methods specified in this Section 9.
UPDATING INFORMATION

Please let Us know if the personal information that We hold about You needs to be corrected or updated.

ABOUT OUR COOKIES

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies may not contain any information that personally identifies a user, but personal data that We store about You may be linked to the information stored in and obtained from cookies.

COOKIES THAT WE AND OUR SERVICES PROVIDER USE

1 We and Our service providers use cookies and those cookies may be stored on Your computer when You visit our website.
2 We use Google Analytics. Google Analytics gathers information about the use of Our Website by means of cookies. The information gathered is used to create reports about the use of Our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.

MANAGING COOKIES

Most browsers allow You to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
https://support.google.com/chrome/answer/95647 (Chrome);

https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
https://help.opera.com/en/latest/security-and-privacy/ (Opera);
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites.
If You block cookies, You will not be able to use all the features or some services on Our website.

AMENDMENTS

We may update this policy from time to time by publishing a new version on Our Website.
You should check this page occasionally to ensure You are happy with any changes to this policy.
We may notify You of any significant changes to this policy by email.

OUR DETAILS

This website is owned and operated by Castle Craig Hospital.
Castle Craig Hospital Limited, a company registered in Scotland, with a registered number SC108534, and whose registered office is Castle Craig Hospital, Blythe Bridge, West Linton, Peeblesshire, EH46 7DH.

You can contact Us:

(a) using Our Website contact form;

(b) by telephone;

Last updated 25-01-2022