This privacy notice provides you with details of how we collect and process your personal data through your use of our sites aletheiaclinics.com and victoriafenton.net and as a client/customer of Aletheia, a trading name of Victoria Fenton Healthcare Ltd., including any information you may provide through our site when you purchase a product or service, sign up to our newsletter or take part in a prize draw or competition.
By providing us with your data, you warrant to us that you are over 13 years of age.
Victoria Fenton Healthcare Ltd is the data controller in most cases and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). If you have any questions about this privacy notice, please contact us using the details set out below:
Victoria Fenton Healthcare Ltd.
Director: Victoria Fenton
Flat 210, Ben Jonson House, Barbican, London, EC2Y 8DL
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com
2. WHAT DATA DO WE COLLECT ABOUT YOU
Personal Data means any information capable of identifying an individual. It does not include anonymised data. Victoria Fenton Healthcare Ltd. may process certain types of personal data about you as follows:
- Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your bank account and payment card details.
- Transaction Data may include details about payments between us and other details of purchases made by you.
- Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your Personal Data so that you can be identified from it, it is treated as personal data. The personal data described above may relate to any of the following categories of person:
- our clients and clients’ personnel our prospective employees and contractors
- our current employees and contractors
- third parties with whom we have contact by virtue of providing services
- our contacts, professional advisors or others with whom we work in the context of our services
- our prospective target clients
- those who submit enquiries through our website or whose details are otherwise entered into our client relationship management system
We collect all above forms of data through the following channels:
- Victoria Fenton Healthcare Ltd. website and Aletheia Website, including newsletter sign up channels
- Social media channels (for example Facebook, Twitter and Instagram)
- By phone
- Email (either person-to-person or via mass-mailing tools such as Mailchimp in the case of our e-newsletters)
- By post
- In person – information given to reception/administrative staff and/or any of our contracted professionals and employees
We are committed to safeguarding your personal information. Whenever you provide personal information (for example your email address, date of birth, telephone number, full name, next of kin or healthcare details) we are legally obliged to use your information in line with all laws concerning the protection of personal information, including the Data Protection Act 1998.
At Victoria Fenton Healthcare Ltd. we collect medical data; information about your health and genetic and biometric data. There may be times we collect other sensitive data about you, where you directly provide us with this. Other sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership. We do not explicitly collect any information about criminal convictions and offences, though these may be stored in your record within documentation created for your use only. We require your explicit consent for processing sensitive data, so when you submit your details we ask you to confirm your consent to this processing. We treat sensitive data under the legislation of Special Category Data. (It should be noted that these areas of legislation are still being determined by governing bodies and under our membership of the ICO will keep up to date with any further policy making in this field.)
In addition, all laboratories and third parties that Victoria Fenton Healthcare Ltd. chooses to work with are vetted by ourselves to comply with stringent data protection, privacy and confidentiality laws. Companies not based in the UK are selected carefully to comply with European GDPR rules. Where we are required to collect personal data by law, or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you).
If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
- Direct interactions – you may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:order our products or services; work with us; network online or offline with us; create an account on our site; subscribe to our service or publications; request resources or marketing be sent to you; enter a competition, prize draw, promotion or survey; or give us feedback
- Third parties or publicly available sources – depending on your settings or the privacy policies for other online services, you may give us permission to obtain information from your account with those other services such as analytics providers, advertising networks and search information providers. For example, this can be via social media or by choosing to send us your location data when accessing our Site from your smartphone.
Upon acceptance of our policy, we can track your behaviour on our Site from social media, direct, referral, organic or email traffic using Facebook Pixel and Google Analytics. We may also receive personal data about you from public sources.
4. WHY WE COLLECT YOUR PERSONAL DATA
Victoria Fenton Healthcare Ltd. will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us.
- 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.
This may include:
- to respond to any query that you may submit to us
- to manage our relationship with you (and/or your business), including by maintaining our database of clients and other third parties for administration, and accounting and relationship management purposes
- to complete our contractual obligations to you, or otherwise taking steps as described in our client Agreements (including any associated administration)
- to carry out any relevant conflict checks
- to send you any relevant information on our services and events that may be of interest to you using the email and/or postal address which you have provided, but only if you have given us your consent
- to ensure that our Site’s content is presented in the most effective manner for you and your device
- to customise our Site according to your interests
- to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey responses
- to allow you to participate in interactive features on our Site when you choose to do so
- as part of our efforts to keep our Site safe and secure
- to measure or understand the effectiveness of advertising we send to you and others, and to deliver relevant advertising to you
- to comply with any other professional, legal and regulatory obligations which apply to us or policies that we have in place as we feel is necessary to prevent illegal activity or to protect our interests.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email, customised online advertising or text message. You have the right to withdraw consent to marketing at any time by emailing us at firstname.lastname@example.org
Marketing communications: You will receive marketing communications from us if you have:
(i) requested information from us or purchased goods or services from us; or(ii) if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and (iii) in each case, you have not opted out of receiving that marketing.
Victoria Fenton Healthcare Ltd. will not sell or rent your personally identifiable information, gathered as a result of filling out the Site newsletter sign up forms, to anyone. Victoria Fenton Healthcare Ltd. may share generic aggregated demographic information not linked to any personal identification information regarding visitors and Users with the business partners, trusted affiliates and advertisers for the purposes outlined above. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
We use a third party provider to process your subscription and deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. You can unsubscribe to general mailings at any time by clicking the unsubscribe link at the bottom of any of our emails or by emailing us. If at any time you would like to unsubscribe from receiving future emails, you can email us at: email@example.com and we will promptly remove you from ALL marketing correspondence. Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at firstname.lastname@example.org
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing. We may process your personal data without your knowledge or consent 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 for the purposes set out in paragraph 4 above:
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Our bank for the purposes of preventing money laundering or terrorist financing, may require us to disclose your personal data on request to our bank from time to time where we hold monies
- Our employees and contractors (under agreement)
- Our data processors providing security, email security, data governance, archiving and other IT and business support services
- Our email marketing platform provider and our website platform provider
- Analytics and search engine providers that assist us in the improvement and optimisation of our website
- Any third party you ask us to share your data with
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We share your personal data within our company which involves transferring your data outside the European Economic Area (EEA). Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria. Many of our third party service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. Please email us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
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 such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Access to personal data and information
Only practitioners registered with Victoria Fenton Healthcare Ltd. (and its trading name of Aletheia) have access to our systems and data storage. We use an accredited, centralised, third-party practice management system (Function 365) bound by UK law with regard to GDPR, data protection, privacy, confidentiality and storage. Computers which have access to these systems are password and/or fingerprint protected. Only practitioners assigned to specific patients have access to specific patient data. In such a way, whilst we are an integrated team, your data is only shared with other practitioners with your express permission (in writing, via email).
We are a paperless practice. All of our data is held electronically. We store no paper records and in cases where information is received in paper form it is digitised and the paper copy securely destroyed.
We will store you personal data in line with all laws pertaining to the treatment of medical data. Please find the guidance that we follow on here: https://researchbriefings.files.parliament.uk/documents/SN07103/SN07103.pdf
Our Site is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Site as safe as possible. We do not use Malware Scanning. All sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology. When you are on a secure page, a lock icon will appear in the address bar of your browser. We implement a variety of security measures when a User places an order, hires us, enters, submits, or accesses their information to maintain the safety of your personal information. All transactions are processed through a gateway provider (PayPal or Stripe) or a bank transfer and are not stored or processed on our servers. Payment and login information are encrypted. Non-sensitive details (e.g. your name, email address) are sent normally over the internet and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.
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.
8. DATA RETENTION
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. 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.
Deletion of personal data
Under GDPR regulations, any individual has a right to request erasure of their information at any time. However, the expert view is that medical requirements take precedence over GDPR rights to erasure. Therefore, notable exceptions include:
- medical diagnosis
- the provision of health or social care
- the management of health or social care systems or services
Victoria Fenton Healthcare Ltd. and its trading name Aletheia are healthcare service providers: medical and healthcare data is deemed as exempt from deletion or erasure upon patient request in the majority of cases until retention schedule limits are met.
At Victoria Fenton Healthcare Ltd. we voluntarily comply with the NHS Records Management Code of Practice for Health and Social Care 2016. Within these detailed retention schedules, we are bound to retain patient information for 8 years. Our records are all electronic and our systems allow for metadata sub data records to be retained so deletion takes place in accordance with an 8 year retention policy. By law, we have to keep basic information about our clients/customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients/customers for tax purposes.
In some circumstances – notably those in which you have provided data which is not medical in nature – you can ask us to delete your data: see below for further information.In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. However, at Victoria Fenton Healthcare Ltd. we have committed to asking your express permission before utilising your data in this way.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data (except in circumstances laid out under “Deletion of Personal Data” listed above
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.orgAs laid out above, this applies to personal data – though will not apply to medical data held on our systems. 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. 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.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 a number of requests. In this case, we will notify you and keep you updated.
Choosing how we use your personal data
We understand that you trust us with your personal information and we are committed to ensuring you can manage the privacy and security of your personal information yourself. With respect to the information relating to you that ends up in our possession, and recognising that it is your choice to provide us with your personal data, we commit to giving you the ability to do all of the following:
- You can verify the details you have submitted to Victoria Fenton Healthcare Ltd. by contacting us on email@example.com Our security procedures mean that we may request proof of identity before we reveal information.
- You can also contact us by the same method to change, correct, or delete your personal information controlled by Victoria Fenton Healthcare Ltd. regarding your profile at any time. Please note that if you have shared any information with others through social media channels, that information may remain visible, even if your account is deleted.
- You can unsubscribe from receiving marketing emails from us by clicking the “unsubscribe” link at the bottom of any email. Once you do this, you will no longer receive any emails from us unless you select you would still like to receive emails about an individual topic or you explicitly provide consent in future.
- You can request a readable copy of the personal data we hold on you at any time. To do this, please contact us: firstname.lastname@example.org
11. QUESTIONS, REQUESTS AND COMPLAINTS
Victoria Fenton Healthcare Ltd.
Director: Victoria Fenton – email@example.com – Flat 210, Ben Jonson House, Barbican, London, EC2Y 8DL
Last updated, 8 January 2020
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When you visit the Site, we use the following third party services: Google Analytics, Analytics and Facebook Pixel/Custom Events to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the Site. This information is only processed in a way which does not identify anyone. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the Site, but will not store, save or collect personal information. We do not make, and do not allow these third parties to make, any attempt to find out the identities of those visiting our Site.
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IF YOU DISABLE COOKIES IN YOUR BROWSER:
If you disable cookies, some features will be disabled. It will turn off some of the features that make your Site experience more efficient and some of our services will not function properly.
This document was last updated on May 20th 2019.