Privacy Notice

Executive summary

Manchester Urology (MU”, “we”, “us”, “ours”) as custodian of personal information relating to your medical diagnosis and/or treatment, will look after your information in line with privacy and data protection laws, including the General Data Protection Regulation (“GDPR”) (collectively, the “Data Protection Laws”).This Privacy Notice explains what data we collect and why, how we use it and who we share it with, as well as your rights as a data subject. We are committed to keeping your data safe with appropriate technical and organisational measures to ensure its security, integrity and availability.

Introduction

This Privacy Notice sets out details of the information that the MU clinician responsible for your diagnosis and/or treatment (and including our medical secretaries), may collect from you and how that information may be used. Please take your time to read this Privacy Notice carefully.
In the event that you have any queries, comments or concerns in respect of the manner in which your personal information is or may be used by us, then you should contact your MU consultant directly using the contact number given in correspondence or on the MU website (www.manchesterurology.org.uk).

Your personal data
We are known as the “data controller” of your personal data. The personal data we process about you will mainly relate to your medical diagnosis and/or treatment but will be likely to also include other information such as financial data in relation to billing.MU must comply with the data protection legislation and relevant guidance when handling your personal information, and so must any medical secretary who assists us in an administrative capacity. Your personal data may include any images taken in relation to your diagnosis and/or treatment which must not only be managed in accordance with the Data Protection Laws, but also all applicable professional standards including guidance from the General Medical Council and British Medical Association.
MU will provide your treatment in conjunction with a hospital provider and, in due course, it may be necessary for the hospital provider to also process your personal data.MU will do so in accordance with the Data Protection Laws, the principles of this Privacy Notice and to the extent that it is necessary to do so.This could be where the hospital provider needs to arrange other healthcare services as part of your treatment, such as nursing or dietician advice, or support other aspects of the treatment which we provide to you.In that case, the hospital provider will become a joint data controller in respect of your personal information and it is their responsibility to provide you with a copy of their Privacy Notice which sets out how they will manage that information.
Your personal information will be handled in accordance with the principles set out within this Privacy Notice. This means that whenever MU use your personal data, it will only do so as set out in this Privacy Notice.From time to time, we may process your personal information at a non-hospital provider site (medical or non-medical), as may our medical secretaries.

What personal information is collected and used from patients?
MU will use “special categories of personal information” (previously known as "sensitive personal data") about you, such as information relating to your physical and mental health.
If you provide personal information about other individuals (including medical or financial information) you should inform the individual about the contents of this Privacy Notice.MU will also process such information in accordance with this Privacy Notice.
In addition, you should note that in the event you amend data which we already hold about you (for instance by amending a pre-populated form) then we will update our systems to reflect the amendments.Our systems will continue to store historical data.

Personal information
As one of our patients, the personal information MU holds about you may include, but is not limited to, the following:
The confidentiality of your medical information is important to us, and we make every effort to prevent unauthorised access to and use of information relating to your current or former physical and mental health (or indeed any of your personal information more generally). In doing so, MU will comply with UK Data Protection Laws and all applicable medical confidentiality guidelines issued by professional bodies including, but not limited to, the General Medical Council and the Nursing and Midwifery Council.

How is information collected?
MU may collect personal information from a number of different sources including, but not limited to:
1. GPs
2. Dentists
3. Other hospitals, both NHS and private
4. Mental health providers
5. Commissioners of healthcare services
6. Other clinicians (including their medical secretaries)
  
  Directly from you
Information may be collected directly from you when:
1. You enter into a contract with MU or a hospital provider
2. You use those services
3. You complete enquiry forms on the hospital provider website
4. You submit a query to MU and its Partners/employees including by email or by social media
5. You correspond with me by letter, email, telephone (incoming and outgoing calls from/to patients may be recorded) or social media.
  
  From other healthcare organisations
Patients will usually receive healthcare from other organisations, and so in order to provide you with the best treatment possible MU may have to collect personal information about you from them.These may include:
We may communicate with you in a range of ways, including by telephone, SMS, email, and / or post.If we contact you using the telephone number(s) which you have provided (landline and/or mobile), and you are not available and this subsequently results in the call being directed to a voicemail and/or answering service, we may leave a voice message on your voicemail and/or answering service as appropriate,including only sufficient basic details to enable you to identify who the call is from, very limited detail as to the reason for the call and how to call us back.
However:
1. to ensure that we provide you with timely updates and reminders in relation to your healthcare (including basic administration information and appointment information only (including reminders)), we may communicate with you by SMS and/or unencrypted email (where you have provided us with your SMS or email address) [in each case where you have expressed a preference in the patient registration form to be contacted by SMS and / or email.
2. to provide you with your medical information (including test results and other clinical updates) and/or invoicing information, we may communicate with you by email (which will only be if encrypted) where you have provided us with your email address and have expressed a preference in the patient registration form to be contacted by email.The first time we send you any important encrypted email that we are not also sending by post or which requires action to be taken, we will endeavour to contact you separately to ensure that you are able to access the encrypted email you are sent.
Please note that although providing your mobile number and email address and stating a preference to be communicated by a particular method will be taken as an affirmative confirmation that you are happy for us to contact you in that manner, we are not relying on your consent to process your personal data in order to correspond with you about your treatment.As set out further below, processing your personal data for those purposes is justified on the basis that it is necessary to provide you with healthcare service.

What are the purposes for which your information is used?
We may 'process' your information for a number of different purposes, which is essentially the language used by the law to mean using your data. Each time we use your data we must have a legal justification to do so. The particular justification will depend on the purpose of the proposed use of your data. When the information that we process is classed as a “special category of personal information”, we must have a specific additional legal justification in order to use it as proposed.
Generally we will rely on the following legal justifications, or 'grounds':
1. Taking steps at your request so that you can receive healthcare services from us.
2. For the purposes of providing you with healthcare pursuant to a contract between you and us. We will rely on this for activities such as supporting your medical diagnosis and/or treatment or care and other benefits, supporting your nurse, carer or other healthcare professional and providing other services to you.
3. We have an appropriate business need to process your personal information and such business need does not cause harm to you. We will rely on this for activities such as quality assurance, maintaining my business records, monitoring outcomes and responding to any complaints.
4. We have a legal or regulatory obligation to use such personal information.
5. We will need to use such personal information to establish, exercise or defend our legal rights.
6. You have provided your consent to our use of your personal information.
Note that failure to provide your information further to a contractual requirement with us may mean that we are unable to set you up as a patient or facilitate the provision of your healthcare.
We provide further detail on these grounds in the sections below.

Appropriate business needs
One legal ground for processing personal data is where we do so in pursuit of legitimate interests and those interests are not overridden by your privacy rights.Where we refer to use for our appropriate business needs, we are relying on this legal ground.

The right to object to other uses of your personal data
You have a range of rights in respect of your personal data.This includes the right to object to us using your personal information in a particular way (such as sharing that information with third parties), and we must stop using it in that way unless specific exceptions apply.This includes, for example, if it is necessary to defend a legal claim brought against us, or it is otherwise necessary for the purposes of your ongoing treatment.

You will find details of our legal grounds for each of our processing purposes below. We have set out individually those purposes for which we will use your personal information, and under each one we set out the legal justifications, or grounds, which allow us to do so. You will note that we have set out a legal ground, as well as an 'additional' legal ground for special categories of personal information. This is because we have to demonstrate additional legal grounds where using information which relates to a person's healthcare, as we will be the in majority of the time.

Purpose 1: To set you up as my patient, including carrying out fraud, credit, anti-money laundering and other regulatory checks
As is common with most business, we have to carry out necessary checks in order for you to become a patient.These include standard background checks, which we cannot perform without using your personal information.
Legal ground: Taking the necessary steps so that you can enter into a contract with us for the delivery of healthcare.
Additional legal ground for special categories of personal information: The use is necessary for reasons of substantial public interest, and it is also in our legitimate interests to do so.

Purpose 2: To provide you with healthcare and related services
Clearly, the reason you come to us is to provide you with healthcare, and so we have to use your personal information for that purpose.
Legal grounds:
1. Providing you with healthcare and related services
2. Fulfilling my contract with you for the delivery of healthcare
Additional legal grounds for special categories of personal information:
1. We need to use the data in order to provide healthcare services to you
2. The use is necessary to protect your vital interests where you are physically or legally incapable of giving consent
  
  Purpose 3: For account settlement purposes
  
  Accounting and coding information will be be shared with Medical Billing and Collection Ltd, who are employed to provide billing services for Manchester Urology. If your treatment is under private medical insurance this will also include your relevant insurance company. The Medical Billing and Collection Privacy Policy can be found at https://medbc.co.uk/website/wp-content/uploads/2018/12/MBC-Privacy-Policy_V1.0_071218-min-1.pdf
We will use your personal information in order to ensure that your account and billing is fully accurate and up-to-date
Legal grounds:
1. Providing you healthcare and other related services
2. Fulfilling my contract with you for the delivery of healthcare
3. Our appropriate business need to use your information which does not overly prejudice you
4. Your consent
Additional legal grounds for special categories of personal information:
1. We need to use the data in order to provide healthcare services to you
2. The use is necessary in order for us to establish, exercise or defend our legal rights
3. Your consent
  
  Purpose 4: For medical audit/research purposes
  
  Clinical audit
We may process your personal data for the purposes of local clinical audit – i.e. an audit carried out for the purposes of assessing outcomes for patients and identifying improvements which could be made for the future.We are able to do so on the basis of our legitimate interest and the public interest in statistical and scientific research, and with appropriate safeguards in place.You are, however, entitled to object to us using your personal data for this purpose, and as a result of which we would need to stop doing so.If you would like to raise such an objection then please contact us using the details provided in paragraph 2 above.
We may also be asked to share information with U.K. registries for which ethical approval is not necessarily required but which form part of the National Clinical Audit programme, hosted by NHS England and who provide a list of National Clinical Audit and Clinical Outcome Review programmes and other quality improvement programmes which we should prioritise for participation. We may do so without your consent provided that the particular audit registry has received statutory approval, or where the information will be provided in a purely anonymous form, otherwise your consent will be needed and either we will seek this from you or the registry themselves will do so. The registries which we regularly share data with are National Cancer Registries, British Association of Urological Surgeons and the National eLogbook.

Medical research
We may also be asked to participate in medical research and share data with ethically approved third party research organisations.
We will share your personal data only to the extent that it is necessary to do so in assisting research and as permitted by law.Some research projects will have received statutory approval such that consent may not be required to use your personal data. In those circumstances, your personal will be shared on the basis that:

Legal grounds:
1. We have a legitimate interest in helping with medical research and have put appropriate safeguards in place to protect your privacy
  
  Additional legal grounds for special categories of personal information:
2. The processing is necessary in the public interest for statistical and scientific research purposes
3. If consent is required then either we will seek this from you, or the research agency will do so.
  
  Purpose 5: Communicating with you and resolving any queries or complaints that you might have.
From time to time, patients may raise queries, or even complaints, with their consultant and hospital provider. We take those communications very seriously.It is important that we are able to resolve such matters fully and properly and so we, as well as the hospital provider will need to use your personal information in order to do so.
Legal grounds:
1. Providing you with healthcare and other related services
2. Having an appropriate business need to use your information which does not overly prejudice you
Additional legal grounds for special categories of personal information:
1. The use is necessary for the provision of healthcare or treatment pursuant to a contract with a health professional
2. The use is necessary for us to establish, exercise or defend our legal rights
  
  Purpose 6: Communicating with any other individual that you ask us to update about your care and updating other healthcare professionals about your care.
In addition, other healthcare professionals or organisations may need to know about your diagnosis and/or treatment in order for them to provide you with safe and effective care, and so we may need to share your personal information with them.
Legal grounds:
1. Providing you with healthcare and other related services
2. We have a legitimate interest in ensuring that other healthcare professionals who are routinely involved in your care have a full picture of your treatment
Additional legal ground for special categories of personal information:
1. We need to use the data to provide healthcare services to you
2. The use is necessary for reasons of substantial public interest under UK Data Protection Laws
3. The use is necessary for us to establish, exercise or defend our legal rights
We also participate in initiatives to monitor safety and quality, helping to ensure that patients are getting the best possible outcomes from their treatment and care. The Competition and Markets Authority Private Healthcare Market Investigation Order 2014 established the Private Healthcare Information Network (“PHIN”), as an organisation who will monitor outcomes of patients who receive private treatment.Under Article 21 of that Order, we are required to provide PHIN with information related to your treatment, including your NHS Number in England and Wales, CHI Number in Scotland or Health and Care Number in Northern Ireland), the nature of your procedure, whether there were any complications such as infection or the need for readmission/admission to a NHS facility and also the feedback you provided as part of any PROMs surveys.PHIN will use your information in order to share it with the NHS, and track whether you have received any follow-up treatment.We will only share this information with PHIN if you have provided your consent for us to do so.
The records that we share may contain personal and medical information about patients, including you. PHIN, like us, will apply the highest standards of confidentiality to personal information in accordance with Data Protection Laws and the duty of confidentiality. Any information that is published by PHIN will always be in anonymised statistical form and will not be shared or analysed for any purpose other than those stated. Further information about how PHIN uses information, including its Privacy Notice, is available at www.phin.org.uk.

Purpose 7: Complying with our legal or regulatory obligations, and defending or exercising our legal rights
As a provider of healthcare, we are subject to a wide range of legal and regulatory responsibilities which is not possible to list fully here.We may be required by law or by regulators to provide personal information, and in which case we will have a legal responsibility to do so.From time to time, clinicians are unfortunately also the subject of legal actions or complaints.In order to fully investigate and respond to those actions, it is necessary to access your personal information (although only to the extent that it is necessary and relevant to the subject-matter).
Legal grounds:
1. The use is necessary for us to comply with our legal obligations
Additional legal ground for special categories of personal information:
1. We need to use the data for others to provide informed healthcare services to you
2. The use is necessary for reasons of the provision of health or social care or treatment or the management of health or social care systems
3. The use is necessary for establishing, exercising or defending legal claims
We are also required by law to conduct audits of health records, including medical information, for quality assurance purposes. Your personal and medical information will be treated in accordance with guidance issued by the Care Quality Commission (England), Health Inspectorate Wales and Healthcare Improvement Scotland

Purpose 8: Managing our business operations such as maintaining accounting records, analysis of financial results, internal audit requirements, receiving professional advice (e.g. tax or legal advice)
In order to do this, we will not need to use your special categories of personal information and so we have not identified the additional ground to use your information for this purpose.
Legal grounds:
1. We have an appropriate business need to use your information which does not overly prejudice you
  
  Purpose 9: Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed.
As a provider of private healthcare services, we need to carry out marketing but are mindful of your rights and expectations in that regard.As a result, we will only provide you with marketing which is relevant to our business and only where you have specifically confirmed your consent to do so.
Legal grounds:
1. We having an appropriate business need to use your information which does not overly prejudice you
2. You have provided your consent
  
  Disclosures to third parties:
We may disclose your information to the third parties listed below for the purposes described in this Privacy Notice. This might include, but is not limited to:

Name
Contact details, such as postal address, email address and telephone number (including mobile number)
Financial information, such as credit card details used to pay us and insurance policy details
Occupation
Emergency contact details, including next of kin
Background referral details

Special Categories Personal Information
1. As one of our patients, MU will hold information relating to your medical condition/treatment(s) which is known as a special category of personal data under the law, meaning that it must be handled even more sensitively.Your GP would be party to this information, but it would not be forwarded to third parties unless with your permission.Special category data we hold about you may include, but is not limited to, the following:
  1. Details of your current and/or former physical or mental health, including information about any healthcare you have received from other healthcare providers such as GPs, dentists or hospitals (private and/or NHS), which may include details of clinic and hospital visits, as well as medicines administered. MU will provide further details below on the manner in which it handles such information.
  2. Details of services you have received.
  3. Details of your nationality, race and/or ethnicity
  4. Details of your religion
  5. Details of any genetic data or biometric data relating to you
  6. Data concerning your sex life and/or sexual orientation, and life style choices

Medical records from your GP
Medical records from other clinicians (including their medical secretaries)
Medical records from your dentist
Medical records from the NHS or any private healthcare organisation
1. Medical records include information about your diagnosis, clinic and hospital visits, medicines administered, recommendations given and treatments received.
  From third parties
2. As detailed in the previous section, it is often necessary to seek information from other healthcare organisations.We may also collect information about you from third parties when:
  1. You are referred for the provision of services including healthcare services
  2. Your consultant liaises with your current or former employer, health professional or other treatment or benefit provider
  3. With your family
  4. With your insurance policy provider
  5. MU deals with experts (including medical experts) and other service providers about services you have received or are receiving from us or them
  6. With NHS health service bodies about services you have received or are receiving from us or them
  7. With credit reference agencies
  8. With debt collection agencies
  9. With Government agencies, including the Ministry of Defence, the Home Office and HMRC
    How will MU communicate with you?

A doctor, nurse, carer or any other healthcare professional involved in your treatment
Other members of support staff involved in the delivery of your care, like receptionists and porters
Anyone that you ask us to communicate with or provide as an emergency contact, for example your next of kin or carer
NHS organisations, including NHS Resolution, NHS England, Department of Health
Other private sector healthcare providers
Your GP
Your dentist
Other clinicians (including their medical secretaries)
Third parties who assist in the administration of your healthcare, such as insurance companies
Private Healthcare Information Network
National and other professional research/audit programmes and registries, as detailed under purpose 4 above
Government bodies, including the Ministry of Defence, the Home Office and HMRC
Our regulators, like the Care Quality Commission, Health Inspectorate Wales and Healthcare Improvement Scotland
The police and other third parties where reasonably necessary for the prevention or detection of crime
Our insurers
Debt collection agencies
Credit referencing agencies
Our third party services providers such as IT suppliers, actuaries, auditors, lawyers, marketing agencies, document management providers and tax advisers
Selected third parties in connection with any sale, transfer or disposal of our business
We may also use your personal information to provide you with information about products or services which may be of interest to you where you have provided your consent for me to do so.
1. We may communicate with these third parties in a variety of ways including, but not limited to, email, post, fax and telephone.
  
  What marketing activities does Manchester Urology carry out?
2. We may also use your personal information to provide you with information about products or services which may be of interest to you where you have provided your consent for us to do so.
  
  Automated Decision Making
3. An automated decision is a decision made by computer without any human input, and there will be no automated decision-making in relation to your diagnosis and/or treatment or other decisions which will produce legal or similarly significant effects.
  
  How long is your personal information kept?
4. We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Notice and in order to comply with our legal and regulatory obligations.
  
  International data transfers
5. We (or third parties acting on my behalf) may store or process information that we collect about you in countries outside the European Economic Area ("EEA").Where it is necessary for your healthcare to make a transfer of your personal information outside of the EEA we will take the required steps to ensure that your personal information is protected.Under such circumstances, we may request your consent for such a transfer.
6. If you would like further information regarding the steps we take to safeguard your personal information, please contact us using the details provided in Paragraph 2 above.
7. Please note that we have listed above the current common transfers of personal data outside of the EEA but it may be necessary, in future, to transfer such data for other purposes.In the event that it is necessary to do so, we will update this Privacy Notice.
  
  Your rights
8. Under the Data Protection Laws you have certain rights in relation to the personal information that we hold about you. These include rights to know what information we hold about you and how it is used.You may exercise these rights at any time by contacting us using the details provided at Paragraph 2 above.
9. There will not usually be a charge for handling a request to exercise your rights.
10. If we cannot comply with your request to exercise your rights we will usually tell you why.
11. There are some special rules about how these rights apply to health information as set out in legislation including the Data Protection Act (current and future), the General Data Protection Regulation as well as any secondary legislation which regulates the use of personal information.
12. If you make a large number of requests or it is clear that it is not reasonable for us to comply with a request then we do not have to respond.Alternatively, we can charge for responding.
  
  Your rights include:
  
  The right to access your personal information
13. You are usually entitled to a copy of the personal information we hold about you and details about how we use it.
14. Your information will usually be provided to you in writing, unless otherwise requested.If you have made the request electronically (e.g. by email) the information will be provided to you by electronic means where possible.
15. Please note that in some cases we may not be able to fully comply with your request, for example if your request involves the personal data of another person and it would not be fair to that person or lawful to provide it to you.
16. You are entitled to the following under the Data Protection Laws.

Under Article 15(1) of the GDPR I must usually confirm whether we have personal information about you.If we do hold personal information about you we usually need to explain to you:
1. The purposes for which we use your personal information
2. The types of personal information we hold about you
3. Who your personal information has been or will be shared with, including in particular organisations based outside the EEA.
4. If your personal information leaves the EU, how we will make sure that it is protected
5. Where possible, the length of time we expect to hold your personal information.If that is not possible, the criteria we use to determine how long we hold your information for
6. If the personal data we hold about you was not provided by you, details of the source of the information
7. Whether we make any decisions about you solely by computer and if so details of how those decision are made and the impact they may have on you
8. Your right to ask us to amend or delete your personal information
9. Your right to ask us to restrict how your personal information is used or to object to our use of your personal information
10. Your right to complain to the Information Commissioner's Office
We also need to provide you with a copy of your personal data, provided specific exceptions and exemptions do not apply.

The right to rectification
1. We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you do not believe this is the case, you can ask us to update or amend it.
  
  The right to erasure (also known as the right to be forgotten)
2. We may update this Privacy Notice from time to time to ensure that it remains accurate, and the most up-to-date version can always be found on the Manchester Urology website.
3. In some circumstances, you have the right to request that we delete the personal information we hold about you.However, there are exceptions to this right and in certain circumstances we can refuse to delete the information in question.For example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercising or defending legal claims.
  
  The right to restriction of processing
4. In some circumstances, we must "pause" our use of your personal data if you ask us to do so, although we do not have to comply with all requests to restrict our use of your personal information.For example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercise or defending legal claims.
  
  The right to data portability
5. In some circumstances, we must transfer personal information that you have provided to you or (if this is technically feasible) another individual/ organisation of your choice.The information must be transferred in an electronic format.
  
  The right to object to marketing
6. You can ask us to stop sending you marketing messages at any time and we must comply with your request. You can do this by contacting us using the details provided at Paragraph 2 above.
  
  The right to withdraw consent
7. In some cases, we may need your consent in order for our use of your personal information to comply with the Data Protection Laws.Where we do this, you have the right to withdraw your consent to further use of your personal information. You can do this by contacting us using the details provided at Paragraph 2 above.
  
  The right to complain to the Information Commissioner's Office
8. You can complain to the Information Commissioner's Office if you are unhappy with the way that we have dealt with a request from you to exercise any of these rights, or if you think we have not complied with our legal obligations.
9. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/
10. Making a complaint will not affect any other legal rights or remedies that you have.
  
  National Data Opt-Out Programme
11. NHS Digital is currently developing a national programme which will go live on 25 May 2018, pursuant to which all patients will be able to log their preferences as to sharing of their personal information.All health and care organisations will be required to uphold patient choices, but only from March 2020.In the meantime you should make me aware directly of any uses of your data to which you object.
  
  Updates to this Privacy Notice
12. We may update this Privacy Notice and will post any changes on the Manchester Urology website, so it’s a good idea to check [www.manchesterurology.org.uk] from time to time.
13. This Privacy Notice was last updated on 21^st July 2018

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