Privacy notice for Feature Medical Limited

Feature Medical Limited (we or us ) is a company registered in England and Wales under company number 07451720 . Our registered office is at Virginia House 56 Warwick Road, Solihull, West Midlands, B92 7HX

Our contact details are privacy@featuremedical.co.uk

1 What is the purpose of this document?

1.1 We are committed to protecting and respecting your privacy. This privacy sets out the basis on which any personal data is collected and applies to:

1.1.1 Visitors to our web site at www.featuremedical.co.uk (our site) including those who register with us and those who do not;

1.1.2 Individual patients and test subjects who use Feature Medical’s testing services;

1.1.3 Individual contacts for clients and prospective clients of Feature Medical; and

1.1.4 Individual contractors and services providers who provide services to us (“you”).

1.2 We are a data controller. This means that we are responsible for deciding how we hold and use personal information about you, and for explaining this clearly to you.

1.3 We have appointed a data protection lead (DPL) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPL using the details set out above.

1.4 Please read this privacy notice carefully to understand what we do with your personal information and what rights you have in relation to our activities.

1.5 Our site is not intended for children and we do not knowingly collect data relating to children.

 

2 What is personal data and our lawful basis for processing?

2.1 Personal data, or personal information, means any information relating to an individual from which that person can be identified. There are special categories of more sensitive personal information which require a higher level of protection (see further at section 34, below).

2.2 We will only use your personal information when the law allows us to. Our principal lawful basis for processing is set out below. However, some of our grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

2.3 We may only rely on our legitimate interests (or those of a third party) to process your personal information if your interests and fundamental rights do not override those interests. Where we rely on legitimate interests for our processing, we have set out the relevant interest below.

2.4 Generally, we do not rely on consent as a legal basis for processing your personal data although, if you are a private individual, we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

2.5 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. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

2.6 Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

2.7 Where we need to collect personal data 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). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

 

3 Data  we collect about you

3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.

Medical Data includes details of your health, current medical concerns, medical records, details about medications you take or treatment you are undergoing, your health history, allergies, pregnancy, medical samples such as swabs or urine samples and any subsequent results from these samples and any other relevant information about your wellbeing that you may provide to us.

Contact Data includes email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Usage Data includes information about how you use our website, and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

3.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

3.4 As part of our usual course of business, we will collect Medical Data but generally we do not collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, we may process information:

3.4.1 to ensure meaningful equal opportunity and diversity and inclusion monitoring and reporting;

3.4.2 where it is needed to protect your vital interests (or someone else’s interests) and you are not capable of giving your consent;

3.4.3 where it is necessary to establish, exercise or defend a legal claim;

3.4.4 where you have manifestly made the information public; or

3.4.5 otherwise with your explicit consent. 

 

4 How is your personal data collected?

4.1 We use different methods to collect data from and about you including through:

4.2 Direct interactions. You may give us your Identity, Contact, Medical and Financial Data by filling in forms , having a consultation with a member of our staff,  by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

4.2.1 receive healthcare services from us;

4.2.2 complete any consent form for testing or other form as part of the services;

4.2.3 contact us about our services or

4.2.4 make a booking;

4.2.5 subscribe to our mailing lists or request marketing to be sent to you;

4.2.6 give us feedback, make a complaint or contact us;

4.2.7 make an enquiry about working with us.

4.3 Third parties or publicly available sources: We will receive personal data about you from various third parties including your employer when our services are used on set, including

4.3.1 Contact and Identity Data from your employer, the production team or other third party who refers you to Feature Medical for care or testing;

4.3.2 Medical Data from any third party healthcare professionals involved in your care;

4.3.3 Medical Data comprising test results from third parties who carry out testing on our behalf.

4.4 Automated technologies or interactions. As you interact with our website, we will automatically collect Usage and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy, for further details.

4.5 Automated decision-making:   Automated decision-making takes place when an electronic system uses personal information to make a decision 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.

 

5 Our Lawful basis for processing

Information	How we use your information	How our use complies with the law
Patients
Contact Data and Identity Data We collect your name and contact details, including telephone number and email address	This may be passed to other healthcare professionals with a duty of confidentiality to provide care to you; The record will be archived once your care has ended	This information is required to enable us to record all observations and treatments given to you. This is a legitimate interest to enable us to provide your care safely.
Medical Data
We may ask you for your previous medical history, including background to your condition and treatment, current and past medication, hospital admissions and discharge information, lifestyle information (smoking and drinking levels) and other background information relating to your medical condition and related treatment.	This information is used to form a clinical judgement on your presenting complaint and how best to manage your care. We may need to discuss care pathways with other healthcare providers using this information.	This information is required to enable us to record all observations and treatments given to you. This is a legitimate interest to enable us to provide your care safely. Our processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of the employee, and the provision of healthcare by medical professionals who are subject to professional secrecy obligations.
From time to time you may voluntarily provide us with personal data, including special category data	This information is used to ensure appropriate provision of services to you.	We process information voluntarily provided to us, with your consent.
Business Related Contacts
For customers and prospective customers, we collect the name, job title and business contact information of your individual employees and other representatives.	This information is used to respond to your enquiry.	This information is needed to be able to conduct our business with you as part of our legitimate business interest.
We collect name and contact details for healthcare professionals involved in delivering the service to patients.	This is held in our HR database and on staffing rotas.	This is a legitimate reason for the purpose of providing auditability of patient care.
For suppliers and prospective suppliers of services to our business, we collect the name, job title and business contact information of your individual employees and other representatives.	our business, we collect the name, job title and business contact information of your individual employees and other representatives. We use this information to enable you to provide us with your goods or services	This information is needed to be able to conduct our business with you as part of our legitimate business interest
We use the business contact information provided for individual employees and other representatives of our clients and suppliers (including prospective clients and suppliers) to provide updates and information about our services	We use this to provide you with information about our services.	This information is needed to be able to conduct our business with you as part of our legitimate business interest.

 

6 Sharing your information

6.1 We share your personal information with third party contractors and service providers to the extent necessary to provide our services.

6.2 We share your information with other third parties as follows:

6.2.1 If you are using our medical services as part of your employment we may share specific test results with your employer or provide them with an assessment of your fitness to work;

6.2.2 We will share any medical samples you provide with appropriate medical testing facilities;

6.2.3 We may share your individual health record as permitted by the Records Management Code of Practice for Health and Social Care 2021 (as updated from time to time);

6.2.4 We share your name address, date of birth and other details as to record the details for any sample. This is shared on a pseudonymised basis with the lab to conduct tests on your sample and with the professionals who take your samples.

6.2.5 We may share your test results with your employer and other companies and organisations that you work with such as relevant broadcaster(s), co-producer(s) or other third-party production companies involved in the production, including but not limited to, insurers or service providers such as providers of medical services or physical security for workplace safety purposes

6.2.6 We may share your personal data other than Medical Data with:

a) our regulators, professional advisors, insurance provider and auditors;

b) HMRC or other government or law enforcement agencies;

c) if we sell the business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets;

d) payment service providers when you purchase products via the website;

e) if we have a legal obligation to do so; and

f) or the purposes of fraud protection and credit risk reduction.

6.3 The categories of third parties listed above use your personal data for their own purposes and are responsible for their own compliance with data protection legislation.

6.4 We also share your data with third-party service providers who provide services to our business such as our web site host server, IT support and maintenance service, cloud storage provider and email exchange server, delivery services and other businesses that provide certain services on our behalf.  All of our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes.

 

7 Data security

7.1 We have put in place:

7.1.1 Appropriate technical and organisational security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

7.1.2 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.

Transferring information outside the EEA

7.2 Any personal information that you submit to us will be held on secure servers, based within the European Economic Area (EEA).

7.3 If we are required to transfer your information outside the EEA, we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.

7.4 If you are based outside the EEA we may transfer personal information to the correspondence address you provide to us to the extent necessary to complete your order. We will take all reasonable steps to ensure that such transfers are secure. By instructing us from outside the EEA you agree that such transfer is necessary for us to complete your order.

 

8 How long will we keep your personal information for?

8.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

8.2 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, regulatory, tax, accounting or other requirements.

8.2.1 We keep individual health records as required by law in accordance with our records management Policy and The Code of Practice for H&SC 2021.

8.3 We keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes and for the purpose of any legal claims.

8.4 In some circumstances you can ask us to delete your data: see your rights below for further information.

8.5 In some circumstances we will anonymise your personal data (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.

 

9 Your rights

9.1 You have the following rights:

9.1.1 to be told what we are doing with your personal information. We do this by providing you with this privacy notice;

9.1.2 to correct or update the personal information we hold about you.

9.1.3 to object to the processing of your personal information;

9.1.4 to request a copy of the personal information we hold about you;

9.1.5 to ask us to delete the information that we hold about you where there is no good reason for us continuing to process it;

9.1.6 to ask us to stop processing your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground and where there is no good reason for us continuing to process it;

9.1.7 to ask us to restrict how we use your personal information for a period of time if you claim that it is inaccurate and we want to verify the position or in some limited other circumstances;

9.1.8 to ask us to send your personal information to another organisation in a computer-readable format;

9.1.9 to complain to the Information Commissioner’s office if you are unhappy with our use of your personal data: you can do this at https://ico.org.uk/concerns/. Do contact us straight away if you consider that we are not handling your personal information properly so we can try and sort the problem out.

9.2 If we delete your personal information or restrict our use of it, we will not be able to provide our services to you.

9.3 If you want to exercise any of your rights, please contact privacy @featuremedical.co.uk . We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).

Last Updated 08 November 2022