Privacy Policy

How Willow Health uses your information to provide you with care

This service keeps medical records confidential and complies with the General Data Protection Regulation (GDPR) and Data Protection Act 2018.

We hold your medical record so that we can provide you with the most accurate advice, safe medical care and treatment.

We will also use your information so that this service can check and review the quality of the care we provide. This helps us with the ongoing improvement of our services to you.

The confidentiality of your information is very important to us and we comply with UK data protection legislation and medical confidentiality guidelines of the General Medical Council.

We will share relevant information from your medical record with other health care professionals if they need to provide you with care. For example, if you are referred to another private service, or when we send any prescriptions to your chosen pharmacy. A condition of providing care at Willow Health is the ability to share the care given to you with your GP.

You have the right to object to information being shared for your own care. Please speak to the Willow Health director if you wish to object. You also have the right to have any information errors corrected.

The Type of personal information we collect

We currently collect and process the following information:

  • Personal identifiers – name, address, date of birth, telephone number, e-mail address
  • Confirmation of ID will be checked by the clinic
  • Your usual GP name and address
  • Your medical history
  • Details of your consultations and contacts with Willow Health
  • Information about your personalised treatment plans and any prescriptions provided
  • Record of your consent to treatment
  • Any correspondence relating to you from yourself or other health care professionals

How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following reasons:

  • You have opted to seek information, advice, and treatment at Willow Health

We use the information that you have given us :

  • To create a personal medical record on our system
  • To be able to provide you with high quality care and meet your needs
  • To practise safely and in a timely manner

How we store your personal information

Your information is securely stored digitally in a clinical software system called Semble.

The information is only accessible and seen by authorised members of Willow Health. Our computer system has secure audit trails and we back up information routinely. The practice has a confidentiality policy that all staff adhere to.

We may use anonymised data for audit purposes to monitor, measure and improve the quality of the care we provide.

For more information about this, please speak to the director of Willow Health.

Why do we hold information about you?

We need to keep comprehensive and accurate personal medical records about patients to be able to provide you safe and appropriate medical care. If patients continue to follow up at Willow Health, we ask you if there has been any change to your personal details and medical history.

Obtaining an accurate medical history will help us identify patients who might be at risk of developing certain medical conditions. We may search our database to identify patients who may be at risk to offer them additional care or support.

Safeguarding

Sometimes we need to share information so that other people, including healthcare staff, children or others with safeguarding needs, are protected from risk of harm. These circumstances are rare.

We do not need your consent to do this.

The Willow Health Safeguarding policy is supported by the  Adult Support and Protection (Scotland) Act 2007 and s designed to protect those adults who are unable to safeguard their own interests and are at risk of harm.

We are required by law to provide you with the following information about how we handle your information:

Data Controller contact details:

Dr Lauren Colquhoun

Willow Health

1 Union Street

Bridge of Allan

FK9 4NS

Email: info@willow-health.co.uk

Company Registration number SC776490

Purpose of the processing

·       To give direct health to individual patients. For example, when a patient agrees to a referral for direct care, such as to a hospital, relevant information about the patient will be shared with the other healthcare staff to enable them to give appropriate advice, investigations, treatments and/or care.

·       To check and review the quality of care. (This is called audit and clinical governance.)

·       To advise patients of changes to services or new services.

Lawful basis for processing

These purposes are supported under the following sections of the GDPR:

·       Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and

·       Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…’

Healthcare staff will also respect and comply with their obligations under the common law duty of confidence.

Recipient or categories of recipients of the processed data

Disclosure of information

To provide safe medical care we may need to disclose personal information about you including to:

·       Healthcare professionals and staff in this practice

·       Hospitals (if required, e.g. referral or emergency transfer)

·       Out of hours services

·       Other organisations involved in the provision of direct care to individual patients

·       Regulatory bodies e.g. Health Improvement Scotland

Information would only be shared with your consent and you would be copied into all correspondence if you wished.

Disclosure will take place on a ‘need-to-know’ basis. Only those individuals or organisations who need to know to provide care for you will be given the information.

In very limited circumstances or when required by law or a court order, personal data may have to be disclosed to a third party not connected with your health care. The service would take legal advice before disclosing data in these very limited circumstances and where possible you will be informed of these requests for disclosure.

Requesting your consent under GDPR

We will continue to obtain consent from you as a patient be it implied, verbal or written, for the treatment or procedures undertaken at Willow Health. This will be in line with the General Medical Council’s guidelines and will be recorded appropriately in your medical records.

In addition to this: 

We require your consent under GDPR to communicate with you by phone, email or post.

We will:

·       Ask you to opt-in to any marketing or other communications

·       Offer choices as to how to communicate with you

·       Offer you the option to withdraw consent to that communication at any time

Collection of personal information when visiting our website

You may choose to share your personal information with us if you submit an enquiry on our website, and it is a requirement when using the booking system. When you submit personal information, you consent to our use of the information as set above under ‘Requesting your consent under GDPR’.

Use of personal information

We will use personal information given to us as stated in this policy, and with any additional statements appearing on forms used for submitting personal information. We will not disclose personal information to any third parties without obtaining your prior consent unless we are required by law to do so.

If you submit an enquiry, we will use your personal information to administer and respond to your enquiry. We will store securely the information you supply and our response.

If you comment or complain about our services, we may use your personal details to access your medical records.

Your data protection rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us info@willow-health.co.uk if you wish to make a request.

Data we get from other organisations

We may receive information about your health from other organisations who are involved in providing you with health care for example if you are referred to a consultant. This allows us to keep your personal medical record as up to date as possible. 

We do not have access to your NHS GP medical record.

Retention period

Personal Medical records will be kept in line with the law and national guidance. At Willow Health we only use digital medical records which will be stored indefinitely until government regulations change.

Access to your medical records

You have the right of access to the data that we hold about you and to receive a copy. Formal applications for access must be in writing to the director of Willow Health.

If you do not agree

If you do not wish personal data that we hold about you to be disclosed or used in the way that is described in this Code of Practice, please discuss the matter with your doctor.

You have the right to object; however, this may affect our ability to provide you with medical care. You have a right to withdraw your consent at any time, however this will not be retrospective.

Cookies and Internet Protocol (IP) logging

When you visit our website, our server will record your computer’s IP address (the unique numerical address given to every computer connected to the Internet) and the time and duration of your visit.

This website uses cookies, a piece of data that may be stored on your computer when you visit a website; these cookies store the anonymised IP address (the last digit group of the IP is removed before storage).

Cookies and your IP address will be used to track the pages you visit on our website. We will use this information to analyse the way our site is used, and to administer and improve the accessibility of our site. We will not use it for any other purpose. You may disable the use of cookies in your Internet browser without affecting your use of our website.

Links

From time to time our website may contain links to other sites. We are not responsible for the content or privacy practices of third parties that run other websites.

Right to complain

If you have any concerns about our use of your personal information, you can make a complaint to us in writing and send to:

Willow Health

1 Union Street

Bridge of Allan

FK9 4RX

 

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:           

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk