Irrefutable Health Privacy Notice – June 2018

Why we collect your personal data and what we do with it

We’re Irrefutable Health (IH) and we’re dedicated to protecting your privacy. We are part of Tri-Health Group (THG) which also comprises of The Willow Kingston, Bluesky Connexions and Function 365 (F365).

When you supply your personal details to Irrefutable Health, they are stored and processed for 6 reasons (the bits in bold are the relevant terms used in the Data Protection Act 2018, which includes the General Data Protection Regulation (GDPR),i.e. the law):

1. We need to collect personal information about you and your health in order to provide you with the best possible treatment. Your request for treatment and our agreement to provide that care constitutes a contract. You can, of course, refuse to provide the information, but if you were to do that we would not be able to provide treatment.
2. We have a “Legitimate Interest” in collecting that information, because without it we couldn’t do our job effectively and safely.
3. We also think that it is important that we can contact you in order to confirm your appointments with us or to update you on matters related to your medical care. This again constitutes “Legitimate Interest”, but this time it is your legitimate interest.
4. When we provide you with care, you become an IH Practice Member and are also entitled to receive THG membership. THG membership permits and controls your THG KeyCard which gives you access to a) the building at authorised times, b) your patient portal via the screens in the clinic, and c) the THG loyalty points programme when it is launched. Your THG KeyCard’s unique identification number enables your access to the building but your personal or medical details are NOT stored on the card. A separate Privacy Notice applies to THG Membership and your THG KeyCard and can be found under the ‘THG Privacy Notice’ tab on this page.
5. Provided we have your consent, we may also send you emails with relevant information, news, offers and updates from the companies within THG.  You may unsubscribe from these emails at any time by clicking on the unsubscribe link included in each email. A separate Privacy Notice relating to the use of the Irrefutable Health website including the use of “cookies” can be found under the ‘IH Website Privacy Notice’ tab on this page.
6. Your anonymised information may also be used to give direction to the development of events, functions and programmes to promote health and wellness for the individual and the community.

We have a legal obligation to retain your records for 8 years after your most recent appointment (or age 25, if this is longer), but after this period you can ask us to delete your records if you wish. Otherwise, we will retain your records indefinitely in order that we can provide you with the best possible care should you need to see us at some future date.

Your records are stored as follows:

• on paper, in locked filing cabinets, and the office is always locked and alarmed out of working hours.
• electronically (“in the cloud”), using a specialist medical records service called F365. This service is fully compliant with GDPR. Access to this encrypted data is password-protected, and the passwords are changed regularly.
• on our office computers. These are password-protected, backed up regularly, and the office is locked and alarmed out of working hours.

We will never share your data with anyone who does not need access without your written consent, and we will never share, rent or sell your contact or health details to any other third parties or companies outside THG for marketing purposes. Only the following people/agencies will have routine access to your data:

• The medical records service F365 which stores and processes our files
• Your practitioner(s) so that they can provide you with treatment
• Our reception staff, because they organise our practitioners’ diaries, and coordinate appointments and reminders
• Other administrative staff, such as our bookkeeper. Administrative staff will not have access to your medical notes, just your essential contact details.
• We also use Mailchimp to coordinate our marketing emails, so your name and email address may be saved on their server.

Anonymised health information may also be provided to medical research processing service providers who process your information on our behalf in accordance with our instructions or as necessitated by law or functions of the business.

From time to time, we may have to employ consultants to perform tasks which might give them access to your personal data (but not your medical notes). We will ensure that they are fully aware that they must treat that information as confidential, and we will ensure that they sign a non-disclosure agreement.

You can view the contact details we have for you and your IH health records including your individualised lifestyle recommendations, laboratory test results, medications and supplements usage charts by logging in to your patient portal. You can access the patient portal in 2 ways:

1. On the screens in the clinic reception using your THG card
2. At home using a password chosen by and known only to you. If you forget your password, you can use the link on the login screen to reset it.

Full details of how to access your patient portal will be supplied when you become a Practice Member.

You have the right to see what personal data of yours we hold, and you can also ask us to correct any factual errors. Provided the legal minimum period has elapsed, you can also ask us to erase your records.

We want you to be absolutely confident that we are treating your personal data responsibly, and that we are doing everything we can to make sure that the only people who can access that data have a genuine need to do so.

Of course, if you feel that we are mishandling your personal data in some way, you have the right to complain.

Requests for personal data or complaints need to be sent in writing to what is referred to in the jargon as the “Data Controller”. Here are the details you need for that:

Data Controller

16 The Triangle

Kingston-upon-Thames

Surrey

KT1 3RT

If you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office.