Privacy Policy

Who we are

Healthcode Limited (“Healthcode”) is owned jointly by Aviva, AXA Health, Bupa, Nuffield Hospitals and VitalityHealth.  It is the policy of Healthcode to take steps to ensure that your information is kept confidential and secure and to otherwise protect and respect your privacy.  As well steps set out in this policy, Healthcode also follows the Code of Practice for Information Security Management Systems as set out in ISO/ISE 27001.

This policy details what information we collect from you, why we collect it, what we do with it and how it might be shared.


Healthcode as a data controller and/or a data processor

In providing products and services, Healthcode may be acting as a data controller and/or as a data processor on behalf of certain third parties (such as medical practitioners, hospitals and/or insurers) who will themselves be the data controllers.  Where acting as a data controller, Healthcode will comply in full with this policy.  Where acting as a data processor, Healthcode will be required to act on the instructions of the data controller (and the data controller’s privacy policy will apply) but, unless inconsistent with the instructions and requirements of the data controller, Healthcode will still endeavour to comply with this policy.


How we use your information

We will only use your personal data when law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • With your consent and please note that you have the right to withdraw your consent at any time by contacting us. (Consent).
  • Where we need to perform a contract, we are about to enter into, or have entered into, with you (Fulfilling contracts).
  • 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 (Our legitimate interests).
  • Where we need to comply with a legal or regulatory obligation (Our legal duty).

This privacy policy tells you what to expect when Healthcode collects personal information.  It applies to information we collect about:

  • Visitors to our websites
  • Healthcare practitioners and organisations who register for or subscribe to Healthcode products and services


Visitors to our websites

When someone visits,, or (“Healthcode’s sites”) we use a third party service (with your Consent), Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. This information is used to track visitor use of the website and to compile statistical reports on website activity.  This information is only processed in a way which does not identify anyone.

Use of Cookies

You can read more about how we use cookies on our Cookies page.  For more information about cookies generally, visit or


Healthcare practitioners and organisations who register for or subscribe to Healthcode products and services

What we use your personal information for

Our reasons

Our legitimate interests

Type of personal information

·  To manage our relationship with you or your business.

·  To develop new ways to meet our customers’ needs and grow our business.

·  To study how our customers, use products and services from us.

·  To provide guidance and updates about our products and services.

·  Fulfilling contracts

·  Our legitimate interests

·  Our legal duty

·  Keeping our records up to date, working out which of our products and services may interest you and telling you about them.

·  Developing products and services, and what we charge for them.

·  Being efficient about how we fulfil our legal duties.

·  Contact

·  Consents

·  Communications

·  Transactional

·  To develop and manage our brands, products and services.

·  To pilot new products and services.

·  Fulfilling contracts

·  Our legitimate interests

·  Our legal duty

·  Developing products and services, and what we charge for them.

·  Being efficient about how we fulfil our legal and contractual duties.

·  Behaviour

·  Contact

·  Communications

·  Transactional

·  To deliver our products and services (the facilitation of the processing of electronic medical bills for payment; providing practice management tools; and the facilitation of the processing of personal information for private medical insurance recognition and hospital practising privileges providing The Private Practice Register).

·  To make and manage customer payments.

·  To manage fees, charges and interests due on customer accounts

·  To collect and recover money that is owed to us.

·  To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning communications, governance and audit.

·  Fulfilling contracts

·  Our legitimate interests

·  Our legal duty

·  Being efficient about how we fulfil our legal and contractual duties.

·  Contact

·  Demographic

·  Profile

·  Practice details

·  Financial

·  Appraisal

·  Contractual

·  Qualifications & Certificates

·  Indemnity

·  Insurer details

·  Special types of data

·  Consents

·  Technical

·  Transactional

·  Behaviour

·  To exercise our rights set out in agreements or contracts.

·  Fulfilling contracts


·  Contact

·  Contractual

·  Communications

·  Transactional


Types of Personal Information

 We use different kinds of personal information and group them together like this:

Type of personal information



Your name, correspondence and billing address, email address and phone number.


This includes details about your work or profession, professional identification details such as registration numbers and regulatory body information, personal description and photographs.


This includes biography and resume, areas of interest, research interests and publications.

Practice details

This includes current and past post, hospital location, specialties and secretary information.


Financial and bank account information.


Dates of appraisals


Details about the products and services we provide to you.

Qualifications and Certificates

Details about education or training courses including copies of certificates and qualifications


This includes medical indemnity cover and renewal dates

Insurer details

Medical insurer specific information, such as insurer name, identification details

Special types of data

Where special type of personal data is given, Healthcode will obtain explicit consent for processing, special categories of personal information may include but are not limited to:

·         disclosure barring service

·         fitness to practise information

·         ethnic origin

·         occupational health records


Any permissions, consents or preferences that you give us.  This includes things like how you want us to contact you, consent forms.


What we learn about you from letters, emails and conversations between us.


Details on the devices and technology you use.  Internet protocol (IP) address used to connect to your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.


Details about payments you make to us.


Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Healthcode’s sites (including date and time); products and/or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call Healthcode’s customer service number.


Where we collect personal information from

We may collect personal information about (or your business) from other companies and from these sources:

Information you give us:

  • When you register for and/or subscribe to our products and services via forms on Healthcode sites.
  • When you talk to us on the phone or in person
  • When you participate in discussion boards, or other social media functions on Healthcode sites
  • In emails and letters
  • In customer surveys
  • If you take part in our competitions or promotions
  • When you report a problem with Healthcode sites


Data from third parties:

Healthcode may receive information about you if you use any of the other websites Healthcode operates or the other products and services Healthcode provides, in which case this information may be shared internally and combined with other information Healthcode has collected.

  • Healthcode are also working closely with third parties (including, for example, business partners, hospitals, insurers, regulatory bodies, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers) and may receive information about you from them. Specifically:
  • insurers and hospitals: in the context of administering clinical and financial records; and
  • General Medical Council (“GMC”): Healthcode holds a republication licence to the GMC’s database of the List of Registered Medical Practitioners (“LRMP”). Some of the information Healthcode holds about you has been sourced from the LRMP based on your GMC reference number.1


Data we process on your behalf when you use our services:

  • information that is necessary to process invoices including patient demographics, diagnosis information, type of care delivered and treatment details and practitoner information.


Who we share your personal information with

Healthcode may share your information with these organisations:

  • any member of its group, which means its subsidiaries, ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
  • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. Healthcode do not disclose information about identifiable individuals to advertisers, but Healthcode may provide them with aggregate information about users (for example, Healthcode may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). Healthcode may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). Healthcode may make use of the personal data it has collected from you to enable Healthcode to comply with its advertisers' wishes by displaying their advertisement to that target audience; and
  • analytics and search engine providers that assist Healthcode in the improvement and optimisation of the Healthcode sites.


We may need to share your personal information with other organisations to provide you with the product or service you have chosen:

  • business partners, suppliers, insurers, hospitals and sub-contractors for the performance of any contract Healthcode enter into with them or you. For further information of our suppliers visit


Healthcode may also disclose your information to third parties:

  • in the event that it sells or buys any business or assets, in which case Healthcode may disclose your information to the prospective seller or buyer of such business or assets;
  • if Healthcode or substantially all of its assets are acquired by a third party, in which case information held by it about its customers will be one of the transferred assets; and/or
  • if Healthcode are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply any of the Healthcode terms that we have in place with you from time to time; or to protect the rights, property, or safety of Healthcode, its customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.


In accordance with the above, certain information that you provide to Healthcode when using its products and/or services will be passed to third parties (including insurers and hospitals) who will then become data controllers of this information.  As such, the processing of the information by these third parties will be undertaken in accordance with the privacy policies of these third parties.  Despite this, however, Healthcode undertakes that certain categories of information that you provide to Healthcode will be deemed to be “non-publishable” by either Healthcode or certain of these third parties.  Healthcode will tell you (via such means as Healthcode deems appropriate, such as in the terms and conditions) of the categories of information that are to be “non-publishable”.


International data transfers

We, or third parties acting on our behalf, may need to transfer Personal Information outside of the United Kingdom (UK). We will always take steps to ensure that any transfer of Personal Information outside of the UK is carefully managed to protect your privacy rights and ensure that adequate safeguards are in place. This might include transfers to countries that the UK considers will provide adequate levels of data protection for your Personal Information (such as countries in the European Economic Area) or putting contractual obligations (SCCs) in place with the party we are sending information to.



We may use your personal information to tell you about relevant products and services and offers.   The personal information we have for you is made up of what you tell us, and the data we collect when you use our services.  We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’.  This is when we have a business or commercial reason to use your information. 

You can ask us to stop sending you marketing messages by contacting us at any time by emailing This email address is being protected from spambots. You need JavaScript enabled to view it., or you can opt out via the application within user preferences.  Healthcode will inform you (before collecting your data) if it intends to use your data for such purposes.

Whatever you choose, you will still receive other important information such as changes system updates and changes to your existing products and services.



Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information.  This information is used to track visitor use of the website and to compile statistical reports on website activity.  You can set your browser to refuse all or some browser cooked or to alert you when websites set or access cookies.  If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

For further information about the cookies we use, please see our Cookie Policy.  For more information about cookies generally, visit or


Other websites

Where there are links to third party sites from the Healthcode sites, Healthcode emphasises that it has no control over these third party sites, their content or the way in which they collect or use information. If you follow links to third party sites from the Healthcode sites, your information will be subject to the privacy policies of those sites. Healthcode therefore strongly advises users to check the privacy policy on any third party site they visit.


Healthcode takes all reasonable steps to protect your information. All information collected and processed by Healthcode is stored on a secure server. Healthcode’s security includes the use of user authentication (username and password), where applicable, the use of secure FTP connection with insurers and applicable third parties.

In addition, Healthcode takes the following security measures:

  • implementing procedures to comply with all relevant statutory requirements and monitoring internal procedures periodically to ensure that there is such compliance;
  • implementing and complying with the applicable data protection legislation in place from time to time;
  • making all officers of Healthcode, its employees and sub-contractors aware of the rules and procedures laid down by Healthcode from time to time in respect to the security of information and the importance of confidentiality. Officers of Healthcode, employees and sub-contractors have a duty to follow the rules laid down by Healthcode and to co-operate with Healthcode to ensure that this policy is effective. Healthcode will, where it considers it appropriate, take disciplinary action against any officer or employee who fails to comply with these rules and procedures;
  • ensuring the proper training, supervision and instruction of employees dealing with your information;
  • requiring all sub-contractors to enter into confidentiality agreements in respect to information they acquire from Healthcode;
  • not retaining information for longer than is necessary for the purposes set out in this policy; and
  • establishing a committee chaired by a Healthcode director to review confidentiality and security arrangements on a regular basis and to put in place measures to maintain and, where possible, improve information security.


Unfortunately, the transmission of information via the internet is not completely secure. Although Healthcode will do our best to protect your information, Healthcode cannot guarantee the security of your data transmitted to Healthcode’s sites; any transmission is at your own risk. Once Healthcode has received your information, it will use the above procedures to try to prevent unauthorised access.


Where we store your personal data

The data that we collect from you will only be stored by Healthcode within the UK.  However, other third parties that are not acting as data processors for Healthcode, but who receive your data from Healthcode (such as insurers or hospitals), may transfer and store your data at a destination outside the UK.  You should carefully check the privacy policies of those third parties to see how and where your data is being processed.


How long we keep your personal information

We can only keep your personal data for as long as necessary for the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

The precise length of time we hold your personal data for varies depending on the individual circumstances, but in determining 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.

We regularly review our retention periods to ensure that we are not keeping your data for longer than necessary.  Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us using the details provided under Contact.


Your Rights

How to get a copy of your personal information: you may request a copy of the personal information we hold about you. If you require a copy of some or all your personal information, please email or write to Healthcode as the address detailed under Contact. 

Letting us know if your personal information is incorrect: Healthcode want to make sure that your personal information is accurate and up to date.  Subject to the product or service you have registered for or subscribed to you will have the facility to maintain up to date personal information.  You may ask us to correct or remove information you think is incomplete or inaccurate, though we may need to verify the accuracy of the new data you provide us.

Transfer: you may request that we transfer your personal data to you or a third party.  We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

What if you want us to stop using your personal information?

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it.  This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

You may request that we transfer your personal data to you or a third party.  We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

You may request that we restrict how we process your personal data.  This enables you ask us to suspend the processing of your personal data in the following scenarios:

  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful, but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.


How to withdraw your consent: where we have relied on your consent to process your personal data you will have the right to withdraw your consent at any time.  However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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 personal 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.


Changes to the policy

Any changes Healthcode may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or via a messaging system / pop-up (as appropriate) within the Healthcode product that you use. Please check back frequently to see any updates or changes to this policy.

This policy was last updated April 2021.



Please contact us if you have any questions about our privacy policy or information we hold about you by email or write to us at the below address.

You have the right to request a copy of the information that we hold about you.  If you would like a copy of some or all of your personal information.

Healthcode Limited, Rourke House, Watermans Business Park, The Causeway, Staines-upon-Thames, TW18 3BA

Tel: +44 (0) 330 900 4900 

Fax: +44 (0) 01784 263 155

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.


1Healthcode’s systems are updated every 24 hours, Monday to Friday (except bank holidays) to reflect the information held in the LRMP. Where our system has not refreshed, a more up to date version is available from the GMC website Any information read from the GMC database may be provided to the applicable party or parties as part of your application. Please review carefully and contact the GMC directly if you need to change your records.