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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
How we use your information
Visitors to our websites
When someone visits www.healthcode.co.uk or www.veda.healthcode.co.uk (“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.
Healthcare practitioners and organisations who register for or subscribe to Healthcode products and services
What we use your personal information for
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.
· 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.
· 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.
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.
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
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.
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.
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
This policy was last updated March 2022.
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, Ground Floor (South), One Causeway Park, Lovett Road, Staines-upon-Thames, TW18 3FD
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 www.gmc-uk.org. 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.