Updated: 28/10/2024

1. Who we are and the scope of this Notice

1.1  Medical Health Limited, trading as Private GP Surgery (MHL, we, us or our), is the data controller for personal information processed in connection with services supplied by MHL. We are registered in England and Wales under company number 12705438 and with the Care Quality Commission under provider ID 1-21255364082.

1.2  This Notice applies when you enquire about, book or receive MHL services; visit or communicate with our clinic; use our website; or communicate with us by telephone, email, SMS, WhatsApp, post or another channel we offer.

1.3  Your booking confirmation or clinical documentation should identify the legal provider responsible for your service. A clinician, laboratory, pharmacy, insurer or other provider may sometimes act as a separate or joint controller and should provide its own privacy information where required.

1.4  This Notice supplements our Terms and Conditions, Cookies Policy, consent information and any service-specific notice. It does not override them.

2. How to contact us

2.1  Questions, rights requests or concerns about our use of personal information may be sent to dpo@privategpsurgery.co.uk or by post to Medical Health Limited, 1-5 Portpool Lane, London EC1N 7UU.

2.2  Our business address is 1 Mulberry Close, Weybridge, Surrey KT13 8RA. Our telephone number is 020 3633 6341.

2.3  Please tell us when your information changes so that clinical and contact records remain accurate.

3. The information we collect

3.1  Depending on your relationship with us, we may process:

• identity and demographic data, such as name, title, date of birth, sex, gender identity, ethnicity, NHS number, photographs and identity documents;
• contact data, such as address, telephone number, email address, GP details, emergency contact and next-of-kin information;
• health and care data, including symptoms, medical history, diagnoses, medicines, allergies, disability, pregnancy information, family history, clinical notes, consent, referrals, prescriptions, observations, scans, images, laboratory results and care plans;
• genetic, biometric or other special-category data where relevant to an authorised clinical service;
• appointment, correspondence and communication data, including enquiries, complaints, safeguarding records and messages sent through email, SMS, WhatsApp or forms;
• payment and transaction data, including amounts, invoices, receipts, refunds and limited payment references. Card providers usually process full card details directly;
• technical and usage data, such as IP address, browser, device, cookie identifiers, pages visited and interaction data;
• marketing preferences and records of consent or objection; and
• information about representatives, parents, carers, attorneys, referrers, employers or insurers where relevant to the service.

3.2  We may create anonymised or aggregated information for audit, planning, training, research or service improvement. Information that has been irreversibly anonymised is no longer personal data.

4. Where information comes from

4.1  We collect information directly from you when you enquire, complete a form, book, pay, attend, communicate with us or use our website.

4.2  Clinicians and staff create information while arranging and delivering care, including consultation notes, reports, results, prescriptions, correspondence and safety or quality records.

4.3  We may receive information from a parent, carer, attorney or other authorised representative; your NHS GP, referrer or another healthcare provider; laboratories, imaging providers and pharmacies; an insurer, employer or commissioning organisation; public authorities; and technical service providers.

4.4  If you provide information about another person, you should have authority to do so and, where appropriate, make them aware of this Notice. This does not prevent disclosure where the law, safeguarding duties or vital interests permit it.

5. Why we use information and our lawful bases

5.1  We use personal information only where data protection law permits it. More than one lawful basis may apply to the same activity.

Purpose	UK GDPR Article 6 basis	Special-category condition
Assessing enquiries, suitability, booking and delivering healthcare	Contract; legitimate interests; legal obligation; vital interests where necessary	Healthcare or social care; explicit consent where specifically appropriate; vital interests
Clinical records, results, prescriptions, referrals and continuity of care	Contract; legal obligation; legitimate interests	Healthcare or social care
Safeguarding, serious-risk management and public-interest disclosures	Legal obligation; vital interests; task in the public interest where applicable; legitimate interests	Substantial public interest; healthcare; vital interests
Payment, refunds, debt management and financial records	Contract; legal obligation; legitimate interests	Usually not applicable; legal claims if special-category data is involved
Quality assurance, clinical audit, training, complaints and incident management	Legal obligation; legitimate interests; task in the public interest where applicable	Healthcare; substantial public interest; legal claims
Regulatory, legal, insurance and professional obligations	Legal obligation; legitimate interests	Healthcare; substantial public interest; legal claims
Website operation, security and service improvement	Legitimate interests; consent where required for non-essential cookies	Usually not applicable
Direct marketing	Consent, or legitimate interests where permitted by electronic-marketing law	We do not use health data for marketing without an appropriate condition and clear justification

5.2  For most clinical processing, MHL does not rely on consent as its Article 6 lawful basis merely because clinical consent is required for care. Where we rely on data-protection consent, you may withdraw it at any time, but withdrawal does not make earlier processing unlawful or prevent processing supported by another lawful basis.

5.3  We will use information for a new purpose only where it is compatible with the original purpose or another lawful basis permits it. We will provide further information where required.

6. Healthcare, referrals and communications

6.1  We use health information to assess suitability, provide consultations, investigations and treatment, prescribe, communicate results, make referrals, arrange follow-up and maintain a complete clinical record.

6.2  We may contact your NHS GP, referring clinician or another healthcare provider where this is necessary for safe direct care, continuity, medicines management or verification. We will respect a reasonable objection unless there is an overriding legal, professional or safety reason to share.

6.3  If you choose email, SMS or WhatsApp, you acknowledge that electronic communications carry privacy and delivery risks. We will use reasonable safeguards and may require a more secure channel for sensitive material. Do not use routine messaging for an emergency.

6.4  Telephone or video consultations are documented in the clinical record. We will not routinely record audio or video without telling you and identifying the applicable lawful basis.

7. Children and people represented by others

7.1  We process children’s information where a service is within MHL’s scope and appropriate consent or authority exists. We may verify parental responsibility and consider a competent child’s rights and wishes.

7.2  Where a patient may lack capacity, we may process information involving an attorney, deputy, advocate, carer or other person where lawful and necessary. We will verify authority where appropriate and continue to protect the patient’s confidentiality.

7.3  Our website is not directed at children acting independently. A child or parent should not submit clinical information through general website or social-media channels except through an authorised service route.

8. Sharing personal information

8.1  We share only information reasonably necessary for the purpose and, where appropriate, require recipients to protect it. Recipients may include:

• MHL clinicians, healthcare professionals, administrative staff and authorised contractors involved in care or service delivery;
• NHS GPs, referring clinicians, hospitals, emergency services, specialists, laboratories, imaging providers, pharmacies, couriers and other healthcare providers;
• practice-management, electronic health record, secure communications, cloud-hosting, IT support, payment, accounting, booking and document-service providers;
• insurers, commissioners, employers or occupational-health referrers where they fund or arrange a service and sharing is lawful and transparent;
• professional advisers, auditors, indemnity providers, legal representatives and debt-recovery providers;
• CQC, ICO, HMRC, courts, police, safeguarding authorities, professional regulators and other public bodies where disclosure is required or permitted by law; and
• a buyer, successor or restructuring adviser if the organisation or service changes ownership, subject to confidentiality and legal safeguards.

8.2  Service providers acting as processors may use information only on documented instructions and under appropriate contractual safeguards. Separate controllers are responsible for their own use of information.

8.3  We do not sell personal information and do not share it with unrelated organisations for their own direct marketing.

9. Confidentiality and disclosures without consent

9.1  We owe duties of confidentiality in addition to data-protection obligations. We normally seek agreement before sharing outside the care team where that is appropriate.

9.2  We may disclose information without consent where required by law, ordered by a court, necessary for safeguarding, needed to prevent or respond to serious harm or crime, justified in the public interest, or otherwise permitted under professional and legal duties. Where practicable and safe, we will explain such disclosure.

10. International transfers

10.1  Some technology or support providers may process information outside the United Kingdom. Where this happens, we use a lawful transfer mechanism, such as UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another lawful safeguard.

10.2  You may contact us for further information about the safeguards relevant to your information. Some details may be withheld where necessary to protect security or confidential commercial information.

11. Security and confidentiality

11.1  We use proportionate technical and organisational measures designed to protect information against unauthorised access, loss, alteration, disclosure or destruction. These include access controls, authentication, secure systems, backups, staff confidentiality, training, supplier checks and secure disposal.

11.2  Access is limited to people who need the information for an authorised purpose. However, no electronic system or transmission method can be guaranteed completely secure.

11.3  We assess suspected personal-data breaches and notify affected people and the ICO where the law requires.

12. How long we keep information

12.1  We retain information only for as long as reasonably necessary for care, continuity, patient safety, legal or regulatory duties, complaints and legal claims. Clinical records are retained under MHL’s records-retention schedule, taking account of the patient’s age, the type of record and applicable professional guidance.

12.2  Financial and tax records are generally retained for six years after the relevant accounting period. Routine enquiries that do not lead to care are normally retained for a shorter period unless needed for a complaint, safeguarding, security or legal reason. Marketing records are retained until consent is withdrawn or an objection is recorded, with suppression information retained to respect that choice.

12.3  Where litigation, investigation, safeguarding or a complaint is anticipated or ongoing, relevant information may be retained longer. At the end of the retention period, information is securely deleted, destroyed or irreversibly anonymised.

13. Marketing and cookies

13.1  Clinical and service communications are not marketing. We may send appointment reminders, preparation instructions, results notifications, safety information and messages about an existing service where necessary.

13.2  We send promotional electronic communications only where permitted by law. You may opt out at any time using the message instructions or by contacting us. Opting out of marketing does not stop necessary care or administrative communications.

13.3  Our website uses cookies and similar technologies. Essential cookies support security and operation. Non-essential analytics or advertising technologies are used only in accordance with our Cookies Policy and consent controls.

14. Automated decision-making

14.1  MHL does not currently make decisions producing legal or similarly significant effects solely by automated means. Technology may support administration or clinical work, but appropriately qualified people remain responsible for material clinical decisions.

14.2  If this changes, we will provide the information and safeguards required by law before such processing begins.

15. Your data-protection rights

15.1  Depending on the circumstances and lawful basis, you may have the right to:

• be informed about processing and request access to your personal information;
• ask us to correct inaccurate or incomplete information;
• ask for erasure or restriction of processing;
• object to processing based on legitimate interests and object at any time to direct marketing;
• receive certain information in a portable electronic format or ask us to transmit it to another controller;
• withdraw consent where processing relies on consent; and
• seek review of a solely automated decision where applicable.

15.2  These rights are not absolute. For example, clinical records may need to be retained despite an erasure request, and access may be limited where disclosure would seriously harm another person or reveal another person’s confidential information.

15.3  We may request information to verify identity and authority. We normally respond within one month, although the law permits an extension for complex or numerous requests. We do not usually charge a fee, but may do so or refuse a request where permitted because it is manifestly unfounded or excessive.

16. Complaints

16.1  Please contact us first at dpo@privategpsurgery.co.uk so that we can investigate your concern.

16.2  You also have the right to complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection. Current contact and complaint information is available at ico.org.uk. You may complain to the supervisory authority in the country where you live or work where another applicable data-protection regime permits.

17. Third-party websites and social media

17.1  Our website may link to third-party websites, services or social-media platforms. Those organisations control their own processing, and their privacy notices apply. MHL is not responsible for how an independent platform uses information you choose to disclose there.

17.2  Do not post confidential health information on public pages. If you contact us through social media, we may move the conversation to a more appropriate channel.

18. Changes to this Notice

18.1  We may update this Notice to reflect changes in law, guidance, technology or our services. The current version and effective date will be published on our website or made available on request.

18.2  Where a change materially affects how we use information already collected, we will provide additional notice where required or reasonably practicable.

19. Contact details

Data controller	Medical Health Limited (trading as Private GP Surgery)
Company number	12705438
Service address	1-5 Portpool Lane, London EC1N 7UU
Business address	1 Mulberry Close, Weybridge, Surrey KT13 8RA
Telephone	020 3633 6341
Privacy email	dpo@privategpsurgery.co.uk
General email	info@privategpsurgery.co.uk