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Protecting Your Privacy

The Smart Medical Clinics Ltd

Contents of Privacy Notice

  1. Introduction
  2. Who are The Smart Medical Clinics?
  3. Explaining the legal bases we rely on
  4. When do we collect your personal data?
  5. What sort of personal data do we collect?
  6. How and why do we use your personal data?
  7. How we protect your personal data
  8. How long will we keep your personal data?
  9. Who do we share your personal data with?
  10. What are your rights over your personal data?
  11. How can you stop the use of your personal data for direct marketing?
  12. Contacting the Regulator
  13. Any questions?

  1. Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data and keep how we keep it safe.

We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how The Smart Medical Clinics use your data.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

When you are using The Smart Clinics website, Smart Medical Clinics Ltd is the data controller.

  1. Who are The Smart Medical Clinics?

The Smart Medical Clinics – which we’ll refer to as ‘Smart’ in this document, is a doctor-led company, our mission is to strive towards delivering the best possible service for all our patients, whatever their needs, whenever they contact us or visit for a healthcare appointment.

We are based at the Brompton Cross clinic in South Kensington and also have a second clinic in Wandsworth. Both have state-of-the-art medical facilities as well as regular appointments with GPs and a host of other medical and healthcare professionals, including Dentistry at our Brompton Cross clinic.

Both of our London-based clinics were given the WhatClinic Patient Award 2017, having previously won the WhatClinic Customer Service Award 2016. Both these awards are based on customer feedback and go to very few clinics. Please see the individual clinic pages for details of the award and link to WhatClinic brochures.

For simplicity throughout this notice, ‘we’ and ‘us’ means The Smart Medical Clinics.

  1. Explaining the legal bases we rely on

The law on data protection sets out several reasons for which a company may collect and process your personal data, including:

Consent:

In specific situations, we can collect and process your data with your consent.

For example, when you tick a box to receive email newsletters.

When collecting your personal data, we’ll always make clear to you, which data is necessary in connection with a particular service.

Contractual Obligations:

In certain circumstances, we need your personal data to comply with our contractual obligations.

For example, if blood work is required, we’ll share some of your personal information to ‘The Doctors Laboratory’ (TDL), who complete the required tests and return the results to Smart.

Legal Compliance:

If the law requires us to, we may need to collect and process your data.

For example, we can pass on details of people involved in fraud or other criminal activity affecting Smart to law enforcement.

Legitimate Interest:

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we will use your email address to send promotional mailouts from time to time.

We may also use your address details to send you direct marketing information by post, telling you about services that we think might interest you.

  1. When do we collect your personal data?

  • When you visit our website
  • When you create an account with us
  • When you engage with us on social media
  • When you download or install one of our apps
  • When you contact us by any means with queries, complaints etc
  • When you ask one of our Partners to email you information about a product or service
  • When you enter prize draws or competitions
  • When you book any kind of appointment with us or book to attend an event
  • When you choose to complete any surveys we send you
  • When you comment on or review our Doctors and services
  • Any individual may access personal data related to them, including opinions. So, if your comment or review includes information about the Doctor who provided that service, it may be passed on to them if requested
  • When you fill in any forms. For example, if an accident happens in one of our clinics, a member of the team may collect your personal data
  • When you’ve given a third-party permission to share with us the information they hold about you
  • We collect data from publicly-available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law
  • When you use our clinics which usually have CCTV systems operated for the security of both patients and staff. These systems may record your image during your visit.

  1. What sort of personal data do we collect?

If you have a membership account with us: your name, gender, date of birth, address, medical appointments, prescriptions, email, telephone number and payment card details

For example, our Doctors will collect notes from your appointments, details of any complaints or comments you make, details of prescriptions you made, consultancy services you show interest in, web pages you visit and how and when you contact us.

  • Copies of documents you provide to prove your age or identity where the law requires this (including your passport and driver’s licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality
  • Details of your visits to our websites and which site you came from to ours
  • Information gathered by the use of cookies in your web browser
  • Personal details which help us to recommend services of interest

We’ll only ask for and use your personal data collected for recommending services of interest and to tailor your membership with us. Of course, it’s always your choice whether you share such details with us.

  • Payment card information
  • Your comments and product reviews
  • Your image may be recorded on CCTV when you visit a clinic
  • Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

  1. How and why do we use your personal data?

We want to give you the best possible care and medical services. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.

We then use this to provide healthcare services that are most beneficial to you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of care.

Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

Here’s how we’ll use your personal data and why:

  • To make an appointment or provide a medical service by one of our consultants or Doctors. If we don’t collect your personal data during the membership registration process, we won’t be able to book you in and comply with our legal and medical obligations.

For example, your details may need to be passed to a medical consultant to provide the service that you require, and we will keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds.

  • To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best medical service and understanding how we can improve our service based on your experience.
  • To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your appointment activity with us to quickly identify and resolve any problems and protect the integrity of our staff. We’ll do all of this as part of our legitimate interest.
  • To protect our patients, premises, assets and Partners from crime, we operate CCTV systems in our clinics which record images for security. We do this on the basis of our legitimate business interests.
  • To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
  • If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.

Of course, you are free to opt out of hearing from us by any of these channels at any time.

  • To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.

You are free to opt out of hearing from us by post at any time.

  • To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, and legally required information relating to your membership. These service messages will not include any promotional content and do not require prior consent when sent by email or post. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
  • To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
  • To comply with our contractual or legal obligations to share data with law enforcement.

For example, when a court order is submitted to share data with law enforcement agencies or a court of law

  • To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or post. We have a legitimate interest to do so as this helps make our services more relevant to you.

Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences by contacting our reception team.

  • To process your booking/appointment requests (for example with a consultant). Sometimes, we’ll need to share your details with the relevant consultant who is providing the service. We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.

  1. How we protect your personal data

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all areas of our websites and apps using ‘https’ technology.

Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and tokenised to ensure it is protected.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

  1. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as you are member with Smart and it is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or upon request, provided to your new medical provider.

  1. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

  • We provide only the information they need to perform their specific services.
  • They may only use your data for the exact purposes we specify in our contract with them.
  • We work closely with them to ensure that your privacy is respected and protected at all times.
  • If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work with are:

  • IT companies who support our website and other business systems
  • Private medical providers such as medical consultants
  • Direct marketing companies who help us manage our electronic communications with you
  • Data insight companies to ensure your details are up to date and accurate

  1. What are your rights over your personal data?

An overview of your different rights;

You have the right to request:

  • Access to the personal data we hold about you, free of charge in most cases
  • The correction of your personal data when incorrect, out of date or incomplete
  • For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of your membership)
  • That we stop using your personal data for direct marketing (either through specific channels, or all channels)
  • That we stop any consent-based processing of your personal data after you withdraw that consent

You have the right to request a copy of any information about you that Smart holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection Officer, Smart Medical Clinics, PO Box 3627, Bourne End, SL8 5GQ, Bucks, or email info@thesmartclinics.co.uk. To ask for your information to be amended.

If we choose not to action your request, we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

  1. How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

  • Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
  • Write to our head office; Smart Medical Clinics, PO Box 3627, Bourne End, SL8 5GQ, Bucks, or email info@thesmartclinics.co.uk.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

  1. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

  1. Any questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:


This notice was last updated on 24/05/2018

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