Privacy Statement
PRIVACY STATEMENT
We are iPlato Healthcare Ltd (“we”, “us”, “our”, ” iPlato”), a company registered in England & Wales with company number 6131747 and with registered offices at 1 King St, London, W6 9HR.
We are committed to protecting and respecting your privacy. We are registered as a data controller under UK law, this means we are responsible for determining the purposes for which and the manner in which personal information provided directly to us is processed.
Personal Information is information that identifies you personally such as your name, photo or contact details, or data that can be linked with such information in order to identify you.
Please note, we also provide Patient Services on behalf of GPs, healthcare providers and NHS central services. In these cases, we are simply processing Patient personal information on their instruction. These parties are data controllers in their own right and have their own privacy policies.
What does this statement relate to?
This statement sets out the basis on which any personal information we collect from you, or that you provide to us will be processed by us. Please read this statement carefully to understand our practices regarding your personal information and how we will treat it.
This Statement does NOT relate to the use of the myGP® App. The registration and use of the myGP® App are specifically covered by the App Privacy Policy.
Nor does it cover services provided for patients on behalf of GPs, healthcare providers and NHS central services (“Patient Services”), where we are acting as a data processor only.
This Statement pertains to all other uses of any and all data collected by iPlato in relation to the use of our website and/or other Products and Services.
How do we collect your personal information?
What personal information do you give us / do we collect about you?
You may give us information about you by entering information on our website, filling in forms, or by corresponding with us by phone, e-mail or otherwise. You may also give us information, and we may collect and process information about you resulting from any interactions you undertake or services you request or source from us.
It will be clear at the time what personal information we are requesting from you. If you do not provide the personal information necessary or you withdraw your consent for the processing of your personal information where this information is necessary for us to provide the relevant Services to you, we will not be able to provide these Services to you. You don’t have to provide data and can simply choose to stop using our website or our additional Services.
Information we collect about you and your device.
- Each time you use our website we automatically collect the following information:
- technical information, including the type of device you use, a unique device identifier, mobile network information, your mobile operating system, and time zone setting;
- information either accessed through your device or stored on your device which you have explicitly consented to sharing, and the providence of that data including the device used to collect that data, time, date; and
- details of your use of our site and services.
Information we receive from other sources.
To facilitate the provision of Patient Services, we may receive patient information from GPs or other healthcare providers. Such data may include Patient name, NHS number and relevant contact details as well as sensitive information including booked GP appointments. They provide such data to us to enable us to provide Patient Services on their behalf – we are not the controller for such data.
How do we use your personal information?
We DO NOT use your data for marketing purposes unless you provide us with explicit consent, or you are a business contact and have previously enquired about a similar service.
Personal information you submit to us via our website or that is provided to us by other means is generally required for providing relevant contracted services to you. However, we may also process your data for other reasons. . Specifically, we use information held about you in the following ways:
Where it is in our legitimate interest
- To provide services to you or where we have a Patient Services contract with you
- To register you for our applicable Services and manage your account and for our own internal administrative purposes.
- To provide you with applicable Services and to ensure that our website presents the correct version and data for your device.
- To update you on any developments or information about the applicable Services. These are strictly service emails and do not include marketing.
- To allow us to investigate and address queries, questions and complaints that affect your use of the applicable Services.
- To provide effective and responsive services
- To review and enhance the quality of our services and products through details of your use of our website and applicable Services.
- To allow us respond to general enquiries and feedback from you.
- To protect our business interests and assess our business effectiveness
- For internal operations, including troubleshooting, detection of fraud, log data analysis, testing, security, audit and statistical purposes.
Where we rely on a legitimate interest to process your personal information, before we go ahead with such processing, we carry out a ‘legitimate interest assessment’ to ensure that the processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests.
Where we have a legal obligation
To make disclosures as required by or in compliance with reasonable requests by regulatory bodies including the General Medical Council or Care Quality Commission, or as otherwise required by law or regulation.
Where we have your consent
Where any of the personal information we use contains data concerning health related information and racial or ethnic information, religious or philosophical beliefs, trade union membership data, genetic/ biometric data and sex life or sexual orientation data (together ”sensitive information”), in addition to the above, where you provide this data to us directly through your use of our website or applicable Services, we rely on you having provided us explicit consent to use such data when you provide us with this personal information.
Additionally, you provide us with consent when opting-in to receive communications from us or our parent company Huma Therapeutics Limited (e.g. newsletter / marketing communications).
Where we rely on your GP or healthcare provider’s legal basis for processing
When delivering services on behalf of GPs or other healthcare providers, we may process personal data that includes Sensitive Information; we rely on the lawful basis of the GP or healthcare provider to use such data for healthcare purposes.
When will we share your personal information?
We will not sell your personal information.
We may share your personal data with additional processors which are typically cloud based software providers whose products and services we use, these include the following:
- Email, Office software tools and documentation repositories
- Finance systems
- CRM systems
- Product management, support and development systems
We may disclose your personal information:
- If we are under a duty to disclose or share your personal information to comply with any legal or regulatory obligation; or
- To enforce or apply our Terms and other agreements or to investigate potential breaches of such Terms; or
- To protect the rights, property or safety of iPlato, our customers, or others.
- To our parent company Huma Therapeutics Limited, where you have provided consent.
When providing Patient Services on behalf of a GP or other healthcare provider, we may share relevant Patient information with them where this is required in the course of providing them with applicable Services.
How do we store your personal information?
We may store your personal information at our London office, or for digital data at our secure data centre or on Amazon Web Services, both hosted within the United Kingdom. If applicable all digital data will be encrypted when being transferred to and from us or to our data centre / AWS.
Your data may be transferred outside of the European Economic Area, for example, if we use a cloud service that has host servers located in another country. If your data is transferred outside of the European Economic Area, it is done so under contract, which states how those companies or individuals must keep your data safe.
We take all steps reasonably necessary to ensure that your data is treated securely through strict procedures and security features to prevent unauthorised access to your personal information. However, we cannot guarantee the secure transmission of information via the internet due to security threats outside our control and as such, any transmission of information is at your own risk.
How long do we keep your personal information?
We will retain your personal information for as long as needed to fulfil the purposes outlined in the ‘How do we use your personal information?’ section above or for a period specifically required by applicable regulations or laws. For example, where you are registered for any of our Services, we generally keep your personal information for the duration of time you utilise the Service.
When determining the relevant retention periods, we will take into account factors including:
- our contractual obligations and rights in relation to the information involved;
- legal obligation(s) under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s);
- our legitimate interests where we have carried out balancing tests (see section on ‘How do we use your information’ above);
- (potential) disputes; and
- guidelines issued by relevant data protection authorities.
Otherwise, we securely erase or anonymise your personal information where we no longer require your information for the purposes collected.
What about third party sites?
Our website and other Services we offer may contain links to other independent third-party websites or mobile applications (“Third-party Sites”).
These Third-party Sites are not under our control, and we are not responsible for and do not endorse their content or their privacy policies (if any). You will need to make your own independent judgement regarding your interaction with any Third-party Sites, including the purchase and use of any products or services accessible through them.
What rights do you have?
By law, you have a number of rights (subject to certain conditions) when it comes to your information.
Further information and advice about your rights can be obtained from the Information Commissioners Office (ICO). You can exercise any of these rights by contacting us through our details below.
| Rights | What does this mean? |
| The right to object to processing | You have the right to object to certain types of processing, including processing where we rely on our legitimate interest as the grounds for processing. |
| The right to be informed | You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Policy. |
| The right of access |
You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law. |
| The right to rectification | You are entitled to have your information corrected if it is inaccurate or incomplete. |
| The right to erasure | This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure, there are exceptions. |
| The right to restrict processing | You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We will keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future. |
| The right to data portability | You have rights to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. |
| The right to lodge a complaint | You have the right to lodge a complaint about the way we handle or process your information with the ICO; see details in the ‘contact us’ section below. |
| The right to withdraw consent |
If you have given your consent to anything we do with your information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your information with your consent up to that point is unlawful). Note that such withdrawal in certain circumstance may mean we can no longer continue to provide the Services to you. |
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.
Changes to this Privacy Statement
We update our privacy statement from time to time and any changes we may make to our privacy statement in the future will be posted online and, where appropriate, notified to you. The new terms may be displayed on-screen and you may be required to read and acknowledge them to continue your use of our website and services.
Contact Us
If you have any questions, comments and requests regarding this Policy, please get in touch with us:
iPlato Healthcare Ltd
21-24 Millbank,
London,
SW1P 4QP
Data Protection Officer contact details:
If you are not satisfied with our response to a complaint you have made, or think we are not complying with data protection law, you can make a complaint to the Information Commissioner’s Office:
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Phone number: 0303 123 1113
Email: casework@ico.org.uk
Website: ico.org.uk/concerns/