Welcome to the Healthcare Communication Matter’s privacy policy.
Healthcare Communication Matters respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
We have used a Glossary at the end of the document to help you to understand the meaning of some of the terms used in this privacy policy.
Purpose of this privacy policy
This privacy policy aims to give you information on how Healthcare Communication Matters collects and processes your personal data through your use of this website, including any data you may provide through this website, for example when you submit an enquiry, complete the online Patient Information Support Form, purchase our services, take part in a survey or being involved in our case studies.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Healthcare Communication Matters Limited is the controller and responsible for your personal data (collectively referred to as “HCM”, “we”, “us” or “our” in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: Healthcare Communication Matters Limited
Email address: lfurber@healthcarecommunicationmatters.co.uk
Postal address: Neptune House, Nelson Court, Staffordshire Technology Park, Stafford, ST18 0WQ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in November 2020.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Direct Interactions. You may give us your Identity, Contact and Medical Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes the personal data you provide when you:
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To receive and consider an enquiry submitted to us
| (a) Identity (b) Contact | Legitimate Interests (in order to consider how we can deliver our services to you) |
To deliver training courses
| (a) Identity (b) Contact (c) Marketing and Communications
| Performance of a contract with you
|
The provision of the online Patient Information Support Tool
| (a) Identity (b) Contact (c) Medical
| Consent |
Collection of quantitative and/or qualitative data for research, writing an academic paper, making grant applications or service evaluation purposes, such as holding focus groups with patients, carrying out interviews with patients, applying for grant applications, carrying out surveys and analysng the results.
| (a) Identity (b) Contact (c) Medical | Consent |
Analysis of any completed questionnaires relating to the Patient Information Support Form or other similar services offered
| (a) Identity (b) Contact | Consent |
To complete evaluation surveys relating to the services provided by us
| (a) Contact (b) Identity (c) Profile | Necessary for our legitimate interests (to keep our records updated and to study how clients and patients use our services) |
To manage our relationship with you which will including notifying you about changes to our terms or privacy policy
|
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications
|
Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
|
To use data analytics to improve our website, services, marketing, client relationships and client and patient experiences when using the website. | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of clients and categories of patients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|
To make suggestions and recommendations to you about services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications
| Necessary for our legitimate interests (to develop our services and grow our business) |
Marketing
If we have worked with you either as a client or a patient, or you have shown an interest in being involved with our services (for example sharing your story for our blog, being involved in a focus group etc), we would like to contact you from time to time to let you know about new projects we are involved in or new services we are offering which we think would be of interest to you. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or worked with us previously and you have not opted out of receiving that marketing.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service experience surveys or other similar feedback requests.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Change of purpose
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Where Identity, Contact and Medical Data is collected from you (including but not limited to) as part of interviews, case studies, focus groups, completion of the patient support tool form or by completing a feedback questionnaire, we may share your personal data with the parties set out below for the purposes set out in the table above. Before any such data is shared with any parties set out below, it will be pseudonymised, so that the parties receiving that data will not be able to directly identify you.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
To determine 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, regulatory, tax, accounting or other requirements.
We acknowledge the sensitive nature of certain data provided and use and take steps to mitigate the risks associated with holding this data, These steps include the pseudonymisation of the data as soon as reasonably practicable and then either the deletion of this pseudonymised data from our files in accordance with our retention period or the annoymisation of the data.
We will annonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data (please see Your Legal Rights explanation in the Glossary at section 10). If you wish to exercise any of the rights, please contact us.
No fee usually required
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 could refuse to comply with your request in these circumstances.
What we may need from you
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 person 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
THIRD PARTIES
External Third Parties
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that 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.
Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to 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. 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.
Withdraw consent at any time where we are relying on consent to process your personal data. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.