How we handle your personal data at The London Clinic

1. Who ‘we’ are 

When we outline to you how we take care of your data you will notice we use the words ‘the Clinic’, ‘we’, ‘us’ or ‘our’. This means we are referring to The London Clinic (also known as Trustees of The London Clinic Limited). We are a limited company and charity registered in England and Wales. Find out more information about our company and charity status.  

We are, in almost all circumstances, what is called the ‘Data Controller’ of your personal data. We are responsible for deciding how we hold and use your data, for taking care of your data and ensuring that anyone we work with, who might need to access your data, also takes care of it and follows our rules. If there is ever a situation where another organisation or person is the Data Controller of your data, we will let you know.   

Before we explain what data we collect, why we collect it and what we do with your data, if you have any questions or concerns, you can reach our Data Protection Officer via emailing dataprotection@thelondonclinic.co.uk.  

2. How we use your data  

There are some specific scenarios where we want to give you a little more information. These include:  

• How we use your data to operate this website
• How we use your data to support your care. whether you are a patient of The London Clinic or you are referred to us through another medical professional, insurance company and/or international medical service
• How we use your data to keep in touch with you about our fundraising activities
• How we use your data to progress your job application. 

For each of the above points, we will outline each service we offer and why we use your data, where we ‘need’ it or where it is voluntary to share with us. We will also highlight what your rights are over that data. 

3. What data we collect from you  

We will need different pieces of information from you for different purposes which will be driven by your interaction with us. We will always keep the data we need to a minimum, and internally will ensure that only those with a legitimate need to see your data can do so.  

The pages linked in Section 2 outline what information we need in order to meet each purpose, however, as a summary, the sorts of data we collect fall into the following categories:  

4. How we lawfully process your data 

We use your data for a range of different purposes. To do so lawfully we need to have a legal basis for doing so. We normally process your personal data if it is: 

• Necessary to provide you with your care - to enable us to carry out our obligations to you, arising from any contract entered between us. This may include the provision of services or treatments to you and related matters, such as billing, accounting and audit, credit or other payment card verification and anti-fraud screening
• In our, or a third party's legitimate interests to do so (e.g. in helping with medical safety, quality assurance and medical research, or managing our business operations). We will be utilising legitimate interests as our lawful basis under Article 6 UK GDPR in limited circumstances where the processing of your data does not impede your rights and freedoms. For more information, please refer to the ICO’s guidance on legitimate interests
• Required by any applicable law (i.e. to meet certain legal obligations placed on us by English law as a healthcare provider
• With your explicit consent for example: direct consumer marketing communications, participating in a clinical research project or clinical trial and/or engaging with third parties.

As part of your treatment, we are required to get your consent to the medical treatment itself. However, this consent shouldn’t be mistaken for consent to process personal data. As a private healthcare provider, we process your personal data in order to comply with our obligations under our contract with you. Generally, we will only ask for your consent to data processing if there are no other legal grounds to process. In these circumstances, we will always aim to be clear and transparent about why we need your consent and what we are asking it for. Where we are relying on consent to process personal data you have the right to withdraw your consent at any time by contacting us using the details below and we will stop the processing for which consent was obtained. 

To process special category data (i.e. personal data that needs more protection because it is sensitive), we rely on additional legal grounds and generally, they are as follows: 

• Necessary for the purposes of medical diagnosis, to provide health or social care treatment, or to manage health or social care systems and services. This may also include monitoring whether the quality of our services or treatment is meeting expectations
• With your explicit consent
• It is necessary to establish, make or defend legal claims or court action
• It is necessary so that we can comply with employment laws
• It is necessary for a public interest purpose in line with any laws that are applicable. This should assist in protecting the public against dishonesty, malpractice or other seriously improper behaviour for example, investigating complaints, clinical concerns, regulatory breaches or investigations e.g. the Care Quality Commission (‘CQC’), the General Medical Council (‘GMC’) or the Information’s Commissioner Office (‘ICO’).  

5. Where we get your data from   

We very rarely obtain information about you without your prior knowledge. We will collect your personal data either from you directly, from your Consultant, or from a referring body.  

There might be some instances where we receive data about you from other organisations or people. For example, if we receive a piece of information from your General Practitioner (‘GP’), embassy or insurance company, you should know about it prior to us receiving the data or we may confirm we have received it as part of your interaction with your care team.  

6. Who we share your data with  

Where possible, we avoid sharing your data with anyone outside of The London Clinic. There will be, however, situations where this is not possible, and a third party will need to access or be given a copy of your personal data.  

In Section 2, the linked pages state who we are likely to share your data with (and why) for each service. Some examples have been included below:  

• Consultants who are Data Controllers in their own right (for example, in order to deliver your care)
• Suppliers or collaborators (for example, in order to provide bespoke 3D prosthetics, or to support our IT infrastructure)
• Regulators, authorities or government bodies (for example, in order to resolve a complaint that has been raised or to conduct professional body safety reviews)
• Professional advisers, including external legal advisors, insurance companies and medical experts (for example, in order to resolve a legal claim or dispute, to provide pre and/or post procedure reviews)
• Third parties for the purposes of debt collection
• Third party payment processor companies. For the avoidance of doubt, The London Clinic will not store any of your payment card details
• Delivery companies for the purposes of transportation
• Third parties for health, wellbeing & patient safety analysis
• Third party service providers for the purposes of storage of information and confidential destruction. 

Where a third-party Data Processor is used, we ensure that, in addition to their obligations under Data Protection Laws, they operate under contractual restrictions which aim to safeguard the confidentiality and security of your information. 
 

7. Where in the world your data is physically sitting 

We use systems, technology and/or support vendors who may store or have access to physical or cloud storage which resides both in the UK and abroad. This includes countries both within the European Economic Area (‘EEA’) and, in limited circumstances, those further afield, for example the United States of America.  

Where we store or share personal data with a third party in a country outside of the UK or EEA, we will put appropriate safeguards in place to protect that data in accordance with the applicable Data Protection Laws and the ICO’s guidance. These range from a contract with that third-party supplier through to technical measures to protect it while it gets there.  

We may also need to share your data with a third party in a country outside of the UK if you are a resident of another country and that third party is authorising or providing part of your care.  

8. How long we keep your data 

We only keep your data as long as it is required either by English Law, health regulatory best practice, codes of practice, or our own legitimate business needs in line with our corporate policies.  

The full range of retentions varies per record, some are only kept short-term, and some kept more long-term if they relate to legal matters or long-term medical conditions. Below are the considerations we use to determine the appropriate retention period: 

• The purposes for which we process your personal data and whether we can achieve those purposes through other means
• The applicable legal, regulatory, tax, accounting or other requirements
• The amount, nature, and sensitivity of the personal data
• The potential risk of harm from unauthorised use or disclosure of your personal data. 

9. How we protect your data 

As you can appreciate, we cannot give you the full list of specific measures we have in place to prevent your data from being accidentally lost, used, accessed in an unauthorised way, altered or disclosed. However, please rest assured that we are committed to ensuring a high level of protection for your data while it is in our management.    

Examples of some of the measures we have in place include:   

• Agreed organisation-wide standards on security and data handling    
• IT technical controls to limit access to your personal information only to those employees, agents, contractors and other third parties who have a business need-to-know  
• Physical security controls on our buildings and wards  
• Contractual controls with third parties (‘our house, our rules’)
• Training and awareness for all employees and Consultants
• Key roles in our organisation with specialist knowledge on Information Governance, Data Protection and Cyber Security to ensure your information is always protected. 

10. What your rights are in connection with your data 

Where we use your information with your consent, you control how that data is used and shared by The London Clinic. However, where we are using your data under a legal obligation or other grounds, your rights under Data Protection Laws are more restricted. For example, where we feel we need to share or use data to save your life very few of the Data Protection rights apply.  

A summary of all the Data Protection rights and how they apply to your interactions with us is below:  

How you can find out more information

If you have any questions or queries about how we handle your personal data at The London Clinic, please get in touch at dataprotection@thelondonclinic.co.uk.   

Last updated

Version 2.0. This notice was last updated in February 2022.