Our ‘Data’ & ‘Clinical Data’ Policy


WE ARE AN INDEPENDENT CLINIC:


A. CLINICAL SERVICES

We provide General & Specialist Medical Clinical Services. These mostly comprise:

1    Mainstream and Specialist Medical Laboratory Diagnostics

2    Specialist Naturopathic Medicine (including diagnostics), and

3    Specialist Functional Medicine (including diagnostics).

 

We also provide Advanced Psychological & Psychotherapeutic Services. These mostly comprise:

1    Developmental Individual Psychology

2    Interventional Individual Psychology, and

3    Therapeutic Individual Psychology.


B. R&D

We also conduct Research and Development (R&D) into Multipathic Medicine, Personalized & Individual Medicine, Prevention & Treatment of Multi-morbidity, Prevention & Treatment in Genomic Medicine, Prevention & Treatment in Oncological Medicine, Complexity-Modelled Medicine.

Dr Alex has developed a new system for working with an individual’s presentations. Accordingly, and as matter of Good Practice, we also conduct R&D relevant to the safety, efficacy and value of our therapeutic approach.


DATA PROTECTION OFFICER

On account of the sensitivity of any clinical information, the level of importance we place on the handling of your personal data, and the intellectual property aspects of our R&D, our appointed Data Protection Liaison is Dr Alex Concorde, CEO, who oversees all the handling of your personal information. She can in turn liaise with specialist consultants in GDPR/Data Protection as necessary, and can be reached at:

data.protection@concorde.clinic

 

We collect and use different personal information about you for different reasons, depending on our relationship with you, as follows:


Generally the information we receive is:

Medical / Clinical  (including personal and familial)

Psychological / Experiential  (which may include personal or familial, current or historical, clinical psychology and/or psychiatry, and may include information regards ‘deviant’ and recreational behaviours)

Lifestyle / Biographical – in each or both of the above domains.

More details on the sources and components of this type of information is provided below.

Sometimes we will request or receive special types of personal information. This is information relating to your health, genetic, genomic or biometric data, your marital status, sex life, sexual orientation, racial or ethnic origin, occupation and occupational history, political opinions, personal, religious or philosophical beliefs, criminal convictions, and your membership of organisations.

This policy covers all these special types of personal information.

This relates to instances where you provide personal information to us about  other individuals (for example, friends, work colleagues, members of your family, or dependents).

We are responsible for protecting their personal information and using it appropriately. This policy applies to all individuals we have direct contact with, and to all individuals you bring into our sphere of interaction, through your dialogue, or other communication media including images, with ourselves.

 

We never make any telephone or other recordings without your express permission. We never provide a generalised statement of ‘for quality & training purposes’ to precede any form of recording.

For any recording whatsoever, if ever it were made, we would seek your express consent for a specific recording – and if this were obtained, that consent would not be applied to any future recordings.

Audio recordings are almost never a type of information we will process.

How we process the above types of your personal and clinical information, is outlined in the sections below.

How we handle all other data/information about your visits to and use of this website (including your IP address, geographical location, referral source, length of visit, page views and so on), and our  cookies policy, is covered here.

All financial transactions are handled via specialist external payment gateway providers including Paypal and Stripe – either directly (via a Paypal or Stripe button, for example, on our site), or via our Appointments Booking App, or via invoices we provide to you with payment links or BACS payment options.

We do not see, collect or store your bank details, nor credit and debit card details – with the exception that we can see your originating bank details when you pay us via BACS transfer.

 

This section applies if you are a patient/individual currently receiving treatment, or if you are looking into becoming a patient at our clinic.

It includes:

* Information which we have gathered from social media and/or messaging apps, in limited circumstances where content may have been shared via messaging systems during the course of an enquiry, or contact between or about clinical sessions.

* Information which you have shared by email or via our appointment booking site, by telephone and through other written and verbal communication.

* Any clinical information obtained from you through our website (including via our ‘live chat’ facility, ‘leave a message’ facility, website contact form.

* Personal or clincial data provided when you complete a specific form relating to a specified service or product (including diagnostic test booking forms).

* All clinical information obtained during initial face-to-face, phone or e-media consultations.

* And we will collect information directly from you when we deal with any complaints you may have.

* Via enquiries, discussions and referrals with healthcare professionals including NHS doctors, GPs and Hospital Consultants, plus other hospitals or clinics where  you are currently being treated, or who have previously treated, who have received from you permission to share your medical information with us.

 

Depending on the specific nature of your individual enquiry or consultation/s, we may collect the following personal information:

* General information such as your name, address, phone numbers and email addresses, date of birth and gender.

* Employment information such as job title, employment history and professional accreditations if relevant.

* Information about your family, including your dependents.

And:

Personal details may include any of the special types featured above, such as:

* Details of your race and/or ethnicity

* Details of any genetic / genomic data or biometric data

* Details of your sexual orientation (where relevant to your care).

 

Details about your physical, mental and emotional health including information on your medical history and treatments received.

Including but not limited to:

* referral letters or emails from other clinicians
* laboratory test results
* radiology (imaging reports)
* medical examinations
* histology (biopsies) & histopathology
* allergies
* morbidities and co-morbidities
* current and historical medications
* relevant psychological or psychiatric assessments (including quality of life)
* bone assessments
* functional status & capability.

 

There are a number of reasons we use your personal information and for each use we need to have “legal grounds” to do so, such as:

FULFILLING OUR CONTRACT WITH YOURSELF: We need to use your personal information to enter into or perform the contract that we hold with you.

MEETING OUR OBLIGATIONS: We have a legal or regulatory obligation to use such personal information. For example, your data access rights.

OPERATIONAL IMPERATIVES: We have a valid business reason to use your personal information and which is necessary for our everyday business operations and activities (for example, to keep business and accounting records, manage our business operations and to develop and improve our products and services).

When using your personal information for these purposes, we will always consider your rights and interests. In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights. In most instances, we anonymise the data – by removing any identifying details. For example, we code the personal data by provide a unique identifier that is known only to Dr Alex, in lieu of the patient’s name. For example, we redact part of the data to conceal the identity.

When we use your “special categories of personal information”, we must have an additional “legal ground”.

We rely on the following legal grounds when we process your special categories of personal information:

* You have given your explicit consent to our use of your special categories of personal information

* We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves

* We need to use such special categories of personal information for the purposes of preventative medicine, medical diagnosis, provision of healthcare, provision of relevant and appropriate information appertaining to your individual health (be that for educational, preventative, or therapeutic purposes), and treatment and the management of health care systems and services

* We need to use such special categories of personal information for the purposes of medical and scientific research, where that research is not to support measures or decisions with respect to particular individuals.

 

PURPOSE FOR PROCESSING

LEGAL GROUNDS FOR USING YOUR PERSONAL INFORMATION

LEGAL GROUNDS FOR USING YOUR SPECIAL CATEGORIES OF PERSONAL INFORMATION

To follow up on enquiries you make or enquiries submitted on your behalf by your family and friends.

The processing is necessary for legitimate interest in the form of a business reason (to respond to all communications and enquiries we receive).

You have given us your explicit consent.

To provide marketing information to you.

The processing is necessary for legitimate interest in the form of a valid business reason (to send you selected communications about other products and services we offer).

You have given us your explicit consent.

To review how our website is being used and to make improvements to our website.

The processing is necessary for a legitimate interest in the form of a valid business reason (to run our business efficiently and effectively).

PRIVACY, CONFIDENTIALITY, SECURITY & DATA SHARING

**WE WILL ALWAYS KEEP YOUR INFORMATION PRIVATE, CONFIDENTIAL & SECURE**

We will only share relevant and minimal details, where necessary, for the following purposes:

WITH:

Our business partners, suppliers and sub-contractors for the performance of any contract we enter into with you or with them for your benefit.

For example, your name, date of birth, gender & any relevant clinical details may be supplier to our laboratory test facilities for the purpose of their processing of your clinical sample/s, and their interpretation of your result.

For example, your name, address, email address and/or telephone number, but no clinical details, may be supplied to our couriers when we are sending testing kits, or nutraceuticals, or requested supplies to yourself.

WITH:

Healthcare professionals including NHS doctors, GPs, referring Consultants, Pharmacists, and your other primary care provider(s).

Please note that any clinical information or medical details you provide to us, or send to us electronically for assessment of your condition, arrangement of appointment or any other purpose will only be viewed by Dr Alex except in the instances highlighted above, or similar such instances, in accordance with our stipulation of ‘What we will use your information for’.

 

WITH:

Our insurers (if appropriate) and with your health insurance company to facilitate reimbursement to you of costs incurred by you, upon your explicit request.

Our lawyers (if necessary, under strict confidentiality arrangements).

 

IN ADDITION

Your personal & clinical information may be captured and stored using our clinical-grade security and encryption facilities.

For example, our online forms capture your information which is protected during transit & during storage, with immediate encyrpted and automatic depersonalisation, and remains as such until retrieved by the adminstrator, where Dr Alex is the sole administrator.

For example, our servers and hosting facilities are clinical grade with high-grade encryption.

For example, transfer of your laboratory results is conducted via clinical data portals.


ANONYMISED / AGGREGATED ANONYMISED DATA

We may also share anonymised, aggregated data with specialist bio-statisticians, based in the European Economic Area (“EEA“), for the purposes of medical research. And with modelling software developers.

We may share anonymised data with other third parties who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as document management providers, back office system providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers. and the HMRC.

With those who we are under a duty to disclose or share your anonymised data with, in order to comply with any legal obligation, or for the purposes of fraud protection and credit risk reduction.

With third parties, using anonymised data, for the purposes of conducting market research, analytics and reports.

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