0161 491 2534 (7:00am-22:00hrs) SECRETARY@VIVIENLEES.CO.UK

Privacy Policy

VIVIEN LEES LTD – PRIVACY NOTICE

Introduction

1. This Privacy Notice sets out details of the information that I as Vivien Lees (clinician) trading as Vivien Lees Ltd am responsible for whilst undertaking your treatment. It lays out what information we may collect from you and how that information may be used. Please take your time to read this Privacy Notice carefully.

This Privacy Notice

a) provides you with a detailed overview of how we will manage your data, from the point at which it is gathered and onwards.

b) will give you all the details you need on how we use your information, and how we will comply with the law in doing so. We may also, with your specific agreement, contact you with marketing materials.

c) sets out your rights in respect of your personal information, and how to exercise them. You can, for instance, seek access to your medical information, object to us using your information in particular ways and request rectification of any information which is inaccurate.

2. In this Privacy Notice we use ” we” or ” us” or ” our” to refer to Vivien Lees and medical secretary and practice manager (Vivien Lees Ltd.) who are using your personal information in order to provide your treatment.

3. Our practice address is:

The Beeches Consulting Centre
Mill Lane
Cheadle
Cheshire
SK8 2PY

4. If you would like further information about any of the matters in this Privacy Notice or have any other questions or complaints about how we collect, store or use your personal information, please contact us at the address above.

5. As a clinician I maintain my own set of patient records. If and when you come into hospital for investigation or treatment then the hospital has its own set of patient records. With respect to the records that are held by Vivien Lees Ltd then Vivien Lees acts as Data Controller in respect of your personal information which is held within those records. This means that Vivien Lees Ltd must comply with the data protection legislation and relevant guidance when handling your personal information. To the extent relevant to our practice, you can expect Vivien Lees as a clinician (including her medical secretary and practice manager) to handle your information in line with this Privacy Notice. This includes using your personal information as set out in more detail below.

6. Clinicians are expected to handle your personal data in accordance with the principles set out within this Privacy Notice. This means that whenever we use your personal data, we will only do so as set out in this Privacy Notice.

7. Patients’ medical details are considered as one of the “special categories of personal information” (otherwise known as “special categories of data”). As such we need to have this personal information about your health in order to treat you.

8. If you provide personal information to us about other individuals (including medical or financial information) you should inform the individual about the contents of this Privacy Notice. We will process such information in accordance with this Privacy Notice.

9. In addition, you should note that in the event you amend data which we already hold about you (for instance by amending a pre-populated form) then we will update our systems to reflect the amendments. Our systems will continue to store historical data.

Personal information

10. As a patient of Vivien Lees Ltd, the personal information we hold about you may include the following:

a) Name
b) Contact details, such as postal address, email address and telephone number (including mobile number)
c) Financial information, such as credit card details used to pay us
d) Occupation
e) Emergency contact details, including next of kin
f) Background referral details

Special Categories Personal Information

11. As a patient of Vivien Lees Ltd, we will hold information relating to your medical treatment which is known as a special category of personal data under the law, meaning that it must be handled even more sensitively. The special categories of personal information we hold about you may include the following:

a) Details of your current or former physical or mental health. This may include information about any healthcare you have received (previously on our own service and with other healthcare providers such as GPs, ophthalmologists, hand therapists, dentists or hospitals (private and/or NHS)) or need, including about clinic and hospital visits and medicines administered. We provide further details below on the manner in which we handle such information.
b) Details of services you have received from us
c) Details of your nationality, race and/or ethnicity
d) Details of your religion
e) Details of any genetic data or biometric data relating to you
f) Data concerning your sex life and/or sexual orientation

12. The confidentiality of your medical information is important to us. We make every effort to prevent unauthorised access to and use of information relating to your current or former physical and mental health. In doing so, Vivien Lees Ltd complies with UK data protection law, including the General Data Protection Act 2018, and all applicable medical confidentiality guidelines issued by professional bodies including, but not limited to, the General Medical Council and the Royal College of Surgeons of England.

13. From 25 May 2018, the current Data Protection Act will be replaced by the EU General Data Protection Regulation (GDPR) and a new Data Protection Act. The provisions in this statement apply from this date onwards.

How do we collect your information?

14. We may collect personal information from a number of different sources including, but not limited to:

a) GPs
b) Dentists
c) Other hospitals, both NHS and private
d) Mental health providers
e) Commissioners of healthcare services
f) Clinicians (including their medical secretaries)

Directly from you:

15. Information may be collected directly from you when:

a) You enter into a contract with Vivien Lees Ltd for the provision of healthcare services
b) You use those services
c) You complete enquiry forms on the Vivien Lees Ltd. website
d) You submit a query to us including through our website, by email or by social media
e) you correspond with us by letter, email, telephone (all incoming and outgoing calls from/to patients may be recorded) or social media
f) You take part in our marketing activities

From other healthcare organisations:

16. Our patients will usually receive healthcare from other providers in addition to Vivien Lees Ltd, and so in order to provide you with the best treatment possible we may have to collect personal information about you from other organisations. These may include:

a) Medical records from your GP
b) Medical records from your clinician (including their medical secretaries)
c) Medical records from your dentist
d) Medical records from the NHS or any private healthcare organisation

17. Medical records include information about your clinic and hospital visits, diagnosis, specialist imaging including radiographs, and medicines administered.

From third parties:

18. As detailed in the previous section, it is often necessary to seek information from other healthcare organisations. We may also collect information about you from third parties when:

a) You are referred to us for the provision of services including healthcare services
b) We liaise with your current or former employer, health professional or other treatment or benefit provider
c) We liaise with your family
d) We liaise with your insurance policy provider
e) We deal with experts (including medical experts) and other service providers about services you have received or are receiving from us
f) We deal with NHS health service bodies about services you have received or are receiving from us
g) We liaise with credit reference agencies
h) We liaise with debt collection agencies
i) We liaise with Government agencies, including the Ministry of Defence, the Home Office and HMRC

How will we communicate with you?

19. In order to communicate with you, we are likely to do this by telephone, SMS, email, and/or post.
If we contact you using the telephone number(s) which you have provided (landline and/or mobile), and you are not available which results in the call being directed to a voicemail and/or answering service, we may leave a voice message on your voicemail and/or answering service as appropriate.

20. However:
a) to ensure that we provide you with timely updates and reminders in relation to your healthcare (including basic administration information and appointment information (including reminders)), we may communicate with you by SMS and/or unencrypted email where you have provided us with your email address) in each case where you have expressed a preference in the patient registration form to be contacted by SMS and/or email.

b) to provide you with your medical information (including test results and other clinical updates) and/or invoicing information, we may communicate with you by email (which will be encrypted) where you have provided us with your email address and have expressed a preference in the patient registration form to be contacted by email. The first time we send you any important encrypted email eg one that we are not also sending by post or which requires action to be taken, we will endeavour to contact you separately to ensure that you are able to access the encrypted email you are sent.

c) If we have your mobile number or your email address we may use this method of communication to contact you regarding patient surveys which are for the purpose of improving our service or monitoring outcomes and are not a form of marketing.

21. Please note that, although providing your mobile number and email address and stating a preference to be communicated by a particular method will be taken as an affirmative confirmation that you are happy for us to contact you in that manner, we are not relying on your consent to process your personal data in order to correspond with you about your treatment. As set out further below, processing your personal data for those purposes is justified on the basis that it is necessary to provide you with healthcare services.

Audits and Surveys

22. As detailed above, we may contact you to ask you to participate in surveys which are part of ongoing surveys/ audits (Patient Reported Outcome Measures) with respect to your treatment. If you choose to complete a PROMs survey you will also receive subsequent surveys following your treatment to help establish the benefit you have gained from that treatment.

The surveys will largely be sent post-treatment by email or SMS. This is not a form of marketing and the surveys do not try to sell you any further products or services; it is solely to gather information relating to your experiences of Vivien Lees Ltd., for the purposes of improving the quality and safety of the services we offer to future patients. Participation in the surveys is entirely voluntary. You may decide not to complete the surveys and you will have the option to unsubscribe from receiving further survey invitations.

23. The results of hospital-initiated surveys are shared with PHIN and for NHS patients the results are shared with NHS England. An initial invitation asking you to participate may be sent to you before your treatment takes place. This may be by post, SMS, email or in person when you attend the hospital for treatment.

What are the purposes for which your information is used?

24. We may ‘process’ your information for a number of different purposes, which is essentially the language used by the law to mean using your data. Each time we use your data we must have a legal justification to do so. The particular justification will depend on the purpose of the proposed use of your data. When the information that we process is classed as “special category of personal information”, we must have a specific additional legal justification in order to use it as proposed.

25. Generally we will rely on the following legal justifications, or ‘grounds’:

a) Taking steps at your request so that you can enter into a contract with Vivien Lees Ltd to receive healthcare services

b) For the purposes of providing you with healthcare pursuant to a contract between you and Vivien Lees. We will rely on this for activities such as supporting your medical treatment

c) We have an appropriate business need to process your personal information and such business need does not cause harm to you. We will rely on this for activities such as quality assurance, maintaining our business records, developing and improving our products and services and monitoring outcomes

d) We have a legal or regulatory obligation to use such personal information

e) We need to use such personal information to establish, exercise or defend our legal rights

f) You have provided your consent to our use of your personal information

26. Note that failure to provide your information further to a contractual requirement with us or a clinician may mean that we are unable to set you up as a patient or facilitate the provision of your healthcare on Vivien Lees Ltd. systems.

27. We provide further detail on these grounds in the sections below.

Appropriate business needs

28. One legal ground for processing personal data is where we do this in pursuit of legitimate

interests and those interests are not overridden by your privacy rights. Where we refer to use for our appropriate business needs, we are relying on this legal ground.

29. Special categories of personal information includes information about your:

a) Health
b) Sex life
c) Sexual orientation
d) Ethnicity
e) Political opinions
f) Religious or philosophical beliefs
g) Genetic or biometric information

The right to object to other uses of your personal data

30. You have a range of rights in respect of your personal data. This includes the right to object to Vivien Lees Ltd using your personal information in a particular way (such as sharing that information with third parties), and we must stop using it in that way unless specific exceptions apply. This includes, for example, if it is necessary to defend a legal claim brought against us, or it is otherwise necessary for the purposes of your ongoing treatment.

You will find details of our legal grounds for each of our processing purposes below. We have set out individually those purposes for which we will use your personal information, and under each one we set out the legal justifications, or grounds, which allow us to do so. You will note that we have set out a legal ground, as well as an ‘additional’ legal ground for special categories of personal information. This is because we have to demonstrate additional legal grounds where we are using information which relates to a person’s healthcare, as we will be the majority of the times we use your personal information.

Purpose 1: To set you up as a patient on Vivien Lees Ltd. systems which could potentially include including carrying out fraud, credit, anti-money laundering and other regulatory checks.

31. As is common with most business, we have to carry out necessary checks in order for you to become a patient. These include standard background checks, which we cannot perform without using your personal information.

32. Legal ground: Taking the necessary steps so that you can enter into a contract with us for the delivery of healthcare.

33. Additional legal ground for special categories of personal information: The use is necessary for reasons of substantial public interest.

Purpose 2: To provide you with healthcare and related services.

34. Clearly, the reason you come to us is to provide you with healthcare, and so we have to use your personal information for that.

35. Legal grounds:

a) Providing you with healthcare and related services
b) Fulfilling our contract with you for the delivery of healthcare

36. Additional legal grounds for special categories of personal information:

a) We need to use the data in order to provide healthcare services to you
b) The use is necessary to protect your vital interests where you are physically or legally incapable of giving consent

Purpose 3: For account settlement purposes

37. We will use your personal information in order to ensure that your account and billing is fully accurate and up-to-date.

38. Legal grounds:

a) Our providing you healthcare and other related services
b) Fulfilling our contract with you for the delivery of healthcare
c) Our having an appropriate business need to use your information which does not overly prejudice you

39. Additional legal grounds for special categories of personal information:

a) We need to use the data in order to provide healthcare services to you
b) The use is necessary in order for us to establish, exercise or defend our legal rights

Purpose 4: For medical audit/research purposes:

Clinical audit

40. Vivien Lees Ltd may process your personal data for the purposes of local clinical audit – ie an audit carried out to assess outcomes for patients and identify improvements which could be made for the future. We are able to do so on the basis of a legitimate interest and the public interest in statistical and scientific research, and with appropriate safeguards in place. You are, however, entitled to object to us using your personal data for this purpose, and as a result of which we would need to stop doing so. If you would like to raise such an objection then please contact our Data Protection Officer using the details provided in paragraph 5 above.

41. We may also be asked to share information with UK registries for which ethical approval is not necessarily required but which form part of the National Clinical Audit programme, hosted by NHS England and who provide a list of National Clinical Audit and Clinical Outcome Review programmes and other quality improvement programmes which we should prioritise for participation.

42. A full copy of the current list can be found at https://www.hqip.org.uk/list which comprises the national organisations with whom we regularly share data for the purposes of audit. We may also share your data with other audit programmes which are set up by professional associations.

43. We may do so without your consent provided that the particular audit registry has received statutory approval, or where the information will be provided in a purely anonymous form, otherwise your consent will be needed. In those circumstances, the relevant registry organization may have consent processes of their own so any questions in that regard should be directed to the organisations themselves, otherwise we will obtain that consent from you.

Medical research

44. Vivien Lees Ltd may also participate in medical research and shares data with ethically approved third party research organisations.

45. We will share your personal data only to the extent that it is necessary to do so in assisting research and as permitted by law. Some research projects and/or registries have received statutory approval such that consent may not be required in order to use your personal data. In those circumstances, your personal will be shared on the basis that:

Legal grounds:
a) We have a legitimate interest in helping with medical research and have put appropriate safeguards in place to protect your privacy

Additional legal grounds for special categories of personal information:
b) The processing is necessary in the public interest for statistical and scientific research purposes

46. In the event that consent is required then either the research organisations will obtain this from you themselves, and so any questions in that regard should be directed to them, or we will take consent from you.

Purpose 5: Communicating with you and resolving any queries or complaints that you might have.

47. From time to time, patients may raise queries, or even complaints, with Vivien Lees Ltd and we take those communications very seriously. It is important that we resolve such matters fully and properly, and so we will need to use your personal information in order to do so.

48. Legal grounds:
a) Our providing you with healthcare and other related services
b) Our having an appropriate business need to use your information which does not overly prejudice you

49. Additional legal grounds for special categories of personal information:

a) The use is necessary for the provision of healthcare or treatment pursuant to a contract with a health professional
b) The use is necessary in order for us to establish, exercise or defend our legal rights

Purpose 6: Communicating with any other individual that you ask us to update about your care and updating other healthcare professionals about your care.

50. In addition, your General Practitioner and other healthcare professionals or organisations may need to know about your treatment in order for them to provide you with safe and effective care, and so we may need to share your personal information with them. Further details on the third parties who may need access to your information is set out at section 65 below.

51. Legal grounds:

a) Our providing you with healthcare and other related services
b) We have a legitimate interest in ensuring that other healthcare professionals who are routinely involved in your care have a full picture of your treatment

52. Additional legal ground for special categories of personal information:
a) We need to use the data in order to provide healthcare services to you
b) The use is necessary for reasons of substantial public interest under UK law
c) The use is necessary in order for us to establish, exercise or defend our legal rights

53. We also participate in initiatives to monitor safety and quality, helping to ensure that patients are getting the best possible outcomes from their treatment and care. The Competition and Markets Authority Private Healthcare Market Investigation Order 2014 established the Private Healthcare Information Network (“ PHIN”), as an organisation who will monitor outcomes of patients who receive private treatment. Under Article 21 of that Order, we are required to provide PHIN with information related to your treatment, including your NHS Number in England and Wales, CHI Number in Scotland or Health and Care Number in Northern Ireland), the nature of your procedure, whether there were any complications such as infection or the need for readmission/admission to an NHS facility and also the feedback you provided as part of any PROMs surveys. PHIN will use your information in order to share it with the NHS, and track whether you have received any follow-up treatment. We will only share this information with PHIN if you have provided your consent for us to do so.

54. The records that we share may contain personal and medical information about patients, including you. PHIN, like us, will apply the highest standards of confidentiality to personal information in accordance with data protection laws and the duty of confidentiality. Anyinformation that is published by PHIN will always be in anonymised statistical form and will not be shared or analysed for any purpose other than those stated. Further information about how PHIN uses information, including its Privacy Notice, is available at www.phin.org.uk.

Purpose 7: Complying with our legal or regulatory obligations, and defending or exercising our legal rights

55. As a provider of healthcare, we are subject to a wide range of legal and regulatory responsibilities which is not possible to list fully here. We may be required by law or by regulators to provide personal information, and in which case we will have a legal responsibility to do so. From time to time, clinicians are also the subject of legal actions or complaints. In order to fully investigate and respond to those actions, it is necessary to access your personal information (although only to the extent that it is necessary and relevant to the subject-matter).

56. Legal grounds:
a) The use is necessary in order for us to comply with our legal obligations

57. Additional legal ground for special categories of personal information:
a) We need to use the data in order for others to provide informed healthcare services to you
b) The use is necessary for reasons of the provision of health or social care or treatment or the management of health or social care systems
c) The use is necessary for establishing, exercising or defending legal claims

58. As detailed at section 60, we participate in initiatives to ensure that patients are getting the best possible outcomes from their treatment and care. The records that we share may contain personal and medical information about patients, including you. With respect to PHIN we will only share information with them with your consent. PHIN, like us, will apply the highest standards of confidentiality to personal information in accordance with data protection laws and the duty of confidentiality. Any information that is published by PHIN will always be in anonymised statistical form and will not be shared or analysed for any purpose other than those stated. Further information about how PHIN uses information, including its Privacy Notice, is available at www.phin.org.uk.

59. We are also required by law to conduct audits of health records, including medical information, for quality assurance purposes. Your personal and medical information will be treated in accordance with guidance issued by the Care Quality Commission (England), Health Inspectorate Wales and Healthcare Improvement Scotland.

Purpose 8: Providing improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers) including conducting post treatment surveys

60. Vivien Lees Ltd is a quality-conscious organisation, and always looking to learn from patients’ experiences in order to improve the experience for future patients. With that in mind, we will use your personal information to identify where such improvements can be made.

61. Legal grounds:
a) Our having an appropriate business need to use your information which does not overly prejudice you

62. Additional legal ground for special categories of personal information:
a) We need to use the data in order to manage the healthcare services we deliver, including carrying out surveys (which are not a form of marketing) in order to identify and carry out any necessary improvements

Purpose 9: Managing our business operations such as maintaining accounting records, analysis of financial results, internal audit requirements, receiving professional advice (eg tax or legal advice)

63. In order to do this, we will not need to use your special categories of personal information and so we have not identified the additional ground to use your information for this purpose.

64. Legal grounds:
a) Our having an appropriate business need to use your information which does not overly prejudice you

Purpose 10: Disclosures to third parties:

65. We may disclose your information to the third parties listed below for the purposes described in this Privacy Notice.

This might include:
a) A doctor, nurse, carer or any other healthcare professional involved in your treatment
b) Other members of support staff involved in the delivery of your care, like receptionists and porters
c) Anyone that you ask us to communicate with or provide as an emergency contact, for example your next of kin or carer
d) NHS organisations, including NHS Resolution, NHS England, Department of Health
e) Other private sector healthcare providers
f) Your GP
g) Your dentist
h) Your clinician (including their medical secretaries)
i) Third parties who assist in the administration of your healthcare, such as insurance companies
j) Private Healthcare Information Network (PHIN)
k) National and other professional research/audit programmes and registries, as detailed under purpose 4 above
l) Government bodies, including the Ministry of Defence, the Home Office and HMRC
m) Our regulators, like the Care Quality Commission, Health Inspectorate Wales and Healthcare
n) The police and other third parties where reasonably necessary for the prevention or detection of crime
o) Our insurers
p) Debt collection agencies
q) Credit referencing agencies
r) Our third party services providers such as IT suppliers, actuaries, auditors, lawyers, marketing agencies, document management providers and tax advisers
s) Selected third parties in connection with any sale, transfer or disposal of our business
t) Third parties from whom we order products related to your treatment with us, such as prostheses, named patient prescriptions, products to be used by you at home or administered by ourselves in the clinic as part of your recommended treatment programme

66. We may communicate with these third parties in a variety of ways including, but not limited to, email, post, fax and telephone.

How long do we keep personal information for?

67. We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Notice (a summary of our Retention Policy can be found at https://www.spirehealthcare.com/media/19524/spire-healthcare-retention-summary-patientdata-may-2018.pdf and in order to comply with our legal and regulatory obligations.

68. If you would like further information regarding the periods for which your personal information will be stored, please contact us at the Beeches (address as in 3 above) for further details.

International data transfers

69. We (or third parties acting on our behalf) may store or process information that we collect about you in countries outside the European Economic Area (” EEA”). Where we make a transfer of your personal information outside of the EEA we will take the required steps to ensure that your personal information is protected.

a) To the extent that it is necessary to do so, Vivien Lees Ltd. may transfer your personal data outside of the EEA to the United States to the following specific types of third party:

i. Suppliers of bespoke prostheses eg wrist/distal radioulnar joint prosthesis and other prosthesis, device or consumables suppliers

70. We will only do so to the extent that it is relevant and necessary. The United States and the EEA have in place a framework, known as Privacy Shield, to facilitate compliance with data protection obligations when transferring personal data. Privacy Shield has been assessed by the EU Commission, and deemed to provide adequate protection to personal data.

71. Please note that we have listed above the current common transfers of personal data outside of the EEA but it may be necessary, in future, to transfer such data for other purposes. In the event that it is necessary to do so, we will update this Privacy Notice.

Your rights

72. Under data protection law you have certain rights in relation to the personal information that we hold about you. These include rights to know what information we hold about you and how it is used. You may exercise these rights at any time by contacting us (see 3 above).

73. There will not usually be a charge for handling a request to exercise your rights.

74. If we cannot comply with your request to exercise your rights we will usually tell you why.

75. There are some special rules about how these rights apply to health information as set out in legislation including the Data Protection Act (current and future), the General Data Protection Regulation as well as any secondary legislation which regulates the use of personal information.

76. If you make a large number of requests or it is clear that it is not reasonable for us to comply with a request then we do not have to respond. Alternatively, we can charge for responding.

Your rights include:

The right to access your personal information

77. You are usually entitled to a copy of the personal information we hold about you and details about how we use it.

78. Your information will usually be provided to you in writing, unless otherwise requested. If you have made the request electronically (eg by email) the information will be provided to you by electronic means where possible.

79. Please note that in some cases we may not be able to fully comply with your request, for example if your request involves the personal data of another person and it would not be fair to that person to provide it to you.

80. You are entitled to the following under data protection law.

1. Under Article 15(1) of the GDPR we must usually confirm whether we have personal information about you. If we do hold personal information about you we usually need to explain to you:

i. The purposes for which we use your personal information
ii. The types of personal information we hold about you
iii. Who your personal information has been or will be shared with, including in particular organisations based outside the EEA.
iv. If your personal information leaves the EU, how we make sure that it is protected
v. Where possible, the length of time we expect to hold your personal information. If that is not possible, the criteria we use to determine how long we hold your information for
vi. If the personal data we hold about you was not provided by you, details of the source of the information
vii. Whether we make any decisions about you solely by computer and if so details of how those decision are made and the impact they may have on you
viii. Your right to ask us to amend or delete your personal information
ix. Your right to ask us to restrict how your personal information is used or to object to our use of your personal information
x. Your right to complain to the Information Commissioner’s Office
xi. We also need to provide you with a copy of your personal data

The right to rectification

81. We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you do not believe this is the case, you can ask us to update or amend it. Please note that medical information can be modified by adding a corrected version but the original record cannot be changed retrospectively for legal reasons.

The right to erasure (also known as the right to be forgotten)

82. We may update this Privacy Notice from time to time to ensure that it remains accurate.

In the event that there are any material changes to the manner in which your personal information is to be used then we will provide you with an updated copy of this Privacy Notice via our office website or on application to our office.

83. In some circumstances, you have the right to request that we delete the personal information we hold about you. However, there are exceptions to this right and in certain circumstances we can refuse to delete the information in question. In particular, for example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercise or defending legal claims.

The right to restriction of processing

84. In some circumstances, we must “pause” our use of your personal data if you ask us to. We do not have to comply with all requests to restrict our use of your personal information. In particular, for example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercise or defending legal claims.

The right to data portability

85. In some circumstances, I must transfer personal information that you have provided to you or (if this is technically feasible) another individual/ organisation of your choice.

The right to withdraw consent

86. In some cases I may need your consent in order for my use of your personal information to comply with data protection legislation. Where I do this, you have the right to withdraw your consent to further use of your personal information. You can do this by contacting me using the details provided at section 3 above.

The right to complain to the Information Commissioner’s Office

87.You can complain to the Information Commissioner’s Office if you are unhappy with the way that I have dealt with a request from you to exercise any of these rights, or if you think I have not complied with our legal obligations.

88. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/

89.Making a complaint will not affect any other legal rights or remedies that you have.

Updates to this Privacy Notice

90. I may update this Privacy Notice from time to time to ensure that it remains accurate. In the event that these changes result in any material difference to the manner in which I process your personal data then I will provide you with an updated copy of the Policy via my website. Copies will also be available via our office.

91. This Privacy Notice was last updated on 25th May 2018.