Royal Brompton & Harefield Hospitals Education
Privacy Statement for individuals using our website
Royal Brompton and Harefield hospitals, part of Guy’s and St Thomas’ NHS Foundation Trust, are committed to respecting the privacy of individuals using this website. The information in this statement relates to website use only.
Key points
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Why we use your personal data: We typically use your personal information for purposes related to your user account set up with us.
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Sharing your data: We may share your data with third parties, including volunteer partners.
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Security of your personal data: We respect the security of your data and treat it in accordance with the law.
WHAT IS THE PURPOSE OF THIS PRIVACY STATEMENT?
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.
This privacy policy aims to give you information on how we collect and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our courses or pay for access to certain on-line resources.
It is important that you read this statement so that you know how and why we use information about you. It is also important that you inform us of any changes to your personal information we hold about you so that the information which we hold is accurate and current.
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.
WHO ARE WE?
We are Royal Brompton and Harefield hospitals, part of Guy’s and St Thomas’ NHS Foundation Trust. We provide care for patients with a wide range of complex cardiac conditions and are world leaders in the diagnosis, management and treatment of lung disease.
We are registered with the Information Commissioner’s Office under registration number Z7034208 and have three primary hospital sites at:
- Harefield Hospital, Hill End Road, Harefield, UB9 6JH;
- Royal Brompton & Harefield Hospitals Specialist Care, 77 Wimpole Street, London, W1G 9RU; and
- Royal Brompton Hospital, Sydney Street, London, SW3 6NP.
We are a “data controller” in respect of the information we hold about you. This means that we are responsible for deciding how we use that personal information about you.
OUR DATA PROTECTION OFFICER
Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
If you have any concerns or questions about our use of your personal information, you can contact our Data Protection Officer by emailing ig@rbht.nhs.uk.
THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- personal details (such as your name);
- contact details (such as your, personal telephone number, billing address and personal email address) and your contact preferences;
- the nature of your relationship with us (such as in relation to any previous employment with us and any start/end dates of that employment);
- financial Data (such as bank account and payment card details);
- transaction Data (such as includes details about payments to and from you and other details of products and services you have purchased from us);
- technical Data (such as, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website);
- profile Data (such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses);
- usage Data (such as information about how you use our website, products and services); and
- marketing and Communications Data (such as your preferences in receiving marketing from us and our third parties and your communication preferences).
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.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
SOURCE OF YOUR PERSONAL INFORMATION
We use different methods to collect data from and about you including through:
Direct Interactions. You may give us your personal, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. this includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
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, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
HOW AND WHY WE USE YOUR PERSONAL DATA
We use the types of personal data listed above for a number of purposes, each of which has a “lawful basis”. In accordance with the data protection laws, we need a “lawful basis” for collecting and using information about you. There are a variety of different lawful bases for using personal data which are set out in the data protection laws.
Most commonly, we will use your personal data in the following circumstances:
- where we need to perform the contract we are about to enter into or have entered into with you;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
- where we need to comply with a legal obligation.
We have set out below the different purposes for which we collect and use your personal data, along with the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
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To register you as a new customer |
(a) Identity
(b) Contact |
Permormance of a contract with you |
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To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
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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 |
(a) 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) (b) Necessary to comply with a legal obligation |
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To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
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To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and 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 goods or 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 products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
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 products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by 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 registering for an account on our website.
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.
WHAT MAY HAPPEN IF YOU DO NOT PROVIDE YOUR PERSONAL INFORMATION
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 product or service you have with us but we will notify you if this is the case at the time.
COMPLYING WITH DATA PROTECTION LAW
We will comply with data protection law. At the heart of data protection laws are the “data protection principles” which say that the personal information we hold about you must be:
- used lawfully, fairly and in a transparent way;
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- relevant to the purposes we have told you about and limited only to those purposes;
- accurate and kept up to date;
- kept only as long as necessary for the purposes we have told you about; and
- kept securely.
SHARING YOUR INFORMATION
We will share your personal information with third parties where we have a lawful basis for doing so.
The types of organisations with whom we may share your personal information include:
- Service providers (such as external IT providers and systems maintenance providers);
- The police and other law enforcement agencies (in limited circumstances we may share your personal data with the police if required for the purposes of criminal investigations and law enforcement);
- Professional advisors (such as lawyers, in the exercise or defense of legal claims);
- Affiliated organisations and individuals which support and provide services to us. This is limited to Nudge Digital Ltd
STORING YOUR INFORMATION AND DELETING IT
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in the NHS Digital Records Management Code of Practice for Health and Social Care 2016.
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 requirements.
DATA SECURITY
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, agents, 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 have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
YOUR RIGHTS
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information in certain circumstances. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information if we are relying on a legitimate interest (or those of a third party) or public interest/official authority as our lawful basis for processing and there is something about your particular situation which leads you to object to processing on this ground. You also have the right to object if we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in certain circumstances.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer by emailing ig@rbht.nhs.uk.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where we are relying on your consent as our lawful basis to process your data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer by emailing ig@rbht.nhs.uk.
RIGHT TO COMPLAIN TO THE ICO
You have the right to complain to the Information Commissioner’s Office (the “ICO”) if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.