Privacy Policy

1. Introduction

This Privacy Policy sets out details of the information that Premium Health Ltd (including medical secretaries and staff) may collect from you and how that information may be used. Please take your time to read this Privacy Policy carefully.

2. Contact Premium Health

In the event that you have any queries, comments or concerns in respect of the manner in which Premium Health used, or potentially will use, your personal information then you should contact Premium Health directly to discuss further. You may telephone 0121 242 3299 or email info@premiumhealth.org.uk

3. Your personal data

Premium Health is a Data Controller in respect of your personal information which is held about you. This will mainly relate to your medical treatment, but will be likely to also include other information such as financial data in relation to billing. Premium Health must comply with the data protection legislation and relevant guidance when handling your personal information, and so must any medical secretary who assists Premium Health in an administrative capacity. Your personal data may include any images taken in relation to your treatment which must not only be managed in accordance with the law, this Privacy Policy but also all applicable professional standards including guidance from the General Medical Council and British Medical Association.

Premium Health will provide your treatment from an Independent Private Hospital or Clinic and, in due course, it may be necessary for the Independent Private Hospital or Clinic to also process your personal data. Premium Health will do so in accordance with the law, the principles of this Privacy Policy and to the extent that it is necessary to do so. This could be where the Independent Private Hospital or Clinic needs to arrange other healthcare services as part of your treatment, such as nursing or dietician advice, or support other aspects of the treatment which Premium Health provides to you. In that case, the Independent Private Hospital or Clinic will become a joint Data Controller in respect of your personal information and you will be provided with a copy of their Privacy Policy which sets out how they will manage that information.

Your personal information will be handled in accordance with the principles set out within this Privacy Policy. This means that whenever Premium Health use your personal data, Premium Health will only do so as set out in this Privacy Policy. From time to time, Premium Health may process your personal information at a non-independent Private Hospital or Clinic site (medical or non-medical), as may our medical secretarial team.

What personal information does Premium Health collect and use from patients?

Premium Health will use “special categories of personal information” (previously known as “sensitive personal data”) about you, such as information relating to your physical and mental health.

If you provide personal information to Premium Health about other individuals (including medical or financial information) you should inform the individual about the contents of this Privacy Policy. Premium Health will also process such information in accordance with this Privacy Policy.

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

Personal information

As a patient of Premium Health, the personal information Premium Health holds about you may include the following:

  1. Name
  2. Contact details, such as postal address, email address and telephone number (including mobile number)
  3. Financial information, such as credit card details used to pay us and insurance policy details
  4. Occupation
  5. Emergency contact details, including next of kin
  6. Background referral details

Special categories personal information

As one of our patients, Premium Health 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. This may include the following:

  1. Details of your current or former physical or mental health, including information about any healthcare you have received from other healthcare providers such as GPs, dentists or hospitals (private and / or NHS), which may include details of clinic and hospital visits, as well as medicines administered. Premium Health will provide further details below on the manner in which Premium Health handle such information.
  2. Details of services you have received from Premium Health
  3. Details of your nationality, race and / or ethnicity
  4. Details of your religion
  5. Details of any genetic data or biometric data relating to you
  6. Data concerning your sex life and / or sexual orientation

The confidentiality of your medical information is important to Premium Health, and Premium Health make every effort to prevent unauthorised access to and use of information relating to your current or former physical and mental health (or indeed any of your personal information more generally). In doing so, Premium Health will comply with UK data protection law, including the 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 Nursing and Midwifery Council.

Since 25 May 2018, the current Data Protection Act has been replaced by the EU General Data Protection Regulation (GDPR) and a new Data Protection Act. All uses of your information will comply with the GDPR and the new Data Protection Act.

How does Premium Health collect your information?

Premium Health may collect personal information from a number of different sources including, but not limited to:

  1. GPs
  2. Dentists
  3. Other hospitals, both NHS and private (including Spire / other independent provider)
  4. Mental health providers
  5. Commissioners of healthcare services
  6. Other clinicians (including their medical secretaries)
  7. Directly from you

Information may be collected directly from you when:

  1. You enter into a contract with Premium Health or Independent Private Hospital or Clinic for the provision of healthcare services
  2. You use those services
  3. You complete enquiry forms on the Independent Private Hospital or Clinic website
  4. You submit a query to Premium Health including by email or by social media
  5. You correspond with Premium Health by letter, email, telephone (incoming and outgoing) calls from / to patients may be recorded or social media

From other healthcare organisations

Premium Health patients will usually receive healthcare from other organisations, and so in order to provide you with the best treatment possible Premium Health may have to collect personal information about you from them. These may include:

  1. Medical records from your GP
  2. Medical records from other clinicians (including their medical secretaries)
  3. Medical records from your dentist
  4. Medical records from the NHS or any private healthcare organisation
  5. Medical records include information about your diagnosis, clinic and hospital visits and medicines administered

From third parties

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

  1. You are referred to Premium Health for the provision of services including healthcare services
  2. Premium Health liaises with your current or former employer, health professional or other treatment or benefit provider
  3. Premium Health liaises with your family
  4. Premium Health liaises with your insurance policy provider
  5. Premium Health deals with experts (including medical experts) and other service providers about services you have received or are receiving from Premium Health
  6. Premium Health deals with NHS bodies about services you have received or are receiving from us
  7. Premium Health liaises with credit reference agencies
  8. Premium Health liaises with debt collection agencies
  9. Premium Health liaises with Government agencies, including the Ministry of Defence, the Home Office and HMRC

How will Premium Health communicate with you?

Premium Health may communicate with you in a range of ways, including by telephone, SMS, email, and / or post. If Premium Health contacts 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, Premium Health may leave a voice message on your voicemail and / or answering service as appropriate, and will include only sufficient basic details to enable you to identify who the call is from, very limited detail as to the reason for the call and how to call Premium Health back.

However:

  1. to ensure that Premium Health provides you with timely updates and reminders in relation to your healthcare (including basic administration information and appointment information), including reminders, Premium Health may communicate with you by SMS and / or unencrypted email (where you have provided Premium Health with your SMS or email address); in each case where you have expressed a preference in the patient registration form to be contacted by SMS and / or email.
  2. to provide you with your medical information (including test results and other clinical updates) and /or invoicing information, Premium Health may communicate with you by email (which will be encrypted) where you have provided Premium Health with your email address and have expressed a preference in the patient registration form to be contacted by email. The first time Premium Health sends you any important encrypted email that Premium Health is not also sending by post or which requires action to be taken, Premium Health will endeavour to contact you separately to ensure that you are able to access the encrypted email you are sent.
  3. 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, Premium Health is 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 service.

What are the purposes for which your information is used?

Premium Health 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 Premium Health uses your data Premium Health 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 a “special category of personal information”, Premium Health must have a specific additional legal justification in order to use it as proposed.

Generally, Premium Health will rely on the following legal justifications or ‘grounds’:

  1. Taking steps at your request so that you can enter into a contract with Premium Health to receive healthcare services from us.
  2. For the purposes of providing you with healthcare pursuant to a contract between you and Premium Health. Premium Health will rely on this for activities such as supporting your medical treatment or care and other benefits, supporting your nurse, carer or other healthcare professional and providing other services to you.
  3. Premium Health has an appropriate business need to process your personal information and such business need does not cause harm to you. Premium Health will rely on this for activities such as quality assurance, maintaining business records, monitoring outcomes and responding to any complaints.
  4. Premium Health has a legal or regulatory obligation to use such personal information.
  5. Premium Health needs to use such personal information to establish, exercise or defend its legal rights.
  6. You have provided your consent to Premium Health’s use of your personal information.

Note that failure to provide your information further to a contractual requirement with Premium Health may mean that Premium Health is unable to set you up as a patient or facilitate the provision of your healthcare.

Premium Health will provide further detail on these grounds in the sections below.

Appropriate business needs

One legal ground for processing personal data is where Premium Health do so in pursuit of legitimate interests and those interests are not overridden by your privacy rights. Where Premium Health refer to use for appropriate business needs, Premium Health are relying on this legal ground.

The right to object to other uses of your personal data

You have a range of rights in respect of your personal data, as set out in detail in sections [67-88]. This includes the right to object to Premium Health using your personal information in a particular way (such as sharing that information with third parties), and Premium Health 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 Premium Health, or it is otherwise necessary for the purposes of your ongoing treatment.

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

Purpose 1: To set you up as a Premium Health patient, including carrying out fraud, credit, anti-money laundering and other regulatory checks

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

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

Additional legal ground for special categories of personal information: The use is necessary for reasons of substantial public interest, and it is also in Premium Health’s legitimate interests to do so.

Purpose 2: To provide you with healthcare and related services

Clearly, the reason you come to Premium Health is to provide you with healthcare, and so Premium Health have to use your personal information for that purpose.

Legal grounds:

  1. Providing you with healthcare and related services
  2. Fulfilling Premium Health’s contract with you for the delivery of healthcare

Additional legal grounds for special categories of personal information:

  1. Premium Health may need to use the data in order to provide healthcare services to you
  2. 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

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

Legal grounds:

  1. Premium Health providing you healthcare and other related services
  2. Premium Health fulfilling its contract with you for the delivery of healthcare
  3. Premium Health having an appropriate business need to use your information which does not overly prejudice you
  4. Your consent

Additional legal grounds for special categories of personal information:

  1. Premium Health may need to use the data in order to provide healthcare services to you
  2. The use is necessary in order for Premium Health to establish, exercise or defend its legal rights
  3. Your consent

Purpose 4: For medical audit / research purposes

Clinical audit

Premium Health may process your personal data for the purposes of local clinical audit, i.e. an audit carried out by the Premium Health team for the purposes of assessing outcomes for patients and identifying improvements which could be made for the future. Premium Health is able to do so on the basis of Premium Health’s legitimate interest and the public interest in statistical and scientific research, and with appropriate safeguards in place. You are, however, entitled to object to Premium Health using your personal data for this purpose, and as a result of which Premium Health would need to stop doing so. If you would like to raise such an objection then please contact Premium Health using the details provided on Page 1 of this Policy.

Premium Health 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. Premium Health 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 and either Premium Health will seek this from you or the registry themselves will do so. The registry which Premium Health regularly shares data with is the National Vascular Registry.

Medical research

Premium Health may also be asked to participate in medical research and share data with ethically approved third party research organisations.

Premium Health 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 will have received statutory approval such that consent may not be required in order to use your personal data. In those circumstances, your personal data will be shared on the basis that:

Legal grounds: Premium Health 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: The processing is necessary in the public interest for statistical and scientific research purposes

In the event that consent is required then either Premium Health will seek this from you, or the research agency will do so.

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

From time to time, patients may raise queries, or even complaints, with Premium Health and Independent Private Hospital or Clinic, and Premium Health take those communications very seriously. It is important that Premium Health are able to resolve such matters fully and properly and so Premium Health, as well as Independent Private Hospital or Clinic will need to use your personal information in order to do so.

Legal grounds:

  1. Providing you with healthcare and other related services
  2. Having an appropriate business need to use your information which does not overly prejudice you

Additional legal grounds for special categories of personal information:

  1. The use is necessary for the provision of healthcare or treatment pursuant to a contract with a health professional
  2. The use is necessary in order for Premium Health to establish, exercise or defend Premium Health’s 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

In addition, 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 Premium Health 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 55 below.

Legal grounds:

  1. Providing you with healthcare and other related services
  2. Premium Health have a legitimate interest in ensuring that other healthcare professionals who are routinely involved in your care have a full picture of your treatment

Additional legal ground for special categories of personal information:

  1. Premium Health need to use the data in order to provide healthcare services to you
  2. The use is necessary for reasons of substantial public interest under UK law
  3. The use is necessary in order for Premium Health to establish, exercise or defend its legal rights

Premium Health 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 which will monitor outcomes of patients who receive private treatment. Under Article 21 of that Order, Premium Health is 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 a NHS facility and also the feedback you provided as part of any Patient Reported Outcome Measures (PROM) surveys. PHIN will use your information in order to share it with the NHS, and track whether you have received any follow-up treatment. Premium Health will only share this information with PHIN if you have provided your consent for Premium Health to do so.

The records that Premium Health share may contain personal and medical information about patients, including you. PHIN, like Premium Health, 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 Policy, is available at www.phin.org.uk

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

As a provider of healthcare, Premium Health is subject to a wide range of legal and regulatory responsibilities which it is not possible to list fully here. Premium Health may be required by law or by regulators to provide personal information, and in which case Premium Health will have a legal responsibility to do so. From time to time, clinicians are unfortunately 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).

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

Additional legal ground for special categories of personal information:

  1. Premium Health need to use the data in order for others to provide informed healthcare services to you
  2. The use is necessary for reasons of the provision of health care or social care or treatment or the management of health care or social care systems
  3. The use is necessary for establishing, exercising or defending legal claims

Premium Health is 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: Managing Premium Health’s business operations such as maintaining accounting records, analysis of financial results, internal audit requirements, receiving professional advice (e.g. tax or legal advice)

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

Legal grounds: Premium Health having an appropriate business need to use your information which does not overly prejudice you

Purpose 9: Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed.

As a provider of private healthcare services, Premium Health needs to carry out marketing but is mindful of your rights and expectations in that regard. As a result, Premium Health will only provide you with marketing which is relevant to its business and only where you have specifically confirmed your consent to do so.

Legal grounds:

  1. Premium Health having an appropriate business need to use your information which does not overly prejudice you
  2. You have provided your consent

Disclosures to third parties:

Premium Health may disclose your information to the third parties listed below for the purposes described in this Privacy Policy. This might include:

  1. A doctor, nurse, carer or any other healthcare professional involved in your treatment
  2. Other members of support staff involved in the delivery of your care, like receptionists and porters
  3. Anyone that you ask Premium Health to communicate with or provide as an emergency contact, for example your next of kin or carer
  4. NHS organisations, including NHS Resolution, NHS England, Department of Health
  5. Other private sector healthcare providers
  6. Your GP
  7. Your dentist
  8. Other clinicians (including their medical secretaries)
  9. Third parties who assist in the administration of your healthcare, such as insurance companies
  10. PHIN
  11. National and other professional research / audit programmes and registries, as detailed under Purpose 4 above
  12. Government bodies, including the Ministry of Defence, the Home Office and HMRC
  13. Our regulators, like the Care Quality Commission, Health Inspectorate Wales and Healthcare Improvement Scotland
  14. The police and other third parties where reasonably necessary for the prevention or detection of crime
  15. Our insurers
  16. Debt collection agencies
  17. Credit referencing agencies
  18. Our third party services providers such as IT suppliers, actuaries, auditors, lawyers, marketing agencies, document management providers, lenders and tax advisers
  19. Selected third parties in connection with any sale, transfer or disposal of our business

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

If you choose to make a purchase from us using a loan, we will share your information with lenders with whom we have a relationship. We will only do this with your consent. If you decide to proceed with a loan application, we will share your information with the relevant lender for the purpose of introducing you to their loan product(s). You should refer to the lender’s privacy notice for information on how they process your data.

What marketing activities does Premium Health carry out?

Premium Health may also use your personal information to provide you with information about products or services which may be of interest to you where you have provided your consent for Premium Health to do so.

If you no longer wish to receive marketing emails, you can click on the “unsubscribe” link that appears in all of Premium Health’s emails, otherwise you can always contact Premium Health using the details set out on page 1 of this Policy to update your contact preferences.

If you no longer wish to receive non-website based marketing information, please contact Premium Health.

Automated Decision Making

An automated decision is a decision made by computer without any human input, and there will be no automated decision-making in relation to your treatment or other decisions which will produce legal or similarly significant effects.

How long does Premium Health keep personal information for?

Premium Health will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and in order to comply with Premium Health’s legal and regulatory obligations.

If you would like further information regarding the periods for which your personal information will be stored, please contact Premium Health using the details outlined on Page 1 of this Policy.

International data transfers

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

Premium Health will only transfer your data to the extent that it is relevant and necessary. Under certain circumstances, Premium Health may request your consent for such a transfer.

If you would like further information regarding the steps Premium Health take to safeguard your personal information, please contact Premium Health using the details provided on Page 1 of this Policy.

Please note that Premium Health 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 Policy.

Your rights

Under data protection law you have certain rights in relation to the personal information that Premium Health hold about you. These include rights to know what information Premium Health holds about you and how it is used. You may exercise these rights at any time by contacting Premium Health using the details provided on page 1 of this Policy.

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

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

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

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

Your rights include:

The right to access your personal information

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

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

Please note that in some cases Premium Health 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.

You are entitled to the following under data protection law.

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

  1. The purposes for which Premium Health use your personal information
  2. The types of personal information Premium Health hold about you
  3. Who your personal information has been or will be shared with, including in particular organisations based outside the EEA.
  4. If your personal information leaves the EU, how Premium Health will make sure that it is protected
  5. Where possible, the length of time Premium Health expects to hold your personal information. If that is not possible, the criteria Premium Health use to determine how long Premium Health hold your information for
  6. If the personal data Premium Health hold about you was not provided by you, details of the source of the information
  7. Whether Premium Health 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
  8. Your right to ask Premium Health to amend or delete your personal information
  9. Your right to ask Premium Health to restrict how your personal information is used or to object to Premium Health’s use of your personal information
  10. Your right to complain to the Information Commissioner’s Office

Premium Health also needs to provide you with a copy of your personal data, provided specific exceptions and exemptions do not apply.

The right to rectification

Premium Health take reasonable steps to ensure that the information Premium Health hold about you is accurate and complete. However, if you do not believe this is the case, you can ask Premium Health to update or amend it.

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

Premium Health may update this Privacy Policy from time to time to ensure that it remains accurate, and the most up-to-date version can always be found at here. In the event that there are any material changes to the manner in which your personal information is to be used then Premium Health will provide you with an updated copy of this Privacy Policy.

In some circumstances, you have the right to request that Premium Health delete the personal information Premium Health holds about you. However, there are exceptions to this right and in certain circumstances Premium Health can refuse to delete the information in question. In particular, for example, Premium Health does 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, exercising or defending legal claims.

The right to restriction of processing

In some circumstances, Premium Health must “pause” the use of your personal data if you ask Premium Health to do so, although Premium Health do not have to comply with all requests to restrict the use of your personal information. In particular, for example, Premium Health does 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

In some circumstances, Premium Health must transfer personal information that you have provided to you or (if this is technically feasible) to another individual/ organisation of your choice. The information must be transferred in an electronic format.

The right to object to marketing

You can ask Premium Health to stop sending you marketing messages at any time and Premium Health must comply with your request. You can do this by contacting Premium Health using the details provided on page 1 of this Policy.

The right to not to be subject to automatic decisions (i.e. decisions that are made about you by computer alone)

You have a right to not be subject to automatic decisions (i.e. decisions that are made about you by computer alone) that have a legal or other significant effect on you.

Please see section 60 for detail about when we may make automatic decisions about you.

If you have been subject to an automated decision and do not agree with the outcome, you can challenge the decision.

The right to withdraw consent

In some cases Premium Health may need your consent in order for Premium Health’s use of your personal information to comply with data protection legislation. Where we do this, you have the right to withdraw your consent to further use of your personal information. You can do this by contacting Premium Health using the details provided on page 1 of this Policy.

The right to complain to the Information Commissioner’s Office

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

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

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

National data opt-out programme

NHS Digital has developed a national data opt-out programme which will was launched on 25 May 2018, pursuant to which all patients will be able to log their preferences as to sharing of their personal information. All health and care organisations will be required to uphold patient choices, but only from March 2020. In the meantime you should make Premium Health aware directly of any uses of your data to which you object.

Updates to this Privacy Policy

Premium Health may update this Privacy Policy 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 Premium Health process your personal data then Premium Health will provide you with an updated copy of the Policy.

This Privacy Policy was last updated on 29th March 2024.