Privacy Policy

Purpose of this privacy notice
This privacy notice aims to give you information on how Dr McGreevy collects and
processes your personal data through your use of my website and online booking system, including any data you may provide through this website when you sign up to our newsletter, request information on our services, or register to avail of any services.

This website is not intended for children (being an individual under the age of 16 years old) alone and does not permit children to open accounts. Children may avail of our services where an individual with parental responsibility registers a child and accompanies them to all consultations or episodes of service usage. Dr McGreevy reserves the right to make enquiries to ensure that you hold appropriate parental responsibility to be able to give clear informed consent for your child. We do not knowingly collect data relating to children without appropriate consent.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data. This privacy notice supplements the other notices and is not intended to override them.

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (UK) 2016/679) (the “UK GDPR”), and the Data Protection Act 2018 the controller responsible for your personal data is Dr Angela McGreevy (collectively referred to as Lecale Clinic, ‘we’, ‘us’ or ‘our’ in this privacy notice). If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact us using the details set out below.
Contact Details:
Full name: Dr Angela McGreevy
Email Address: info@lecale.clinic
Postal Address: Lecale Clinic, 50 Church Street, Downpatrick. BT30 6EJ

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance.

Changes to the privacy notice and your duty us inform me of changes This version was updated on 24/3/022 It is important that the personal data we hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with us.

Third-party links
Lecale Clinic’s 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 notice of every website or service you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which I have grouped together follows:
Non-Special Category of Personal Data

• Identity Data includes first name, last name, date of birth, username or similar identifier, marital status, title, sex, gender, relative’s contacts, and NHS GP details. This may include photographs or videos where required (and agreed to) including those required for consultations.
• Contact Data includes billing address, postal address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address of your device, your login data, browser type and version, temporary or persistence unique device identifiers, mobile operating system type, 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 and/or application.
• Profile Data includes your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of services you have purchased or requested from us.

We also collect, use and share Aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

Special Categories of Personal Data
This type of data may be required for the provision of health care services intended to be provided by our services. When relevant, via Doctor consultation, we may collect: Medical Data: this may include blood pressure, weight, sex life, sexual orientation, glucose levels, test results, repeat prescription information, family information, genetic data, biometric data, medical history or other details contained in your health records.

If you fail to provide personal data
Where I need to collect personal data by law, or under the terms of contract or service provision agreement and you fail to provide that data when requested, we may not be able to perform the contract I have or are trying to enter into with you (for example, to provide you with an online consultation with a doctor). In this case, we may have to cancel a product or service you have with us but will notify you if this is the case at the time.

We use different methods to collect data from and about you, including through:

1. 1. Direct interactions. You may give us your identity, contact, medical, and financial data by filling in forms on my website or application or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
      • set up a user account;
      • subscribe to our services;
      • request and/or use services via your account (i.e. making arrangements for consultation with medical professionals or fulfilment of prescriptions);
      • Make an order for medications, and/or repeat prescriptions through our website;
      • request marketing to be sent to you;
      • enter a competition, promotion or survey; or
      • give us feedback.
   2. Automated technologies or interactions. As you interact with our website, we may 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. Please see our Cookies Policy.
   3. Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
      1. Technical Data from the following parties from:
         • analytics providers such as Google based outside the EU,
         • advertising networks and events based inside the EU,
         • Search information providers (such as google based outside the EU)
         • third party providers for emails and communications.
      2. Identity, Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe and Square based outside the EU.
      3. Identity and Contact Data from publicly available sources (such as the Electoral Register or Companies House and similar sources based inside the EU).
         Your medical records are held securely on a web application, cloud based electronic database ‘Semble’.
         Medical data about you may include the following information;
         • Details about you, such as your address, your carer or legal representative and emergency contact details.
         • Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments.
         • Notes and reports about your health.
         • Details about your treatment and care.
         • Results of investigations such as laboratory tests, x-rays etc.
         • Relevant information from other health professionals, relatives or those who care for you.
         • Contact details (including email address, mobile telephone number and home telephone number)
         • Financial information such as payment details and previous transactions are stored via an encrypted STRIPE integration with Semble.

Semble is UK GDPR Compliant. For their full privacy policy go to Semble.io.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. Where we need to perform the contract we are about to enter into or have entered into with you.
2. 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.
3. Where processing is necessary for medical diagnosis, the provision of health or social care or treatment.
4. Where we need to comply with a legal or regulatory obligation.
   Where we use a Special Category of data, including Medical Data, I am required to confirm an additional lawful basis (to that set out above) for the processing of such data which will most commonly include the following circumstances:
   • Provision of Direct Medical Care and administrative processes.
   • Purposes other than direct care (Quality improvement, audit, research, monitoring). When your personal information is used for secondary use this will be limited and deidentified so that the process is confidential.
   • Safeguarding of vulnerable adults and children.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email, text message or postage. You have the right to withdraw consent to marketing at any time by contacting us at info@lecale.clinic.

In addition to the data protection laws which I adhere to, we also respect The Common Law Duty of Confidentiality, which prohibits use and disclosure of information, provided in confidence unless there is a statutory requirement or court order to do so. Such information may be disclosed only for purposes that the data subject has been informed about and has consented to, provided also that there are no statutory restrictions on disclosure. This duty will only be overridden if Dr McGreevy can justify disclosure as being in the public interest, for example, to protect the vital interests of the data subjects or another person, or for the prevention or detection of a serious crime. Your records will not be disclosed to any third party not involved in the provision of services (other than your registered GP or if required for the purposes of improving medical care and services (i.e. the RQIA) between us unless you expressly consent to me doing so (i.e. for continuity of care). We may also share details with insurers where you consent/request me to do so.
Purposes for which we will use your personal data we have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases I rely on to do so. We have identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground I am relying on to process your personal data where more than one ground has been set out in the table below.

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. I have established the following personal data control mechanisms:
• 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 me if you have requested information from us or received services from us or if you provided me with your details when signed up or registered in the application or website and, in each case, you have not opted out of receiving that marketing.
• Third-party marketing: I will get your express opt-in consent before we share your personal data with any third party outside Lecale Clinic for marketing purposes.
• Opting out: You can ask us or third parties to stop sending you marketing messages at any time by amending your preferences in your user account (via the website or application) and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting me at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to me as a result of using the services, requesting services, ordering prescriptions, or providing feedback or surveys.

Cookies:
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see cookies notice.

Change of purpose and other lawful disclosures:
We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for an alternative 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 at info@lecale.clinic. 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, where this is required or permitted by law. For example, we may be required to disclose your data in the interests of public health, national security, or serious threats to health and/or safety (including child abuse or neglect). We may also have to make available information in response to requests from the General Medical Council (GMC) or Regulation and Quality Improvement Authority (RQIA). We will always identify a valid basis for disclosure of data.

Dr McGreevy may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom I may choose to sell, transfer, or merge parts of her business or her assets. Alternatively, she may seek to acquire other businesses or merge with them.

If a change happens to my business, then the new owners may use your personal
data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with my instructions.

Some of our External Third Parties are based in the US outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it as per GDPR by ensuring at least one of the following safeguards is implemented
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in
Europe. For further details, see European Commission: Model contracts for the
transfer of personal data to third countries.
• Where we use providers based in the United States of America, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the United States of America. For further details, see European Commission: EU-US Privacy Shield.

Please contact us at info@lecale.clinic if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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. We use SSL encryption to transfer information between your device and our servers. All data is encrypted at rest. 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 I am legally required to do so.

How long will you use my personal data for?
I will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

Guidance as made by the Information Governance Alliance (the IGS, which is a group comprising of the Department of Health, NHS England, NHS Digital and Public Health England) and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in my retention policy which you can request from me by contacting us.
Where we have anonymised your personal data (with consent where appropriate) so that it can longer be associated with you, or collected aggregated data for research or statistical purposes, we may continue to use that data indefinitely without further notice to you. In some circumstances you can ask me to delete your data: see Request erasure below for further information.

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.]
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
  If you wish to exercise any of the rights set out above, please contact us at info@lecale.clinic.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What I may need from you
We may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

LAWFUL BASIS
Legitimate Interest means the interest of my business in conducting and managing my business to enable me to give you the best service/product and the best and most secure experience. I make sure I consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for my legitimate interests.
I do not use your personal data for activities where my interests are overridden by the impact on you (unless I have your consent or are otherwise required or permitted to by law). You can obtain further information about how I assess my legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request before entering into such a contract. With regards to Dr. Siobhan Graham, this is the terms you agree to upon opening an account, following which you can request consultations and other services.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that I am subject to.
Medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems means the processing of your data is necessary for the purpose of providing you consultations, fulfilment of prescriptions, and other services related to your health as provided by me as requested by you, and for the improvement and management of health care systems more generally.
For compliance with a legal obligation means the processing of data is required by me to comply with my legal obligations for instance, allowing the Regulation and Quality
Improvement Authority (RQIA)to audit and review Lecale Clinic services.

THIRD PARTIES
External Third Parties

• Service providers acting as processors who provide IT and system administration services.
• Marketing service providers (including email list providers) who act as processors for my engagement correspondence and marketing with users.
• Verification service providers who verify the identity of individuals who register for child accounts.
• Online survey providers (including Survey Monkey) who convey information supplied by customers to Now Healthcare Group.
• Practitioners, being qualified medical practitioners as regulated by the General Medical Council, acting as processors based in Northern Ireland who provide medical consulting services.
• NHS, the health service for Northern Ireland, being a joint controller of your health data for fulfilment of regulatory requirements and other national interest uses as it so determines.
• Payment providers, as processors of payment information, including Stripe.
• Postal and delivery service providers acting as processors.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Please note that Dr McGreevy may object to amending your health records that may be held by us in the interests of maintaining the integrity of this data and benefitting your healthcare.

Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want me to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain products or services to you. I will advise you if this is the case at the time you withdraw your consent.

If you have any concerns about our use of your personal information, you can make a complaint to us at

Dr Angela McGreevy
Lecale Clinic
50 Church Street,
Downpatrick
BT30 6EJ

02844612737

info@lecale.clinic

You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk