Privacy Policy

Privacy Policy

Lindo Anaesthesia LLP (Lindo Anaesthesia or we/us/our) are committed to protecting the privacy and security of your personal data. This means data which by itself, or with other data available to Lindo Anaesthesia, can be used to identify you as an individual.

Lindo Anaesthesia is a ‘data controller’ for the purposes of this privacy policy. This means that we are responsible for deciding how we hold and use your personal data. We are required under data protection legislation to notify you of the information contained in this privacy policy. The privacy policy explains how we collect and use your personal data during, and after, your relationship with us, in accordance with the General Data Protection Regulation (GDPR). In some circumstances, we may acquire or handle your personal data as a ‘data processor’ which means that we have been asked to handle your personal data by a third party controller, who should have their own privacy policy.

The GDPR grants individuals certain rights in relation to their personal data (for example, subject to certain conditions, individuals can ask for copies of their personal data to be erased).

Our contact details are set out in the Contact Us section at the end of this privacy policy. If you have any questions, including about your rights, please email: imperial.lindoanaesthesia@nhs.net

This notice applies to:

• all patients;
• all third parties and suppliers with whom we have dealings in the ordinary course of our business;
• visitors to our website; and,
• partner service providers of Lindo Anaesthesia, including healthcare professionals.

We may update this notice at any time and we will make the new privacy notice available to you via our website.

What personal data do we collect and use?

During the course of our relationship with you, we will collect, store, and use personal information about you. This personal data may include:

• your basic personal identifiers such as name, title, date of birth and gender
• your personal contact details such as your home address, telephone numbers and email address
• your marital status and dependents
• your next of kin and emergency contacts
• information about your visit or stay at the Lindo Wing including: planned procedure, booking type, expected delivery date (EDD), attending or admitting Consultant, date of admission, length of stay and admission status
• your medical records and information about medical or health conditions, which may be provided to us by you or by our trusted partner hospitals or practices
• information about medical or health conditions of your family
• information about any disabilities you may have
• your personal or company financial information (such as bank account) and payment records where we invoice you directly, and information about any third party funders such as insurers or sponsors
• your nationality and, if applicable, national insurance number
• information about your entitlement to treatment or, if you are a healthcare professional, work in the UK
• information you may submit to us via our website or in the course of a claim or complaint.

If you provide services to us (eg, as a contractor) (Service Provider) we may also collect and use:

• your basic personal identifiers such as name, title, date of birth and gender
• your contact details such as address, telephone and email address
• bank account details, payroll details and tax status information
• salary, annual leave, pension and benefits information
• driving licence and passport
• compensation history
• performance information
• disciplinary and grievance information
• electronic swipecard records
• information about your use of our information and communications systems
• photographs
• equal opportunity monitoring information, including about your ethnic origin, sexual orientation, health, religion or belief.

• If you are a medical professional or healthcare provider not employed by Lindo Anaesthesia, in addition to the Service Provider details above, we may also collect and use information about the clinical services you carry out.

• If you visit our website, we collect anonymous, statistical information about the way in which you browse and use the website, from which you cannot be identified. This means information about your computer (eg, your IP address, browser information, and operating system) and the website pages that you access (eg, mouse clicks, mouse movements and page scrolling). This is to help us improve our website usability. For information about the cookies we collect and use, please see the section below entitled ‘Cookies’.

When and how do we collect your personal data?

There are a number of ways in which we may collect your personal data:

• when you book for delivery or other procedure with us at the Lindo Wing or when you register for an appointment/consultation with a member of Lindo Anaesthesia
• during appointments, interviews and medical assessments
• when you are admitted or book in for a stay at the Lindo Wing
• when you visit our website and contact us via the details provided
• from correspondence with you
• from our trusted third party partners with whom we work to provide our services, including: the NHS, healthcare providers, insurers, funders, referrers
• agencies we use for background and other checks
• in the course of dealings with us as a supplier of goods and/or services
• in the course of job-related activities throughout the period of you working with or for us
• publically available information.

How do we use your personal data?

We use information about you in different ways depending on your relationship with us. We may use your personal data:

• to provide our anaesthetic services, including planning and managing your visit to, or stay at, the Lindo Wing
• to review and update your records
• to decide and plan for the procedure or support services which are best for you
• to deal with your requests and enquiries
• following up with you after you have been to the Lindo Wing
• to administer and manage your account with us, including the payment of your services, whether by you or a third party
• to release personal information to regulatory or law enforcement agencies, if we are required or permitted to do so
• if you are a medical professional or healthcare provider, providing services to us, we use your information to procure your services, perform our contract with you and manage your relationship with us.

International transfers

Sometimes the way in which we use your personal data might involve us transferring your personal data outside of the UK and the European Economic Area (EEA). If we do, we ensure that the recipient commits to having appropriate safeguards in place to protect it, including via standard contractual clauses approved by the European Commission and other appropriate solutions under the GDPR. Note that some countries are regarded as having a legal system as protective of personal data as the UK and the EEA. Where that is the case, we do not need to take any special steps before we transfer your personal data.

Our legal grounds for processing your personal data

Under the GDPR, the main grounds that we rely upon in order to process personal data of patients are:

(a) with your consent – in some circumstances, we ask for your consent to process your personal data in a particular way. We may ask for your explicit consent to process your sensitive data which includes your medical records and health-related data;

(b) necessary for entering into, or performing, a contract (including the provision of health care and treatment, and managing our health services) – in order to perform obligations that we undertake in providing our services to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;

(c) necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;

(d) Necessary for the purposes of legitimate interests – either we, or a third party, will need to process your personal data for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include: providing you with our services, responding to requests and enquiries from you or a third party; to monitor emails, calls and communications on our networks and systems; improving our website usability and client experience, informing you about our services; auditing our operations and ensuring that they are conducted in an appropriate and efficient manner; and, improving our services and support through client surveys, feedback and market research.

If you fail to provide personal data

If you fail to provide certain information when requested, we may not be able to perform our services or we may be prevented from complying with our legal obligations.

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 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, including in connection with our legal ground for processing your data (as above).

How do we share your personal data?

Sometimes, we share your personal data with other parties. Details of those parties are set out below along with the reasons for sharing it; for example, because of a legal requirement, to perform our contractual obligations or for a legitimate business reason.

1. Other healthcare departments or professionals within Imperial College Healthcare NHS Trust or other NHS Trusts or hospitals

This is for any or all of the following purposes:
• where we work in conjunction with them to provide our services and treatments
• so that we can provide you with services and treatments around the clock, including in an emergency
• if we refer you or hand over the provision of your care to another provider
• to provide extended care.

2. Third parties who perform functions on our behalf and provide services

This is for any or all of the following purposes:
• the processing of invoices and payments
• for us to obtain legal or other professional assistance, including auditing
• to provide us with IT support and infrastructure
• for security reasons to protect you, us and other patients.

4. Third parties, to whom you request that we send your personal data, or with your consent.

This is for any or all of the following purposes:
• so that your insurers or funders have the information they require
• so that you may participate in surveys or give feedback, to help us to continuously improve
• for scientific research, with your explicit consent and subject to data protection law compliance
• Where you opt-in, for marketing purposes. For details on how you can withdraw consent to marketing, see the section entitled ‘Your rights’ below.

5. Courts, regulators government bodies or agencies, such as tax authorities.

This is for any or all of the following purposes:
• to comply with a legal request or requirement
• for the administration of justice
• to meet our regulatory obligations.

6. If we or our business or assets are sold, re-organised or we merge with another business, we will share your personal data with the new owners and their advisors.

7. In an emergency, we will share your personal data as necessary to protect your vital interests.

Internet-based transfers

The way in which we collect, use and share your personal data necessarily may involve the transmission of your personal data via the internet. Unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our systems via third party networks; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Other websites

Please note that clicking on links and banner advertisements on our website can result in your browser accessing a third party website, where data privacy practices are different to that of Lindo Anaesthesia.
We are not responsible for, and have no control over, information that is submitted to or collected by these third parties and you should consult their privacy policies.

How long do we hold your personal data?

The length of time we will hold or store your personal data for will depend on the services we perform for you and for how long you require these. The appropriate retention period will depend upon factors such as: the amount, nature and sensitivity of the personal data, the potential risk of harm from the unauthorised use or disclosure of the personal data, the form the personal data takes (eg, hardcopy or electronic), the purpose(s) for which we originally collected the personal data and whether we can achieve those purpose(s) through other means.

Sometimes, we are required to keep information about you for a certain period. This might be because:

• A law or regulatory requirement requires us to hold onto your information, including where you receive medical services;
• We are within the period during which a claim or legal proceedings may arise and we may need your information to defend or otherwise deal with such matters; or,
• We are dealing with a query from you and need to maintain a record of this.

Your rights

You have certain rights in relation to your personal data. You can ask to exercise any of these rights by contacting us using any of the methods in the Contact Us section below.

We may need to request specific information from you to help us confirm your identity and ensure your right to access 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 does not have the right to receive it.

Please note that where you ask us to erase, correct, object to process or seek to restrict our processing of data we may refuse your request where we have a legal obligation, contractual or other legitimate business interest to refuse your request. If we refuse your request then we will notify you of this refusal and you will have the right to appeal.

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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

1. Right of access

You have the right at any time to ask us for a copy of the personal data about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal data, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.

2. Right of correction or completion

If personal data we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed. You can let us know by contacting us using the details in the Contact Us section.

3. Right of erasure

In certain circumstances, you have the right to request that personal data we hold about you is erased eg, if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.

4. Right to object to or restrict processing

In certain circumstances, you have the right to object to our processing of your personal data by contacting us – see below. For example, if we are processing your data on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal data for direct marketing purposes.

You may also have the right to restrict our use of your personal data, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.

5. Right of data portability

In certain instances, you have a right to receive any personal data that we hold about you in a structured, commonly used and machine-readable format such as CSV. You can ask us to transmit that data to you or directly to a third party organisation.

The above right exists only in respect of personal data that:
• you have provided to us previously; and
• is processed by us using automated means.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal data of others without their consent.

6. Withdrawing your consent

To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time.

Questions or complaints

If you have any questions or are unhappy about our use of your personal data, you can contact us using the details in the Contact Us section below. You are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods:

Telephone: 0303 123 11113

Website: https://ico.org.uk/concerns/

Post: Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

If you live or work outside of the UK or you have a complaint concerning our activities outside the UK, you may prefer to lodge a complaint with your local supervisory authority.

Contact us

Lindo Anaesthesia is a data controller. Please note that some of the partner organisations with whom we work will also be controllers of your personal data, and are therefore responsible for how it is handled and sent to us.

You can contact us at:

Postal address: Lindo Anaesthesia, The Lindo Wing, Praed Street, St Mary’s Hospital, London, W2 1NY.

Email address: imperial.lindoanaesthesia@nhs.net

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