Introduction

Your Persona l Data is data which by itself or with other data available to HCA International Limited (HCA UK) can be used to identify you as an individual.  HCA Foundation is a wholly owned subsidiary of HCA UK. HCA UK is the data controller. This privacy notice sets out how HCA will use your personal data.  You can contact our Data Protection Officer (DPO) at 242 Marylebone Rd, Marylebone, London NW1 6JL, or at DPO@hcahealthcare.co.uk if you have any questions.

The types of personal data we collect and use

We will use your personal data for the reasons set out below.  We will collect most of this directly during the registration and/or admission process but there may be sources of personal data collected indirectly as set out later in this Policy. The persona l data we use may include:

your name, address and contact details, including email address and home and mobile telephone numbers, date of birth and gender;

your previous and current medical health records weather provided by HCA UK or other third parties;

the terms and conditions of your contract with us for the provision of healthcare and related services;

your financial information (your bank account and national insurance number) if you are a ‘self pay’patient or the financial information of the company or individual who is responsible for the payment of invoices/bills relating to your care (e.g. insurer or sponsor);

information about your marital status, next of kin, dependants nominated and/or emergency contacts;

information about your nationality and entitlement to treatment in the UK;

information about medical or health conditions, including whether or not you have a disability for which the organisation needs to make reasonable adjustments; 

information about medical or health conditions of your family; 

Information received in response to any surveys, complaints claims;

equal opportunity monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief; and

Information about how you use our website.

If you are employed by HCA UK we will also hold and process other information relating to your employment (You can obtain a copy of the Staff Privacy Notice from the HR team)

If you are a Consultant/ Doctor or other healthcare provider you are not employed by HCA UK but we will also hold and process other information relating to the clinical services you carry out.  (You can obtain further information form the facility CEOs or your [clinical contact].

This data may also include visual images, personal appearance and behavior e.g. where CCTV is used as part of our building security measures.

HCA UK may collect this information in a variety of ways. For example, data might be collected through Registration and Admission forms; obtained from your passport or other identity documents such as your driving licence; from pre-admission forms, online web forms completed by you at the start of your treatment; from correspondence with you; through the Admission and Registration process or through interviews, meetings or other assessments.

In some cases, the organisation may collect personal data about you from third parties, such as insurer providers, referral agencies, sponsors, checks permitted by law.

Providing your personal data 

We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases, we need you to provide your personal data so we can provide care and treatment and receive payment for these services.

Monitoring of communications

Subject to applicable laws, we may monitor and record staff calls, emails, text messages, social media messages and other communications in relation to our dealings with you.  We will do this to ensure an appropriate standard of care, for regulatory compliance, self-regulatory practices, crime prevention and detection, to protect the security of our communications networks and systems, to check for unlawful content, obscene or profane content, for quality control and staff training, and when we need to see a record of what has been said. We may also monitor activities on our network and systems where necessary for these reasons and this is for our legitimate interests or other legal obligations.

Using your personal data and the legal basis for processing

We will process your personal data under Article 6 (1); Article 9 (2) of the General Data Protection Regulations:

To support the provision of your healthcare;

To decide how best to provide treatment to you; 

As necessary to support the healthcare contract with you and to allow us to receive [full] payment for those services;

To take steps at your request during the course of your treatment;

To keep your records up to date; 

We will process your personal data under Article 6 (1) of the General Data Protection Regulations:

As necessary for our own legitimate interests or those of other persons and organisations, e.g.:

For good governance, accounting, and managing and auditing our clinical and business operations;

To monitor emails, calls, other communications, and activities on HCA networks and systems;

For market research, analysis and developing statistics for improving clinical performance; and

As  necessary  to comply with a legal obligation:

When you exercise your rights under data  protection law and make requests;

For compliance with legal and regulatory requirements and related disclosures;

For establishment and defence of legal rights;

For activities relating to the prevention, detection and investigation of crime;

To verify your identity, make credit fraud prevention and anti-money laundering checks; and

To investigate complaints, legal claims and data protection or clinical incidents.

Based on your consent:

If you ask us to disclose your personal data to other people or organisations such as a company handling a claim on your behalf; or otherwise agree to disclosures;

When we process any special categories of personal data about you at your request (e.g. my racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning your health, sex life or sexual orientation).

You are free at any time to change your mind and withdraw your consent. The consequence might be that we cannot continue to provide full healthcare services to you.

Sharing of your personal data

Subject to applicable data protection laws we may share your personal data with:

Consultants/Doctors and other healthcare professionals who provide treatment to you at our Facilities;

Other healthcare providers where we feel this will enhance the quality of your care;

The HCA group of companies and associated companies including entities in the United States;

Sub-contractors and other persons who help us to provide healthcare products and services to you;

Companies and other persons providing services to you as part of your extended care;

Our legal and other professional advisors, including our auditors;

Fraud prevention agencies, credit reference agencies, and debt collection agencies;

Government bodies and agencies in the UK and overseas (e.g. HMRC who may in turn share it with relevant overseas tax authorities and with regulators, the Information  Commissioner's Office;

Courts, to com ply with legal requirements, and for the administration of justice;

In an emergency or to otherwise protect your vital interests;

To protect the security or integrity of our business operations and other patients;

W hen we restructure or sell our business or its assets or have a merger or re-organisation;

Payment systems and providers; and

Anyone else where we have your consent or as required by law

Sharing of your personal data to contribute to the review and publishing of information about the quality and cost of privately funded healthcare

Subject to applicable data protection laws HCA Healthcare (HCA UK) is required to provide hospital performance data to the Private Healthcare Information Network (PHIN), which publishes information on the quality and cost of privately funded healthcare.

PHIN’s goal is to help patients make more informed choices about where to go for treatment.

HCA UK will not supply your name, date of birth, or full address to PHIN. PHIN is only concerned with understanding the treatment that hospitals and doctors provide, whether that treatment was safe and effective, and whether there were any complications.

Any processing of personal data shall be made in accordance with the Data Protection Laws.

Publication will be made via the PHIN website in a format that will allow patients requiring hospital treatment and their doctors to search for local private hospitals by procedure and to compare how they perform in terms of quality and safety based on treatment data. Individuals are then able to make informed choices; which Consultant to see, which treatment option to follow, and at which hospital to be treated.  This information will not be in a form where individuals can be identified.

An additional reason for obtaining the NHS Number relates to HCA UK’s intention to access the UK Child Protection Information Sharing (CP-IS) system in order to facilitate the sharing of information between health and local authorities where a child may be at risk of being neglected, maltreated or abused.

HCA UK ensures all the information it holds is kept safe and confidential.

You have the option to withhold your personal information, in which case we will only share an anonymised record of your treatment to PHIN, but will not provide your NHS Number (or equivalent) or postcode.

If you tell us that you are not happy for HCA UK to pass on your NHS Number and Postcode to PHIN we will indicate this o your Registration Form. 

If you subsequently change your mind please contact the facility where you were treated. Contact details are available on this website.

Sharing of your personal data for research purposes

Subject to applicable data protection laws and your explicit written consent we may share your personal data for the purpose of scientific research.

Sharing of your personal data for marketing purposes

Subject to obtaining your written consent and communications preferences we may use your contact details to send you newsletters and other information on new Facilities, services and treatments which we think may be of interest to you.  We will not sell your personal data to a third party without your written consent.

You are free at any time to change your mind and withdraw your consent. Please contact [insert email address].  This will not affect the healthcare services we provide to you.

International transfers

Your personal data may be transferred outside the UK and the European Economic Area.  While some countries have adequate protections for personal data under applicable laws, in other countries steps will be necessary to ensure appropriate safeguards apply to it.  These include imposing contractual obligations of adequacy or requiring the recipient to subscribe or be certified with an 'international framework' of protection.

How long do we keep your data?

Information will be kept in in accordance with the retention periods outlined in the Information Governance Alliance (IGA) Records Management Code of Practice for Health and Social Care (2016). Information may be held for longer periods where the following apply: 

Retention in case of queries. We will retain your personal data as long as necessary to deal with any queries you may have;

Retention in case of claims. We will retain your personal data for as long as you might legally bring claims against us; and

Retention in accordance with legal and regulatory requirements.   We will retain your persona l data after you have received healthcare services at our Facilities based on our legal and regulatory requirements.

Your rights under applicable data protection law

Your rights are as follows (noting that these rights do not apply in all circumstances):

The right to be informed about processing of your personal data;

The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed;

The right to object to processing of your persona l data

The right to restrict processing of your personal data 

The right to have your personal data erased (the "right to be forgotten”)

The right to request access to your personal data and information about how we process it;

The right to move, copy or transfer your personal data ("data portability") ; and

Rights in relation to automated decision making including profiling

You may exercise these rights by contacting us on exercisingmydatarights@hcahealthcare.co.uk

You have the right to complain to the Information Commissioner's Office. It has enforcement powers and can investigate compliance with data protection law ico.org.uk.

For more details on all the above you can downloading a copy from our Website [insert website link] or contact our Data Protection Officer to request a paper copy of the 'Using My Personal Data' booklet. This Notice may be translated into other languages on request.