This policy applies to the use of our Perci Health platform located at www.percihealth.com (the “Platform”). The Platform is not intended for children and we do not knowingly collect data relating to children.
2. Who We Are
We are Perci Health Ltd, a company registered in England under company no. 12402935. Our registered address is at Wellers Accountants, 1 Vincent Square, London, United Kingdom, SW1P 2PN.
We are the controller of your personal data. This means that we are responsible for what happens to any data you send to us, and we are subject to certain legal obligations about how we store it, who we send it to and what we can lawfully do with it.
|Title||Data Protection Officer|
|Name||Mr Joe Stock|
|Email Address||[email protected]|
3. The Data We Collect
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where any identifying markers have been removed (see section 4 regarding our use of aggregated data for further information).
Some of the personal data we collect, store and use will be the same whether you are an allied health professional (“AHP”) who provides services via the Platform, or a customer. In both cases, we will collect the following kinds of personal data from you:
|Identity Data||First, middle and last name, title, date of birth, sex and gender (if different from sex).|
|Contact Data||Billing address, email address and telephone number.|
|Financial Data||Bank account and payment card details.|
|Transaction Data||Details regarding payments made to or from you, and other details regarding services you have either purchased or provided (as applicable).|
|Technical Data||The internet protocol address you use to access the Platform, your log-in data, browser type and version, location, operating system and device type.|
|Usage Data||Information about how you use our Platform.|
If You Are an AHP
If you are an AHP, we will also collect the following categories of personal data from you:
|Qualifications and Fitness to Practice||Details of your qualifications, certifications, professional body registration, regulatory approvals, indemnity insurance and DBS clearance.|
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Whilst we do not collect extensive information about criminal convictions and offences, we do carry out a Disclosure and Barring Service (“DBS”) check on all AHPs who apply to provide services via the Platform. In such a case, we will retain any information recorded within the DBS clearance. DBS certificates will be stored as part of our records for a period of 6 months.
If You Are a Customer
If you are a customer, we also process special category data from you. The type of data will depend on the service you engage with, but can include any of the following:
|Medical Data||Details about your medical history, conditions, medications, therapies, and other health-related information.|
|Race or Ethnicity||Collected as part of our clinical assessment, if relevant to your medical history.|
|Sex / Gender||Collected as part of our clinical assessment, if relevant to your medical history.|
|Sexual Health||Collected as part of our clinical assessment, if relevant to your medical history.|
|Disability||Collected as part of our clinical assessment, if relevant to your medical history.|
4. Aggregated Data
Perci may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate data about which types of services are more in demand than others, or the areas of the country where the Platform is most popular. We may also aggregate data about how the Platform is used (e.g. the percentage of users who access the Platform via an IOS device against those who use Android or Windows.) We will use this data to inform our marketing and development strategies.
5. How We Collect Your Data
Almost all of the data we collect about you will be provided by you directly to us when you sign-up to access the Platform, or as you use it.
We will collect technical data from your browser upon log-in and every time you connect to a consultation.
6. How We Use Your Personal Data
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:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
- Where we feel there is a safeguarding concern or emergency/life threatening situation. Further details on this are available within our Safeguarding Policy which can be requested at anytime.
Where we rely on our own legitimate interests to process your data, those interests are:
- To administer and protect our business, including the Platform and its security;
- To understand and measure the effectiveness of our referrals;
- To develop the Platform in accordance with what our AHPs and customers need; and
- To use data analytics as a way of improving the user experience on our Platform.
To process special category data about you, including your health data, we rely on an exemption in GDPR which allows for processing where it is necessary to provide health and care services.
We will send you emails from time to time, giving you details about new features, partners or webinars we are holding. You can opt out of these newsletters at any time by clicking the link at the bottom of each email message.
7. Disclosures of Your Data
Keeping your data safe is extremely important to us, we take extra steps to ensure that we keep it safe. One of these steps is to encrypt your data using a key that belongs to your account, this means that only you and the people you choose to engage with can see your data. We will never sell your personal data.
We will only ever share necessary updates about your clinical care with third parties that have been nominated by you. These may include GP’s, oncologists, other medical referrers and your medical insurers. In line with HCPC (The Health and Care Professions Council) protocols, details around your clinical care will only be shared outside these purposes in in exceptional circumstances. This includes where there is sufficient evidence to raise serious concern about your safety, the safety of other persons who may be endangered by your behaviour or the health, welfare or safety of children or vulnerable adults. In such circumstances, we will obtain your consent to share information unless in situations where we have to communicate with third parties to protect you or another individual as required by. If we were to liaise with third parties, we will only do so in a way whereby the information being shared is relevant and necessary for the protection of you or someone else.
In very rare circumstances we may be required to share personal information where legally requested by for example a Coroner’s Office or Court of Law.
Where we share your data with essential suppliers or subcontractors, they will be subject to a contract which imposes strict obligations of confidentiality and compliance with UK data protection laws on them.
Some of our external third-party suppliers and subcontractors are based outside of the UK, so their processing of your personal data will involve a transfer of data outside of the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by putting in place a valid legal transfer mechanism, as permitted under data protection law.
8. Data Security and Retention
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Note that AHPs are subject to separate requirements regarding how long they must retain medical data about their patients. If you wish to have further information on this, please ask the relevant AHP directly, as requirements can differ.
9. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to the personal data we hold about you;
- Request corrections to any of the personal data we hold, if it is inaccurate;
- Ask us to erase your personal data;
- Object to the way in which we process your personal data; or
- Request transfer of your personal data in a commonly-used file format.
You will not have to pay a fee to access your personal data (or to exercise any of your other rights as outlined in this policy). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. If you wish to exercise any of the rights set out above, please contact us. We try to respond to all legitimate requests within one month. Occasionally it could take us 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.
10. Your Right to Complain
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK regulator for data protection issues. Details of how to do this can be found on their website, which you can access by clicking here. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.