Privacy Policy

1. Policy Objective

The purpose of this policy is to ensure that robust and sustainable governance frameworks are in place throughout the Clinic. This policy outlines the key principles and related procedures regarding clinical and other governance, as well as monitoring of the provision of high-quality services.

The policy will also ensure that high standards of care are safeguarded by creating an environment in which excellence in care will flourish for users. In addition the policy will ensure compliance with the requirements of statutory regulations and the governance policies of any organisation whose premises are used to treat users.

Carpathia Clinic is acting as a ‘data controller’ under the Data Protection (Jersey) Law 2018 as we collect and process personal information about you. We process and hold your information in order to provide public services and meet our statutory obligations. This notice explains how we use and share your information. Information may be collected on a paper or online form, by telephone, email, or by a member of our staff. We will continually review and update this privacy notice to reflect changes in our services and feedback from service users, as well as to comply with changes in the law. 

2. What Information Do We Collect About You? 

We collect the following types of information about you:

• Name
• Date of birth
• Address
• Contact details (phone, email)
• Occupation
• Verification of information (KYC)
• Photographic I.D.
• Social Security/National Insurance number
• Next of Kin details
• Medical information that is relevant inc. notes and reports
• Details of your treatment and care 

The Clinic may also collect, use and store the following special personal data about you:

• Notes and reports relevant to your health, including any information you have told us about your health.
• Details of your treatment and care, including the professional opinion of the staff caring for you.
• Results of investigations, such as laboratory tests and x-rays.
• Relevant information from health and social care professionals, relatives or those who care for you.
• Information about your ethnicity, sexual orientation, sex life, religious beliefs or opinion or genetic data, or any disability where this is relevant to your care or is information that you have provided to us as part of your care. 

3. Why Do We Collect Information About You? 

We need to collect and hold information about you, in order to:

• Stay in touch with you.
• Verify you are who you say you are.
• Handle your application.
• Answer your query.
• Provide you with information you may need.
• Carry out the service we provide.
• To process financial transactions.
• To provide you with a service tailored to your preferences.
• Monitor and improve our performance, responding to service requests.
• Ensure we meet our legal/statutory obligations.
• Send direct marketing communications, where you have consented to this.
• To prevent and detect crime.
• To allow statistical analysis of data for provision of service planning. 

4. How Will We Use The Information About You 

We will use the information you provide in a manner that conforms to the Data Protection (Jersey) Law 2018. We will endeavour to keep your information accurate and up to date and not keep it for longer than is necessary. In some instances the law sets the length of time information has to be kept. Please ask to see our retention schedules for more detail about how long we retain your information. We may not be able to provide you with a service unless we have enough information or your permission to use that information. We will not pass any personal data on to anyone, other than those who either process information on our behalf, or because of a legal or statutory requirement, and we will only do so, where possible, after we have ensured that sufficient steps have been taken by the recipient to protect your personal data. We will not disclose any information that you provide 'in confidence', to anyone else without your permission, except in the few situations where disclosure is required by law, or where we have good reason to believe that failing to share the information would put someone else at risk. You will be told about this unless there are exceptional reasons not to do so. 

5. How is the Information Stored? 

Your information will be stored electronically on a patient information system. From time to time some of your data may be stored temporarily in other systems in order to provide patient services and support. We take the security of your data seriously and take all appropriate steps, including encryption, and multi-factor authentication, to protect it from unauthorised access, loss and misuse. We never sell any of your personal data for any purpose. We further restrict access to any sensitive personal data we may collect (medical records for example), such data is never used for marketing purposes. 

6. Data Sharing 

Usually the Clinic will not share information about you with other organisations unless they are involved in your care or you have agreed to data sharing, such as when instructing us to send your prescription to a pharmacy.

We may disclose information to other departments where it is necessary, either to comply with a legal obligation, or where permitted under other legislation. At no time will your information be passed to organisations for marketing or sales purposes or for any commercial use without your prior express consent.

We may need to share your information for the following reasons:

• There is an immediate risk of harm to you or other people.
• There is a legal requirement to do so e.g. the police have obtained a court order requiring us to provide information.
• In the interests of demonstrating a transparent decision-making process.
• Where we are required to provide statistical information about a group of people; although your data will be anonymised to protect identity.
• Where you have responded to public consultation; although your comments will be anonymised to protect your identity.
• We will not publish any of your sensitive personal information unless there is a legal or statutory requirement to do so. 

7. Emails 

If you email us, we may keep a record of your email address and a copy of the email for record keeping purposes. For security reasons we will not include any confidential information about you in any email we send to you. We would also suggest that you keep the amount of confidential information you send to us via email to a minimum or use our secure online services where possible. We will not share your email address or your email contents unless it is necessary for us to do so; either to fulfil your request for a service; to comply with a legal obligation, or where permitted under other legislation.

8. Telephone Calls 

We do not record or monitor any telephone calls you make to us using recording equipment, although if you leave a message on our voicemail systems your message will be kept until we are able to return your call or make a note of your message. File notes of when and why you called may be taken for record keeping purposes. We will not pass on the content of your telephone calls, unless it is necessary for us to do so; either to fulfil your request for a service; to comply with a legal obligation, or where permitted under other legislation.

9. Your Rights 

You can ask us to stop processing your information: You have the right to request that we stop processing your personal data in relation to any of our services. However, this may cause delays or prevent us delivering a service to you. Where possible we will seek to comply with your request but we may be required to hold or process information to comply with a legal requirement.

You can withdraw your consent to the processing of your information: In the few instances when you have given your consent to process your information, you have the right to withdraw your consent to the further processing of your personal data. However, this may cause delays or prevent us delivering a service to you. We will always seek to comply with your request but we may be required to hold or process your information in order to comply with a legal requirement.

You can ask us to correct or amend your information: You have the right to challenge the accuracy of the information we hold about you and request that it is corrected where necessary. We will seek to ensure that corrections are made not only to the data that we hold but also any data held by other organisations/parties that process data on our behalf.

You request that the processing of your personal data is restricted: You have the right to request that we restrict the processing of your personal information. You can exercise this right in instances where you believe the information being processed is inaccurate, out of date, or there are no legitimate grounds for the processing. We will always seek to comply with your request but we may be required to continue to process your information in order to comply with a legal requirement.

You can ask us for a copy of the information we hold about you: You are legally entitled to request a list of, or a copy of any information that we hold about you. However, where our records are not held in a way that easily identifies you, for example a land registry, we may not be able to provide you with a copy of your information, although we will do everything we can to comply with your request.

If you have questions about information in this privacy notice or your rights you can contact our offices, please email: contact@carpathiaclinic.com 

10. Complaints 

You can complain to us about the way your information is being used. If you have any concern regarding the processing of your personal data please contact our Clinic Manager by telephone on 01534 888121 or via email at contact@carpathiaclinic.com

Our Address: Carpathia Clinic, 1st Floor, York Chambers, 18 Charing Cross, St Helier, Jersey JE2 3RP

You can also complain to the Information Commissioner about the way your information is being used. The Office of the Information Commissioner can be contacted in the following ways:

• Telephone: 01534 716530
• Email: enquiries@jerseyoic.org
• Address: Office of the Information Commissioner, 2nd Floor, 5 Castle Street, St. Helier, Jersey JE2 3BT