Harley Mind Care

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Privacy Policy

Privacy Policy

Last Updated On 23-Apr-2024
Effective Date 23-Apr-2024

This Privacy Policy describes the policies of Harley Mind Care Psychiatrists Ltd, 10 Harley Street, London, London W1G 9PF, United Kingdom of Great Britain and Northern Ireland (the), email: Hello@harleymindcare.com, phone: 02070478888 on the collection, use and disclosure of your information that we collect when you use our website ( https://harleymindcare.com ). (the “Service”). By accessing or using the Service, you are consenting to the collection, use and disclosure of your information in accordance with this Privacy Policy. If you do not consent to the same, please do not access or use the Service.
We may modify this Privacy Policy at any time without any prior notice to you and will post the revised Privacy Policy on the Service. The revised Policy will be effective 180 days from when the revised Policy is posted in the Service and your continued access or use of the Service after such time will constitute your acceptance of the revised Privacy Policy. We therefore recommend that you periodically review this page.

Information We Collect:


We will collect and process the following personal information about you:

Name
Email
Mobile
Social Media Profile
Date of Birth
Address
Payment Info
Gender
GP Information,

How We Collect Your Information:


We collect/receive information about you in the following manner:

When a user fills up the registration form or otherwise submits personal information
Interacts with the website
From public sources

How We Use Your Information:


We will use the information that we collect about you for the following purposes:

Marketing/ Promotional
Creating user account
Testimonials
Customer feedback collection
Enforce T&C
Processing payment
Support
Administration info
Targeted advertising
Manage customer order
Site protection
User to user comments
Manage user account
If we want to use your information for any other purpose, we will ask you for consent and will use your information only on receiving your consent and then, only for the purpose(s) for which grant consent unless we are required to do otherwise by law.

How We Share Your Information:


We will not transfer your personal information to any third party without seeking your consent, except in limited circumstances as described below:

Ad service
Marketing agencies
Analytics
Data collection & process
We require such third party’s to use the personal information we transfer to them only for the purpose for which it was transferred and not to retain it for longer than is required for fulfilling the said purpose.
We may also disclose your personal information for the following: (1) to comply with applicable law, regulation, court order or other legal process; (2) to enforce your agreements with us, including this Privacy Policy; or (3) to respond to claims that your use of the Service violates any third-party rights. If the Service or our company is merged or acquired with another company, your information will be one of the assets that is transferred to the new owner.

Retention Of Your Information:


We will retain your personal information with us for 90 days to 2 years after users terminate their accounts or for as long as we need it to fulfill the purposes for which it was collected as detailed in this Privacy Policy. We may need to retain certain information for longer periods such as record-keeping / reporting in accordance with applicable law or for other legitimate reasons like enforcement of legal rights, fraud prevention, etc. Residual anonymous information and aggregate information, neither of which identifies you (directly or indirectly), may be stored indefinitely.

Your Rights:


Depending on the law that applies, you may have a right to access and rectify or erase your personal data or receive a copy of your personal data, restrict or object to the active processing of your data, ask us to share (port) your personal information to another entity, withdraw any consent you provided to us to process your data, a right to lodge a complaint with a statutory authority and such other rights as may be relevant under applicable laws. To exercise these rights, you can write to us at Hello@harleymindcare.com. We will respond to your request in accordance with applicable law.
Do note that if you do not allow us to collect or process the required personal information or withdraw the consent to process the same for the required purposes, you may not be able to access or use the services for which your information was sought.

Cookies Etc.


To learn more about how we use these and your choices in relation to these tracking technologies, please refer to our Cookie Policy.

Security:


The security of your information is important to us and we will use reasonable security measures to prevent the loss, misuse or unauthorized alteration of your information under our control. However, given the inherent risks, we cannot guarantee absolute security and consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

Third Party Links & Use Of Your Information:


Our Service may contain links to other websites that are not operated by us. This Privacy Policy does not address the privacy policy and other practices of any third parties, including any third party operating any website or service that may be accessible via a link on the Service. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Grievance / Data Protection Officer:


If you have any queries or concerns about the processing of your information that is available with us, you may email our Grievance Officer at Harley Mind Care Psychiatrists Ltd, 10 Harley Street, London, W1G 9PF, email: Hello@harleymindcare.com. We will address your concerns in accordance with applicable law.

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PRIVATE PRACTICE PRIVACY NOTICE FOR PATIENTS

What is a Privacy Notice?

A Privacy Notice (or ‘Fair Processing Notice’) is an explanation of what information the Private practice collects on patients, and how it is used. Being transparent and providing clear information to patients about how a private practice uses their personal data is an essential requirement of the GDPR & Data Protection Act 2018.

Under the DPA, the first principle is to process personal data in a fair and lawful manner and applies to everything that is done with a patient’s personal information. In private practice, this means that the Private practice must;

  • have legitimate reasons for the use or collection of personal data
  • not use the data in a way that may cause adverse effects on the individuals (e.g. improper sharing of their information with 3rdparties)
  • be transparent about how the data will be used, and give appropriate privacy notices when collecting their personal data
  • handle personal data only as reasonably expected to do so
  • make no unlawful use of the collected data

Fair Processing

Personal data must be processed in a fair manner – the DPA says that information should be treated as being obtained fairly if it is provided by a person who is legally authorised or required to provide it. Fair Processing means that the Private practice has to be clear and open with people about how their information is used.

Providing a ‘Privacy Notice’ is a way of stating the Private practice’s commitment to being transparent and is a part of fair processing, however, you also need to consider the effects of processing on the individuals and patients concerned;

  • What information are we collecting?
  • Who collects the data?
  • How is it collected?
  • Why do we collect it?
  • How will we use the data?
  • Who will we share it with?
  • What is the effect on the individuals?
  • If we use it as intended, will it cause individuals to object or complain?

Conducting a Privacy Impact Assessment is an effective way of assessing whether you can safely collect or use patient data according to the DPA and Information Governance requirements. The Information Commissioners’ Office has published guidance on carrying out a PIA which can be found here;

https://ico.org.uk/media/about-the-ico/consultations/2052/draft-conducting-privacy-impact-assessments-code-of-practice.pdf

Data Controllers

Under the Data Protection Act 2018, the data controller is the person or private practice that will decide the purpose and the manner in which any personal data will be processed – they have overall control of the data they collect, and decide how and why it will be processed.

A clinical private practice is a data controller for the patient information it collects, and should already have data processing arrangements with third parties (e.g. IT systems providers) to ensure they do not use or access data unlawfully; the data controllers will have ultimate responsibility for the Private practices’ compliance with the DPA.

Risk Stratification

This is an acceptable way of assessing patients’ needs and preventing ill health, however, it is also regarded as a disclosure of personal information, and patients have the option to opt out of any data collection at the Private practice, and needs to be made clear to them.

Access to Personal Information

The DPA gives patients the right to view any information held about them – the ‘Right of Subject Access’. Explain the process and who to contact. You can find your private practice registration number by entering your Private practice name in the ‘Name’ box here; https://ico.org.uk/ESDWebPages/Search

Data controller: Harley Mind Care Psychiatrists Ltd
Registration reference: ZB568022

Harley Mind Care Psychiatrist Ltd: Information Commissioner certificate

How we use your information

This privacy notice explains why we as a private practice collect information about our patients and how we use that information.

HARLEY MIND CARE PSYCHIATRISTS LTD manages patient information in accordance with existing laws and with guidance from private practices that govern the provision of healthcare in England such as the Department of Health and the General Medical Council.

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

  • GDPR
  • Data Protection Act 2018
  • Human Rights Act 1998
  • Common Law Duty of Confidentiality
  • Health and Social Care Act 2012

As data controllers, clinicians have fair processing responsibilities under the GDPR & Data Protection Act 2018. In private practice, this means ensuring that your personal confidential data (PCD) is handled clearly and transparently, and in a reasonably expected way.

The Health and Social Care Act 2012 changed the way that personal confidential data is processed, therefore it is important that our patients are aware of and understand these changes, and that you have an opportunity to object and know how to do so.

The healthcare professionals who provide you with care maintain records about your health and any treatment or care you have received. These records help to provide you with the best possible healthcare.

Health records may be processed electronically, on paper or a mixture of both; a combination of working private practices and technology are used to ensure that your information is kept confidential and secure. Records held by this private practice may include the following information:

  • Details about you, such as address and next of kin
  • Any contact the private practice has had with you
  • Notes and reports about your health
  • Details about treatment and care received
  • Results of investigations, such as laboratory tests, x-rays, etc.
  • Relevant information from other health professionals, relatives or those who care for you

The private practice collects and holds data for the sole purpose of providing healthcare services to our patients and we will ensure that the information is kept confidential. However, we can disclose personal information if:

  1. It is required by law
  2. You provide consent – either implicitly or for the sake of their own care, or explicitly for other purposes
  3. It is justified to be in the public interest

Some of this information will be held centrally and used for statistical purposes. Where we hold data centrally, we take strict and secure measures to ensure that individual patients cannot be identified.

Information may be used for clinical audit purposes to monitor the quality of service provided and may be held centrally and used for statistical purposes. Where we do this we ensure that patient records cannot be identified.

Sometimes your information may be requested to be used for clinical research purposes – the private practice will always endeavour to gain your consent before releasing the information.

Improvements in information technology are also making it possible for us to share data with other healthcare providers with the objective of providing you with better care.

Patients can choose to withdraw their consent to their data being used in this way. When the private practice is about to participate in any new data-sharing scheme we will make patients aware by displaying prominent notices in the private practice and on our website at least four weeks before the scheme is due to start. We will also explain clearly what you have to do to ‘opt out’ of each new scheme.

A patient can object to their personal information being shared with other health care providers but if this limits the treatment that you can receive then the doctor will explain this to you at the time.

Private practice Website

Our Website does use cookies to optimise your experience. The ‘Remember my details’ feature on our online prescription form uses first-party cookies on your computer to store your information. This information is only used to remember your details and is never passed to any third party (cookies must be enabled for this to work).

Using this feature means that you agree to the use of cookies as required by the EU Data Protection Directive 95/46/EC. You have the option to decline the use of cookies on your first visit to the website.

To learn more about how we use these and your choices in relation to these tracking technologies, please refer to our Cookie Policy.

Risk Stratification

Risk stratification is a process for identifying and managing patients who are at high risk of requiring emergency or urgent care. Typically this is because patients have a long-term condition such as COPD, cancer or other medical conditions at risk of sudden worsening.

Information about you is collected from a number of sources including NHS Trusts and from this private practice. A risk score is then arrived at through an analysis of your de-identified information using the software as the data processor and is provided back in an identifiable form to your doctor or member of your care team as data controller.

Risk stratification enables your doctor to focus on preventing ill health and not just the treatment of sickness. If necessary, your doctor may be able to offer you additional services.

Please note that you have the right to opt out of Risk Stratification.

Should you have any concerns about how your information is managed, or wish to opt out of any data collection at the private practice, please contact the private practice, or your healthcare professional to discuss how the disclosure of your personal information can be limited.

Patients have the right to change their minds and reverse a previous decision. Please contact the private practice, if you change your mind regarding any previous choice.

How do we maintain the confidentiality of your records?

We are committed to protecting your privacy and will only use information collected lawfully in accordance with the GDPR & Data Protection Act 2018 (which is overseen by the Information Commissioner’s Office), the Human Rights Act, and the Common Law Duty of Confidentiality.

All of our staff, contractors and committee members receive appropriate and regular training to ensure they are aware