Privacy Policy
COVID–19 Data Protection Statement
During these unprecedented times, HCA Healthcare’s main priority is the health and safety of our patients, colleagues and the wider community as well as supporting the NHS in responding to the COVID-19 pandemic. We are supporting the NHS in responding to the COVID-19 pandemic and this will remain our focus for the foreseeable future.
As a result of these unique circumstances, HCA may need to share personal data with the NHS and other regulatory and government bodies for the purpose of supporting the response to the COVID-19 pandemic. Each of our hospitals is working in collaboration with their local NHS trusts to ensure we can provide the right help, exactly where and when it is needed and this may involve personal data being shared with us by the local Trusts. This will be done in accordance with data protection laws and will include any amendments to legislation made by the Secretary of State. We will also consider any guidance provided by the Information Commissioner’s Office.
When the NHS and its healthcare professionals provide your healthcare services at a HCA hospital, the privacy notice of the relevant NHS Trust may also apply.
Data Subject’s Rights
Due to the current circumstances, if you submit a Subject Access Request (SAR) or other Data Subjects Rights request, please be aware that you may experience a delay in us responding to your request. That’s because we will be diverting resources to help with other challenges and ensuring the ongoing healthcare and treatment of our patients.
At this current time we are unable to collect any correspondence sent via post. If you need to get in touch regarding a SAR or other information request, please contact us via email at DPO@HCAHealthcare.co.uk
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 document. The personal data we use may include:
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 to you and receive payment for these services.
Monitoring of communications
Subject to applicable laws, we may monitor and record telephone 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)b; Article 9 (2)h of the General Data Protection Regulations. In addition HCA will rely one or more of the following basis when sharing personal data as part of our support work with the NHS during the COVID-19 pandemic:
When processing special category data for the purposes of;
* This includes the Notice by Secretary of State under Reg 3(4) of Health Service Control of Patient Information Regulations issued 1st April 2020 allowing healthcare providers to share personal data and any other such notice that may be issued to support efforts against COVID-19.
We use your personal data to support the provision of your healthcare in the following ways:
We will process your personal data under Article 6 (1) f of the General Data Protection Regulations:
As necessary to comply with a legal obligation:
Based on your consent:
Sharing of your personal data
Subject to applicable data protection laws we may share your personal data with:
Sharing of your Personal Data during the Covid-19 pandemic
During the Covid-19 pandemic your personal data may also be shared for the following purposes:
We will regularly review this privacy statement and its applicability throughout the COVID-19 outbreak. We may also notify you in other ways from time to time about the processing of your personal information.
Sharing NHS numbers
Your NHS number may be shared with PHIN as part of the process
above. 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.
Sharing of your personal data for scientific 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 in order to receive payment
for your treatment from your Insurer, sponsor or
guarantor
We will contact the individual or company including your insurer
and provide them with the information necessary to support our
invoices for payment and to ensure that we receive full payment for
your care. We may also contact them prior to your care to confirm
that the treatment you are about to receive is covered by them and
they are willing to pay for your care. We will also provide
information necessary to support any audits carried out by insurers
and sponsors.
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 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:
Your rights under applicable data protection
law
Your rights are as follows (noting that these rights do not apply
in all circumstances):
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.
How we use cookies
A cookie is a small file which asks permission to be placed on
your computer's hard drive. Once you agree, the file is added and
the cookie helps analyse web traffic or lets you know when you
visit a particular site. Cookies allow web applications to respond
to you as an individual. The web application can tailor its
operations to your needs, likes and dislikes by gathering and
remembering information about your preferences.
We have tried to cover all
cookies in this list that we or our service providers use.
Please be aware that there may be a delay in updating this list. If
you do notice any discrepancies please be sure to let us know.
Content management and responsibility
HCA International Limited, "HCA UK", and the hosts of this website, accept no responsibility for, and exclude all liability in connection with browsing this website, use of information on this website and downloading any material from it, including, but not limited to, any liability for errors, inaccuracies, omissions or misleading or defamatory statements.
Downloads
Although every reasonable effort is made to ensure that files are free of defects and viruses, there are no guarantees that they are free from defects or computer viruses. Therefore, no warranty or guarantee is given by HCA UK, regarding files downloaded or accessed through HCA UK's website or through a link accessed via HCA UK's website.
Website contents
This website is intended to enable information relevant to the
work of HCA UK, to be freely available on the World Wide Web.
Whilst HCA UK hopes you find this website interesting and
informative, the contents are for general information only. HCA UK
believes the contents to be true and accurate as at the date of
writing, but can give no assurances or warranties regarding the
accuracy, currency or applicability of any of this website's
contents. As such, the contents of this website should not be
relied upon. In addition, none of the content of this website will
form any contract between HCA UK and any user of the website, nor
constitute any offer by HCA UK. The use of and access to pages of
the HCA UK website is subject to the foregoing disclaimer, and the
terms and conditions set out below. By using or accessing this
website, you agree to be bound by these terms and conditions.
HCA UK shall not be liable for any loss or damage howsoever arising
in connection with the content of the website. HCA UK does not
guarantee that the website will be error-free, omission-free,
uninterrupted or without delay.
Website security
Whilst HCA UK makes all reasonable attempts to exclude viruses
from the website, we cannot guarantee that the website will be
virus free and accept no liability in the unlikely event that the
website is not virus free.
Users are recommended to take appropriate safeguards before
downloading information from this website.
Access to information
HCA UK will not share your confidential information with anyone
outside of HCA UK. You are prohibited from posting or transmitting,
to and from, the website any unlawful, threatening, defamatory,
obscene, and pornographic or other material which would violate any
law.
Unless otherwise specified, the materials on this website are
directed solely at those who access this website from the United
Kingdom mainland. HCA UK makes no representation that any
information, product or services referred to in the materials on
this website are appropriate for use, or available, in other
locations. Those who choose to access this website from other
locations are responsible for compliance with local laws if and to
the extent local laws are applicable.
Website availability
Although the website has been tested and should work correctly under normal circumstances, there are many factors both within and outside of the control of HCA UK, which may prevent the website from being available. No responsibility is accepted by HCA UK, for any losses howsoever caused that may arise from an inability to access or to access resources through its website. If you find any errors within the HCA UK website, including links that do not work, pages linked to the wrong document and out of date information, please email the HCA Healthcare UK digital team.
We are committed to respecting and protecting your privacy when we deal with your personal information. The following privacy notice gives you details on the information we collect about you, how we protect and use it, and your rights. If you have any questions about how we use your information, please email us at DPO@hcahealthcare.co.uk.
You can pick up a copy of this Privacy Notice from Reception at
our Facilities or download
a copy of our Privacy Notice here.
Further information can be provided from our Data Protection
Officer on DPO@hcahealthcare.co.uk
This Notice may be translated into other languages on request.
Last updated: April 2020