Privacy Notice

Solice Health Ltd (SOLICE) is a private GP service providing a range of specialist services, functional medicine support and wrap-around medical concierge care. We are committed to being open and transparent about how we collect and use data and to meeting our data protection obligations. This privacy notice sets out how we use and protect any personal information we hold and process about you. In this document where we refer to the Regulations we refer to the General Data Protection Regulation 2018, and the Data Protection Act 2018 unless otherwise specified.

Data Protection Principles

All personal data obtained and held by us must be processed in accordance with a set of core principles set out in legislation, as follows:

• processing must be fair, lawful and transparent;
• data must be collected for specific, explicit, and legitimate purposes;
• data collected must be adequate, relevant and limited to what is necessary for the purposes of processing;
• data must be kept accurate and up-to-date. Data which is found to be inaccurate will be rectified or erased without delay;
• data must not be kept for longer than is necessary for its given purpose;
• data must be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures

Personal Data

In providing you with our services, we may process your personal data. Personal data is information about you from which you can be identified, such as your name, date of birth and contact details. We also may process ‘special category data’ such as health data.

How do we protect and safeguard your data?

We take the security of your data very seriously. We will only use information collected lawfully in accordance with the General Data Protection Regulation (GDPR) 2018, Data Protection Act 2018, Common Law Duty of Confidentiality and NHS- Code of Confidentiality. Our internal policies and controls are designed by default to ensure that your personal data is not accidentally destroyed, misused, disclosed or lost and is not accessed except by our employees or contractors in the performance of their duties.

Where we engage third parties to process personal data on our behalf, they do so under written instructions, a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

How long do we keep your data?

We only keep your data for as long as is necessary and in accordance with legislation and medical and industry guidelines.

Your rights and how to exercise them:

As a data subject, you have a number of rights and freedoms. You can:

• obtain confirmation as to whether your personal data is being processed and where that is the case, gain access to the personal data;
• Require Solice to rectify incorrect or incomplete data;
• require Solice to erase or stop processing your data, for example where the data is no longer necessary for the purposes of processing; however please note that we are required by law to retain certain medical data
• object to the processing of your data where Solice is relying on its legitimate interests as the legal ground for processing.
• move, copy or transfer your personal data from one IT environment to another, securely and without affecting its usability.

If you would like to exercise any of these rights, please contact contact@solice.health. We will ask you to provide documentation to confirm your identity or, if you are acting on behalf of another individual, we will ask you for proof of their consent or your legal right to receive their personal information.

Call Recording

We record all our calls for training and monitoring purposes. Please be aware, by dialling our phone number as displayed on the website, you consent to the call being recorded and stored within our system. These recordings will be used for:

• Legal purposes
• Quality monitoring
• Training purposes

Changes to our processing arrangements

Should we need to change the way we collect, store or process your data we will contact you to let you know.

We have provided the rest of the information in a layered format to ensure it remains clear and concise. Please see the sub-headings below and select the heading that best describes you:

Visitors to Our Website

What personal data do we collect?

When you use our website we may collect the following personal data:

• your name, email address and telephone number;
• the internet protocol (IP) address of the device you are using, the browser software you use, your operating system, the date and time of access and information on how you use our website;
• information you give to Solice when submitting a contact form
• We may also collect technical data via Google Analytics, however these reports do not contain any personal data.

How do we collect your data?

We may collect this information in a variety of ways. For example, we might collect data when:

• you email us or complete our ‘contact us’ form;
• you fill in your details to register as a customer, book an appointment, or book an event
• you subscribe to email notifications and/or newsletters;
• you complete an online survey.

Why do we process your personal data?

We may process your personal data for any of the following reasons:

• to enable us to contact you in response to a query or request for information;
• to register you for email notifications and/or newsletters that you have subscribed to;
• to book you onto an appointment/meeting, event and/or webinar;
• to collect your opinions as part of any research we may carry out;
• to send you relevant information about Solice, our products and services

What is the lawful basis for processing?

We may process your data on the grounds of contractual or legitimate interests – if we need to respond to your enquiry or enter into a ‘contract’ of services with you, or book you onto an event we are hosting. If you have subscribed to our email notifications or newsletter we are relying on your consent to process your personal data. You can withdraw this consent at any time.

Who do we share your data with?

Your data may be shared internally within Solice and our employees (including contractors and freelance individuals) who may view your data as part of their job role. We store your data on Semble and share your data with WordPress, the providers of our online portal and CRM. We ensure that they apply the same level of security as we do in order to protect your data. We store company data on Google G Suite – Google are registered with Privacy Shield We do not share your personal information with any third-party organisations to use for their own purposes, except:

• when we have your permission;
• to comply with a legal obligation
• to perform a medical task or medical booking
• to carry out a booking that is non-medical related you have asked us to do on your behalf
• if we are under a duty to disclose or share personal data in order to enforce or apply our terms of use (of our website or any part of it) or terms and conditions of supply of any relevant products or services and other agreements;
• to protect the rights, property, or safety of ourselves, our customers, or others;
• in order to detect, prevent and help with the prosecution of financial crime;
• if there are other exceptional circumstances, and we are unable, or it is not appropriate to seek your permission;
• to archive for statistical or research purposes or in the public interest;
• in the reason of public interest.

Third party websites

Our website may from time to time include hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties. We cannot ensure the security of your data when it is being transmitted to our website or other digital sites from other pages. All transmission of personal information and other data is done at your own risk.

The Below Applied To Those Who Use Our Private GP Medical Services

What personal details do we collect?

Details about you include for example,

• details such as name, address, next of kin and contact details;
• billing address if different;
• payment card/bank details;
• details of contact we have had with you during the booking process for appointments;
• details of services you have received;
• written summaries of calls we receive or make;
• email communications we receive or make;
• information about complaints and incidents;
• appointments, consultations, visits, email ;
• notes/reports about your health;
• details of investigations, such as laboratory tests, x-rays, scans ;
• relevant information from other health professionals, relatives, carers

Under the Regulations certain information such as health data is known as special category data as it is of a more sensitive nature, and the processing of such data requires us to provide you with details of our lawful bases under both Article 6 and Article 9 of the GDPR 2018, as supplemented by Schedule 1 Part 1 of the DPA 2018. As a health professional our lawful bases under Article 6 for processing such data are the performance of a contract to provide you with the service, and our legitimate interests which do not in our opinion override your own interests or fundamental rights and freedoms. Under Article 9(2)(h) our lawful basis is the provision of healthcare services.

Why we collect information

As a health professional who provides you with care, we are legally required to maintain records about your health, treatment and care. We collect and hold information about you for the sole purpose of providing you with healthcare services. These records can be written and/or in digital form.

How we use your information

We primarily use your information to enable us to provide you with healthcare services. However, we may also use information to:

• process payments for services you receive;
• investigate patient queries and complaints;
• review the care we provide through audit;
• train and educate members of staff;
• send you relevant information about Solice, our products and services

Invoice Payments

By settling an invoice issued by Solice, you agree to engage with Solice and thus consent to our Privacy Policy, including the storage and use of your data as described above.

Data Retention

We manage patient records in line with the Records Management Code of Practice for Health and Social Care 2016, which sets the required standards. Financial data may be required by law to be retained for up to 7 years. Other data will normally only be retained for as long as it is required in order to provide you with our services.

Access to your information

You have a right under the Regulations to request access to view or to obtain copies of the information we hold about you. You will need to provide adequate information (full name, address, date of birth, and details of your request) so that we can verify your identity and locate your record. We will respond your request within 28 working days unless your request is highly complex or you provide repeated requests, in which case we may take longer. We will not charge for access to your information unless the request is highly complex or you provide repeated requests.

Change of details

It is important that you inform us if any of your details such as your name, address or contact information have changed or if any of your details are incorrect in order for this to be amended. You have the responsibility to inform us of any changes so our records are accurate and up to date for you.

Email address

If you provide us with your email address, we may use it to contact you about your appointments, your treatment and also about billing and administrative matters. We may also email you newsletters, any changes to our services, our opening hours of our practice and other relevant information related to ours and partner services. Please let us know if you do not wish to receive email correspondence from us by contact contact@solice.health

Complaints and Compliments

If you have concerns or are unhappy about any of our services, or to pass on compliments please contact contact@solice.health or speak to us directly.