It is important that you read this notice, together with any other documents we may provide when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Personal data is data which relates to any living individual who can be identified from that data, or from that data and other information; such as an expression of opinion about the individual.What is the GDPR?
The General Data Protection Regulation 2018 (GDPR) replaces the Data Protection Act 1998 (DPA) in governing how personal data is managed by a "controller" or "processor".
In this respect, a data controller is a person (or business) who determines the way in which, personal data is processed. A data processor is anyone who processes personal data on behalf of the data controller (not including the data controller's own employees).
A "Data Subject" is a person whose data is being processed.
IGP is both a controller and processor of personal data. This means that we are responsible for deciding how we hold and use personal information about you, whether you use our services directly or via a third-party.
Under the GDPR, the data protection principles set out the main responsibilities for organisations.
GDPR requires that personal data shall be:
Processed lawfully, fairly and in a transparent manner.
Collected for specified, explicit and legitimate purposes.
Adequate, relevant and limited to what is necessary.
Accurate and, where necessary, kept up to date.
Kept in a form which permits identification of data subjects for no longer than is necessary.
Processed in a manner that ensures appropriate security of the personal data.
It also requires that the controller shall be responsible for, and be able to demonstrate, compliance with the principles.
The right to be informed – IGP must provide details (such as those provided in this privacy notice) of how IGP processes information to the data subject. This information must be available at any time personal data is obtained.
The right of access – Data subjects have the right to know what information IGP has in relation to them. Data subjects then have the right to access this information.
The right to rectification – Data subjects have the right request we update inaccurate or incomplete information that is being processed or stored by IGP. We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you do not believe this is the case, you can request for us to update or amend it.
The right to erasure – Data subjects have the right to request we delete any information IGP have in relation to them. However, as a medical practice we also have a legal duty to retain medial records for a period of time in line with UK law and guidelines, or if we are bound by other legal obligations.
The right to restrict processing – Data subjects have the right to block or suppress IGP processing their information. However, it may be necessary to keep your information in order to perform a task which is in the public interest or for the purposes of establishing, exercise or defending legal claims.
The right to data portability – Data subjects can request that IGP make their information available to move, copy or transfer personal data easily from one environment to another.
The right to object – Data subjects can object to processing their information for activities such as marketing.
Individuals also have rights in relation to automated decision making and profiling. However, IGP does not carry out this type of processing.
Registered Company Name:
The Independent General Practice Ltd.
Company Registration Number:
Registered Company Address:
Cardiff Gate Business Park,
Oaktree House, Oaktree Court,
Cardiff Gate Business Park,
Any information collected or produced as part of these services will be managed in accordance with The Independent General Practice's information security policies & procedures.
To process your data lawfully IGP must have a legal basis to do so. Set out below are some of the ways in which IGP process your personal data.
We normally process personal data if it is:
Necessary to provide you with a service - to enable us to carry out our obligations to you arising from any contract entered into between us and you.
In our or a third party's legitimate interests to do so - see details below.
Necessary for the performance of a task carried out in the public interest.
Required or allowed by any applicable law.
With your explicit consent.
Generally, we will only ask for your consent to processing if there is are no other legal grounds to process. In these circumstances, we will always aim to be clear and transparent about why we need your consent and what we are asking it for. Where we are relying on consent to process personal data you have the right to withdraw your consent at any time by contacting us using the details below and we will stop the processing for which consent was obtained.
To process special category data we rely on additional legal grounds and generally, they are as follows:
With your explicit consent.
It is necessary for the purposes of occupational medicine, for the assessment of the working capacity of the employee, or the management of health and social care systems and services.
It is necessary to establish, make or defend legal claims or court action.
It is necessary so that we can comply with employment law.
It is necessary for a public interest purpose in line with any laws that are applicable. This should assist in protecting the public against dishonesty, malpractice or other seriously improper behaviour for example, investigating complaints, clinical concerns, regulatory breaches or investigations e.g. the Health Inspectorate Wales/Care Quality Commission or GMC or ICO.
Please note that not all of the above legal bases will apply for each type of processing activity that IGP may undertake. However, when processing any personal data for any particular purpose, one or more of the above legal bases will apply.
Information about an individual, that is likely to be of a sensitive or private nature and could be used in a discriminatory way, is described as sensitive personal information and identified as special category data. This type of information needs to be treated with greater care than other forms of personal data.
Sensitive personal information may include:
Racial or ethnic origin
Religious or other similar beliefs
A physical or mental health or condition
When a data subject presents for an appointment, they will be required to provide, or a clinician may generate/obtain and document information that may contain sensitive or special category data, including information relating to a physical or mental health or condition.
IGP may act as a processor of personal data but become a controller in obtaining special category data during an appointment. IGP may also be a controller and need to transfer information to a third-party where the third-party acts as a processor. In these instances:
Third-parties will be identified to the data subject prior to transfer of information.
Consent may be required for IGP to share personal information with third-parties, irrespective of their original role.
Third-parties will be required to have a contractual agreement with IGP. As part of this contract third-parties will be required to demonstrate that they have attained a suitable level of information security and have met the standards set by GDPR in acting as processor.
IGP will not routinely transfer information outside of the EU. However, upon request from the data subject, IGP may be required to do so. In this situation, IGP will again need to ensure that there are satisfactory safeguards in place and that the recipient has a suitable level of information security and meet the same standards set by GDPR.
In direct communications (such as website, telephone, letter or video) either with the data subject or a third-party controller.
When a data subject completes a consent form, template, questionnaire or registration form, either directly from the data subject or via a third-party.
When a clinician completes a clinical record or report as part of a consultation/appointment.
As part of a third-party instruction or referral where IGP is a processor.
As part of a clinical record obtained from a third-party, such as a diagnostic test result, screen or clinical specialist/expert/consultant where IGP is the original controller and referrer.
As part of financial processing.
A Cookie is a small file that is requested by your internet browser (such as Edge, Chrome, Safari or Firefox) and stored on your computer or device. This cookie file contains various information about websites you have visited. This can include information such as your location, the type of device you are using etc. However, in some instances, some personal data can also be stored, such as when you add items to a shopping cart or enter form information. We use analytics programs (Such as Google Analytics), which collects cookie information to provide us with statistical data about visitors to our websites.
This data includes, how many visits we had, which pages were visited, what device was used and details of from where the visitor was directed to our website.
IGP will need to obtain a minimal amount of personal data to:
Contact a data subject, provide details of an appointment.
When IGP need to make changes to an appointment.
Identify the data subject in relation to their own existing medical record(s).
The type of information includes:
Information that you provide when you enquire, become a customer, patient or apply for a job.
Details of correspondence.
The name and contact details of your next of kin/parent/guardian.
Details of service or treatment you have received from us.
Notes, records or reports relating to your health and/or treatment you have received.
Information you provide when you make a payment, such as financial or credit card information. We Do not store credit/debit card information, unless we have your consent.
Data subjects are permitted to arrange appointments anonymously. However, the data subject will need to provide identifiable details, which will need to be recounted in communications with IGP to provide a continual service, such as receiving results.
The minimum amount of personal data a data subject is required to provide is contact information, name and date of birth. However, as part of an appointment, a clinician may also need to obtain or create sensitive personal information about a data subject, which includes information relating to a physical or mental health condition. IGP may also refer to previous medical opinion (such as medical records). IGP may also request further investigations and/or opinion in the form of a diagnostic screen result or report from a clinical specialist/expert/consultant.
The amount of information required will vary depending individual circumstances, symptoms or requirement. However, the personal data required will be proportional and relevant. For instance, IGP may require a complete family medical history from data subjects undertaking a health assessment or IGP may need to know whether a data subject is pregnant prior to administering a vaccine.
Data subjects are not compelled to provide any information. However, if you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or we may be prevented from complying with our legal obligations. Withholding or providing inaccurate information may also affect the ability of our clinicians to provide an effective and safe service.
The information IGP collect will be confidential and only ever be used for the purposes of undertaking or providing consultation, treatment, immunisation, examination, diagnostic and/or medical management services. As part of these services IGP may require personal information to create appointments and to convey or record medical opinion. IGP will not use or pass on personal data to market services that are unrelated to those that have been consented. However, with consent, IGP may use personal data to inform a data subject about a follow-up or related service.
Sensitive personal data will only be disclosed to those involved with your appointment, care, in accordance with UK laws and guidelines of professional bodies or for the purpose of clinical audits.
We may use your personal data to:
Full-fill our obligations to you in relation to a contractual agreement to provide a service, including financial obligations.
Provide you with information about products or services that we provide.
Notify you about a change to the service requested.
Respond to a request.
Ensure the accuracy of information we hold about you.
Support a healthcare professional or clinician directly involved in your care.
Assess the quality of service you have received.
Information is either stored as an electronic record, on a central database or as a hardcopy (paper record) at IGP£s main administration centre. Information may be processed externally on-site or at one of IGP's clinic locations, so long as use abides to IGP's information security and Remote Working policy. A secure back-up of information is also stored externally, by an ISO accredited IT support provider.
Personal data, including special category data, may be stored temporarily as part of communications, such as email or in a hardcopy transferable format, such as a data disk or paper record.
With consent, IGP may share information with third-parties for further investigation and/or specialist opinion. Examples of third-parties include:
Clinical experts, specialists or consultants
Screening centres or laboratories
Solicitors or agencies where IGP is originally acting as processor
Employers who refer to IGP for occupational health opinion
Anonymised information may be made available to Healthcare Inspectorate Wales (HIW) or Care Quality Commission (CQC) as part of a healthcare inspection to ensure that The Independent General Practice meets the requirements set by the government provide private healthcare services.
IGP may also need to make information available on the basis of necessity. For instance, in an emergency, we may need to process your personal data (including sensitive personal data) or make personal data available to third parties on the basis of protecting your vital interest (i.e. your life or your health).
In providing a service, we may disclose your personal data to third-parties, including:
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you.
Organisations providing IT systems support and hosting in relation to the IT systems on which your information is stored.
Third party service providers for the purposes of storage of information and confidential destruction, third party marketing companies for the purpose of sending marketing emails, subject to obtaining appropriate consent.
Where a third party data processor is used, we ensure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under Data Protection Laws.
Data subjects have the right to withdraw consent or request a copy/transferal/removal of certain information by requesting IGP£s Consent Removal form.
However, as a healthcare provider, we may not be legally able to complete your request to restrict the processing or deletion of personal information.
In relation to data retention, IGP adhere to The Independent Health Care (Wales) Regulations 2011 - SCHEDULE 3 Regulation 23(1), (3).
(a) Patient who was under the age of 17 at the date on which the treatment to which the records refer was concluded.
Minimum period of retention: Until the patient's 25th birthday
(b) Patient who was aged 17 at the date on which the treatment to which the records refer was concluded.
Minimum period of retention: Until the patient's 26th birthday
(c) Patient who died before attaining the age of 18.
Minimum period of retention: A period of 8 years beginning on the date of patient's death.
(d) Patient who was treated for mental disorder during the period to which the records refer.
Minimum period of retention: A period of 20 years beginning on the date of the last entry in the record.
(e) Patient who was treated for mental disorder during the period to which the records refer and who died whilst receiving that treatment.
Minimum period of retention: A period of 8 years beginning on the date of the patient's death
f) Patient whose records relate to treatment by a general practitioner.
Minimum period of retention: A period of 10 years beginning on the date of the last entry in the record
(g) Patient who has received an organ transplant
Minimum period of retention: A period of 11 years beginning on the date of the patient's death
(h) All other cases.
Minimum period of retention: A period of 8 years beginning on the date of the last entry in the record.
Information that cannot be adequately attributable may result in deletion.
Suspected breaches in data protection can be reported to The Independent General Practice£s Data Protection officer Kieran Reynolds. Breaches in Data Protections will result in The Independent General Practice producing an incident investigation. Serious breaches will be reported to the Information Commissioner£s Office (ICO). You retain the right to report a breach to the ICO directly - https://ico.org.uk/for-organisations/report-a-breach/.
It is the responsibility of all IGP employees and contractors to report suspected breaches of information security to IGP department heads, IT department, and/or Data Protection Officer without delay.