This Privacy Notice sets out the basis upon which any personal data we collect from you, or that you provide, will be processed by us. Please read the following carefully to understand our views and practices relating to the processing of your personal data.
- Provides you with a detailed overview of how we will manage your data, from the point at which it is collected and going forwards.
- Will give you all the details you need on how we use your information, and how we will comply with the law in doing so.
- With your specific agreement, we may also contact you with marketing materials.
- Sets out your rights in respect of your personal information, and how to exercise them. You can, for instance, seek access to your medical information, object to us using your information in particular ways, and request rectification of any information which is inaccurate.
Our Contact Details
- Name: Horizon Fertility, company number 14038483
- Registered address: Rodney Chambers, 40 Rodney Street, Liverpool, L1 9AA
- Practice address: 88 Rodney Street, Liverpool, L1 9AR
- Phone Number: 0333 666 0000
- Email: firstname.lastname@example.org
- Website: www.horizonfertility.com
In this Privacy Notice we use "we" or "us" or "our" to refer to Horizon Fertility who will be using your personal information, to provide our services to you. We are committed to protecting and respecting your privacy and intended to comply with the requirements of the current legal framework in relation to the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018) on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data. For the purposes of Data Protection Legislation, we are the data controller.
Personal data is defined in the UK GDPR as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
In providing our services, we may process personal data and special categories of personal data about you We may collect, use, store and transfer the following types of personal data about you:
- Identity details, including your first name, last name, gender, date of birth;
- Contact details, including your address, email address and telephone number;
- Emergency contact details, including next of kin;
- Financial details, including bank account, payment or credit card information;
- Technical details, including IP address, geographical location, browser type and version, operating system, and other technology on the devices you use to access our Website;
- Website usage details, including referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency, and pattern of your service use;
- Marketing and communications details, including your preferences in receiving marketing from us and your communications preferences.
We may also collect, use, store and transfer the following special categories of personal data about you:
• data concerning your health, including details of your medical history, fertility treatment history, current treatments, medications, appointments, scans, and test results;
• data concerning your sex life or sexual orientation but only when this information is relevant to the treatment you are receiving and in order to personalise our services;
• personal data revealing your nationality, race and/or ethnicity, or religious beliefs but only when this information is relevant to the treatment you are receiving and in order to personalise the services.
How Do We Collect Your Personal Data?
Most of the personal information we process is provided to us directly by you when:
- You complete a contact form on the website;
- You submit a query to us through by email or by social media;
- You complete registration forms;
- You receive treatment, diagnosis or screening services from Horizon Fertility
- You communicate with us by letter, email or telephone;
- You reference Horizon Fertility in a review, feedback form or social media post.
We also receive personal information indirectly, from the following sources: Referral from other healthcare organisations:
Information may be shared with us directly from another healthcare organisations so we can provide specific services to you. This information may include:
- Medical records from your GP;
- Medical records from your clinician or healthcare professional;
- Medical records from the NHS or a private healthcare organisation.
Communication with third party service providers:
It is sometimes necessary that we communicate with other external organisations to collection information necessary to provide our services:
- We communicate with third party health professionals or other treatment providers;
- We liaise with your current or former employer;
- We liaise with insurance companies or other healthcare benefit provider;
- We liaise with regulatory authorities such as the HFEA, the Home Office and HMRC.
How Do We Use Your Personal Data?
Horizon Fertility collects, processes and stores personal information for the purpose of providing its services. Each time we use your data we must have a lawful basis (or bases) to do so. For this reason, we will only use your personal data when the law allows us to.
Most commonly, we will use your personal data in the following circumstances:
- Where we are to provide our services in accordance with your requests, i.e our contract to provide the requested services to you. We rely on this information to support the diagnosis, screening, and medical treatment services we provide;
- When processing is necessary on the basis of our legitimate interests or those of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data. We will rely on this for activities such as, maintaining accurate personal records, developing, and improving our services and monitoring outcomes; • Where we need to comply with a legal or regulatory obligation. We are required by law to provide your personal information to our regulator, and in which case we will have a legal responsibility to do so;
- Where you have provided your consent to our use of your personal information and disclosure third parties as required;
- In the case of special categories of personal data, where you have provided your explicit consent.
Please note that where you have provided us with your consent to use your personal data, you can withdraw your consent to further use of your personal information at any time. Withdrawal of your consent will not impede on the lawfulness of the processing of your personal data conducted up to the date of the withdrawal. You can withdraw your consent by contacting Aria whose details at the top of this policy. In relation to your use of our services, please be aware that the withdrawal of your consent will prevent us from providing any further services to you.
Who Do We Share Your Personal Information With?
- Yourself, upon your request & consent;
- Specifically authorised personnel of Aria, including doctors, nurses, scientists, carers, administrators or any other healthcare professionals involved in your treatment;
- Anyone that you ask us to communicate with or provide as an emergency contact, for example your next of kin;
- Pharmacists, health facilities, pathology laboratories and regulatory bodies, specifically authorised and abiding to medical confidentiality and health data sharing regulations;
- Homecare fertility medication providers;
- We may disclose your personal data to our service providers who assist with administration of your healthcare, such as insurance companies or external benefits provider;
- Our third party services providers such as IT suppliers, accountants, auditors, lawyers, marketing agencies and, document management providers;
- Regulatory and/or government bodies such as the Human Fertilisation & Embryology Authority (HFEA), Care Quality Commission (CQC), the Home Office and HMRC;
- We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure;
- Any scientific partners of Aria that would carry out studies, research, or evaluations, providing that your personal data will be pseudonymised.
Horizon Fertility ensures that none of your personal data will be transferred to a non-authorised third party, without your consent. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
How Do We Protect Your Personal Data?
We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How Long Will Your Personal Data Be Kept?
We will only keep your personal information for as long as reasonably necessary to fulfill the relevant purposes set out in this Privacy Notice and in order to comply with our legal and regulatory obligations In case you decide to not use our services, your personal data will be kept for 1 year from the date that you tell us. Please note that the HFEA requires licensed clinics that patient/donor records, for full traceability, must be kept for a minimum of 30 years (or for such longer period as may be specified in Directions from the HFEA) after clinical use, or the expiry date, in an appropriate archive acceptable to the HFEA. Whereby we do not know that any child was born following the treatment, no information shall be removed from the records of the centre for which that person is responsible before the expiry of a period of 50 years after the information was first recorded. For any other personal not covered by the HFEA guidelines, this will be kept during your contractual relationship with Horizon Fertility and then will be archived for a period of 7 years before it is deleted. In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. For example, usage details will be retained for as long as necessary for the relevant processing purposes.
We (or third parties acting on our behalf) may store or process information that we collect about you in countries outside of the United Kingdom. For example, some of the service providers we use for pathology testing send pathology samples to a lab in the France, Spain, South Africa and the USA, and this would involve a transfer of your personal data their. Whenever we transfer your personal data outside the United Kingdom, we ensure that a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented, where necessary.
What Are Your Rights Concerning Your Personal Data?
Under data protection law you have certain rights in relation to the personal information that we hold about you.
These include rights to know what information we hold about you and how it is used. Under certain circumstances, by law you have the right to:
- Information relating to how we collect and process your personal data (Privacy Notice);
- Access your personal information; • Rectify or correct any mistakes to your personal data;
- Erase your personal data, in certain situations;
- Apply restrictions on our processing of your personal data;
- Obtain an electronic copy of your personal data (right of portability);
- Object in certain other situations to our continued processing of your personal data;
- Object to decisions being taken by automated decision making including profiling, which means decision making solely by automated means without any human involvement;
- Withdraw your consent to our processing of your personal data, where we have collected and processed your personal data with your consent.Please note, however, that where you withdraw your consent this will limit our ability to provide our services to you;
- Make a complaint to your supervisory authority. In the UK, this is the Information Commissioner’s Office (www.ico.org.uk).
You may exercise these rights at any time by contacting us using the details set out above at the top of this policy.
We may need to request further information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within 20 working days. Occasionally it may take us longer than 20 working days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If these changes result in any material difference to the manner in which we process your personal data these changes will be displayed on our website.