Continuity Midwifery customer privacy notice
This privacy notice tells you what to expect us to do with your personal information.
· What information we collect, use, and why
· Lawful bases and data protection rights
· Where we get personal information from
· How long we keep information
· Who we share information with
Contact details
Email - birth@continuitymidwifery.co.uk
What information we collect, use, and why
We collect or use the following information to provide patient care, services, pharmaceutical products and other goods:
· Name, address and contact details
· Gender
· Pronoun preferences
· Date of birth
· NHS/HSC/CHI number
· Hospital number
· Next of Kin details including any support networks
· Emergency contact details
· Health information (including medical conditions, allergies, medical requirements and medical history)
· Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
· Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
· Payment details (including card or bank information for transfers and direct debits)
· Records of meetings and decisions
· Call recordings
We also collect the following special category information to provide patient care, services, pharmaceutical products and other goods. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Genetic information
· Health information
· Sexual orientation information
We collect or use the following information for safeguarding or public protection reasons:
· Name, address and contact details
· NHS/HSC/CHI number
· Hospital number
· Emergency contact details
· Health information (including medical conditions, allergies, medical requirements and medical history)
· Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions)
· Relevant information from previous investigations
· Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
· Records of meetings and decisions
We also collect the following special category information for safeguarding or public protection reasons. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Genetic information
· Health information
· Sexual orientation information
We collect or use the following personal information for patient app or portal functionality:
· Names and contact details
· Addresses
· Medical history
· Payment details
· Account information, including registration details
· Information used for security purposes
· Marketing preferences
We also collect the following special category information for patient app or portal functionality. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Genetic information
· Health information
· Sexual orientation information
We collect or use the following personal information to comply with legal requirements:
· Name
· Contact information
· Health and safety information
· Financial information
· Any other personal information required to comply with legal obligations
· Safeguarding information
We also collect the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:
· Racial or ethnic origin
· Religious or philosophical beliefs
· Genetic information
· Health information
· Sexual orientation information
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
· Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
· Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests - we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· I need to process basic contact information submitted through the website enquiry form in order to respond to the person who is asking about care, availability or service information. This processing is necessary for me to operate my midwifery service and respond to potential clients. The impact on the individual is low, the information collected is minimal, and they choose what to send. The benefit to them is that they get the information they are actively seeking, and the benefit to me is the ability to respond. I do not use this information for marketing or unrelated purposes. This balance means the legitimate interests of both parties are protected.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for safeguarding or public protection reasons are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for patient app or portal functionality are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information to comply with legal requirements are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Where we get personal information from
· Directly from you
· Regulatory authorities
· Family members or carers
· Other health and care providers
· Social services
· Relevant regulatory authorities
· no other source of personal information
·
How long we keep information
I keep pregnancy and birth related clinical records for 25 years as required under UK professional record keeping standards for midwifery. This applies whether the record began as digital or paper.
Enquiry form information submitted through this website is only kept for as long as it is needed to respond to the enquiry, and then routinely deleted unless a care relationship forms.
All records are securely stored. Digital records are held on an encrypted external hard drive with password protection. Only I have access to this.
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Who we share information with
Others we share personal information with
· Other health providers (eg GPs and consultants)
· Insurance companies, brokers and other intermediaries
· Care providers
· Organisations we need to share information with for safeguarding reasons
· Emergency services
· Local authorities or councils
· Organisations we’re legally obliged to share personal information with
Duty of confidentiality
We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:
· you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
· we have a legal requirement (including court orders) to collect, share or use the data;
· on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
· If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
· If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
