Last Updated: May 9, 2025
This privacy notice tells you what to expect us to do with your personal information.
Contact details
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
- Date of birth
- Next of Kin details including any support networks
- Emergency contact details
- Photographs
- Payment details (including card or bank information for transfers and direct debits)
- Insurance policy details
We collect or use the following personal information for patient app or portal functionality:
- Names and contact details
- Payment details
- Account information, including registration details
- Information used for security purposes
- Marketing preferences
We collect or use the following personal information to comply with legal requirements:
- Name
- Contact information
- Identification documents
We collect or use the following personal information for information updates, marketing or market research purposes:
- Names and contact details
- Address
- Marketing preferences
- Website and app user journey information
- IP addresses
Personal information used for administration of the research:
- Personal information used for the purpose of research
- Records of consent, where appropriate
We collect or use the following personal information for medical research or archiving purposes:
- Names and contact details
- Address
- Recorded images such as photographs, X-rays or scan images
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Payment details
- Account information
- Purchase or service history
- Relevant information from previous investigations
- Customer or client accounts and records
- Financial transaction information
- Correspondence
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 in brief set out 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. You can read more about this right here.
- Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
- Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
- Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
- Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
- 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. You can read more about this right here.
- Your right to withdraw consent - When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
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.
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.
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.
Our lawful bases for collecting or using personal information for information updates, marketing or market research purposes 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.
Our lawful bases for collecting or using personal information for medical research or archiving purposes 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.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims 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.
Where we get personal information from
How long we keep information
For information on how long we keep personal information, see our retention schedule at eternaplan.co.uk
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
