About the Service
GPDQ has been engaged by The London Borough of Barnet (LBB) to conduct community health screenings. The service is part of LBB’s aim to not only increase the number of individuals who see a GP or healthcare professional following a decline during the pandemic, but also increase healthcare equality across the borough.
Definitions and interpretation
Data – collectively all information that you submit to GPDQ Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Cookies – a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
Data Protection Laws – any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;
GDPR – the UK General Data Protection Regulation;
we or us – GPDQ Limited, a company incorporated in England and Wales with registered number 09635612 whose registered office is at 727-729 High Road, London, N12 0BP;
UK and EU Cookie Law – the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018;
User or you – any third party that accesses the Website and is not either (i) employed by GPDQ Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to GPDQ Limited and accessing the Website in connection with the provision of such services; and
Website – the website that you are currently using, https://www.gpdq.co.uk/, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
- the singular includes the plural and vice versa.
- a reference to a person includes firms, companies, government entities, trusts and partnerships;
- “including” is understood to mean “including without limitation”;
- reference to any statutory provision includes any modification or amendment of it;
4. For purposes of the applicable Data Protection Laws, GPDQ Limited is the “data controller”. This means that GPDQ Limited determines the purposes for which, and the manner in which, your Data is processed.
5. We may collect the following Data, which includes personal Data, from you:
- date of birth;
- contact information such as address, postcode, email addresses and telephone numbers;
- demographic information such as ethnicity, preferences and interests;
- health or medical information
How we collect Data
6. We collect Data in the following ways:
- data is given to us by you; and
- data is collected automatically.
Data that is given to us by you
7. GPDQ Limited will collect your Data in a number of ways, for example:
- when you contact us through the Website, by telephone, post, e-mail or through any other means;
- when you register with us and set up an account to receive our products/services;
- when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
- when you enter a competition or promotion through a social media channel;
- when you elect to receive marketing communications from us;
- when you use our services;
Data that is collected automatically
8. To the extent that you access the Website, we will collect your Data automatically, for example:
- we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
- we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.
Our use of Data
9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
- internal record keeping;
- improvement of our products / services;
- transmission by email of marketing materials that may be of interest to you;
- contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
11. For the delivery of direct marketing to you via e-mail, we’ll need your consent via an opt-in:
- For e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
- if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
12. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and GPDQ and/or taking steps, at your request, to enter into such a contract. GPDQ has a contract with the London Borough of Barnet (LBB) to conduct these community health screening. The legal basis for collecting special category data, such as ethnicity and health data is the provision of health and social care.
Who we share Data with
13. We will share your Data with the following groups of people for the following reasons:
- The London Borough of Barnet (LBB). We will share anonymised and pseudonymised data with LBB for monitoring and analysis of the service.
- Your GP. We will share the medical details recorded during the service with your GP if you explicitly agree that we can do this.
14. We may share your Data with the following groups of people for the following reasons:
- our employees, agents and/or professional advisors – GPDQ policy places a strong emphasis on the need to share information across organisational and professional boundaries, in order to ensure effective coordination and integration of healthcare services. The Caldicott Review ‘To share or not to share’ specified that “The duty to share information can be as important as the duty to protect patient confidentiality”. Health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles;
- relevant authorities – The UK GDPR does not prevent us sharing personal data with enforcement authorities (known under data protection law as “competent authorities”) who are discharging their statutory enforcement functions. The UK GDPR and the DPA 2018 allow for this type of data sharing where it is necessary and proportionate.;
Keeping Data secure
15. We will use technical and organisational measures to safeguard your Data, for example:
- access to your account is controlled by a password and a user name that is unique to you.
- we store your Data on secure servers.
- payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.
16. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: email@example.com.
17. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
19. For health assessments, the booking form and health assessment details will be retained by GPDQ for a period of 30 years.
20. If we delete your Data, it may persist on backup or archival media for legal or regulatory purposes.
21. You have the following rights in relation to your Data:
- Right to access– the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
- Right to correct– the right to have your Data rectified if it is inaccurate or incomplete.
- Right to erase– the right to request that we delete or remove your Data from our systems.
- Right to restrict our use of your Data– the right to “block” us from using your Data or limit the way in which we can use it.
- Right to data portability– the right to request that we move, copy or transfer your Data.
- Right to object– the right to object to our use of your Data including where we use it for our legitimate interests.
22. To make enquiries or exercise any of your rights set out above, please contact us via this e-mail address: firstname.lastname@example.org.
23. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
24. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
National data opt-out
25. A national data opt-out was introduced on 25 May 2018, enabling patients to opt out from the use of their data for research or planning purposes, in line with the recommendations of the National Data Guardian in her review of data security, consent and opt-outs. GPDQ is compliant with the national data opt-out; GPDQ does not share confidential patient information for research or planning purposes. More information about this can be found here: https://www.nhs.uk/your-nhs-data-matters/”
Links to other websites
Changes of business ownership and control
28. We may also disclose Data to a prospective purchaser of our business or any part of it.
29. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
31. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
32. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling GPDQ Limitedto provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
33. This Website may place the following Cookies:
- Strictly necessary cookies – These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies – These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
34. You can find a list of Cookies that we use in the Cookies Schedule.
35. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser.
36. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
37. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
38. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
41. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
42. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
You may contact GPDQ Limited by email at email@example.com