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;
- GPDQ Limited,
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 and Special Category Data, from you:
- date of birth;
- contact Information such as email addresses and telephone numbers;
- demographic information such as postcode, preferences and interests;
- financial information such as credit / debit card numbers;
- physical/mental health, sex life/sexual orientation
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 make payments to us, through this Website or otherwise;
- 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, whether via an opt-in or soft-opt-in:
- soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
- for other types of 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 us and/or taking steps, at your request, to enter into such a contract.
Who we share Data with
13. 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;
- third party payment providers who process payments made over the Website – When we conduct fraud monitoring, prevention, detection, and financial compliance activities or provide such services to our Users, we will receive Personal Data from you (and your device) and about you through our Service and from our business partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. Our fraud monitoring, detection and prevention services may collect Personal Data about you and use technology to help us assess the risk associated with an attempted transaction by you with a GPDQ user.;
- 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
14. We will use technical and organisational measures to safeguard your Data, for example:
- access to your account is controlled by a password and a username 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.
15. 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: firstname.lastname@example.org.
16. 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.
18. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
19. 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 email@example.com – 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.
20. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: firstname.lastname@example.org.
21. 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.
22. 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
23. 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.
Links to other websites
Changes of business ownership and control
26. We may also disclose Data to a prospective purchaser of our business or any part of it.
27. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
29. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
30. 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 Limited to 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.
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).
31. You can find a list of Cookies that we use in the Cookies Schedule.
32. 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.
33. 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.
34. 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.
35. 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.
38. 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.
39. 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.
Bexley NHS Health Checks
GPDQ is commissioned by Bexley Local Authority to deliver a programme of Community Outreach NHS Health Checks. These health checks will be processed on the Health Diagnostics digital tool to record the health check consultation.
All health checks will only be conducted with your complete consent.
If you are currently under medical supervision for any health issue, are pregnant, taking any medication, e.g. blood thinning medication, you must check with the health advisor before undertaking a health check.
You may undergo a Point of Care blood test which is checking your cholesterol and the assessment will also include blood pressure check and your BMI measurement as well as assessing your cardiovascular risk.
All content within your personal report is provided for general information only and should not be treated as a substitute for the medical advice of your health professional. Usage of this system and associated services is not intended for or applicable to the provision of emergency care.
By having an NHS Health Check I understand that:
- My NHS Health Check results will be shared with my GP.
- My anonymous results (i.e. data that does not identify me) will be used in analysis of general health trends and for possible evaluation, publication and research purposes. I understand that I will not be identified in any publication.
Health Diagnostics Security & Privacy Statement for NHS Health Checks
Health Diagnostics are commissioned by LA AREA to supply digital tools for this programme locally. GPDQ and Bexley LA are the data controllers for this programme; Health Diagnostics are a data processor.
This is how the information you provide during your check is managed.
What does Health Diagnostics software do?
Health Diagnostics build digital systems to support health and social care organisations and professionals to identify people who are eligible for public health programmes and services. We also provide systems that are used to support health professionals to manage population health programmes and hold face to face lifestyle consultations with you for the purpose of promoting a healthier lifestyle.
Why do we need your information?
In order to provide this support, there is a requirement for Health Diagnostics to store and process certain information about you. This is information that is generated as you step through the health check pathway. It will, for example, allow the healthcare professional with whom you are working to identify the possible chances of you developing conditions such as cardiovascular disease or type 2 diabetes.
Any reports produced by Health Diagnostics or LA will not contain your personal details.
How do Health Diagnostics make sure data is secure?
Health Diagnostics meet the highest standards of data security required by the NHS and our data security policies and procedures are externally audited every year for full compliance. Our credentials in this respect are detailed in the Security and Privacy area of our website.
Any data about you that is transmitted (for example, to your client record) and stored. This is done so electronically in an encrypted form using the highest NHS standards. The strict electronic controls that Health Diagnostics impose ensure that only people working within health and social care organisations that are authorised to see your data can do so.
We store data at our secure premises in Chester, UK as well as in Microsoft’s secure Azure cloud services data centre in Cardiff, UK.
Our digital tools do not make decisions based solely on automated processing or profiling.
What personal information do we use?
The information we obtain from your organisation includes:
Your full name
Your date of birth
Your full address
Your telephone numbers, home and mobile
Your email address
Health Diagnostics only receive this information about you because LA could not carry out the service you are entitled to without it.
Who has access to my information?
Our digital services include electronic controls, conforming to the highest NHS standards, so that the only people who have access to your information are the people who must offer you the opportunity to attend a public health service and the people who will perform the service should you attend.
There may be a requirement for employees of Health Diagnostics to see data for the purpose of maintenance or if required as part of an audit. Any access to data by our employees is controlled by strict governance processes and auditing. This ensures your data remains safe.
Do you sell my data to other organisations, such as insurance companies?
Absolutely not. We support bona fide health and social care authorisations only for the purpose of your personal health care.
How can I find out what information you hold about me?
If you wish to know if and what information we hold about you, please use our subject access request process. The process can be found here