Welcome to the Matrix Health Services UK Limited’s (“Matrix”) Privacy Notice.
Matrix respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
You can view the policy on our website http://matrixhealthservices.co.uk/. Please also use the Glossary at the end to understand the meaning of some of the terms used in this Privacy Notice.
1. Important Information and Who We Are
Purpose of This Privacy Notice
This Privacy Notice aims to give you information on how Matrix collects and processes your personal data.
It is important that you read this Privacy Notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.
Matrix Health Services UK Limited is the controller and responsible for your personal data (collectively referred to as “Matrix”, “we”, “us” or “our” in this Privacy Notice). Matrix is registered with company number 05260595) whose registered office is at Evolve Business Centre Cygnet Way, Rainton Bridge South Business Park, Houghton Le Spring, Tyne And Wear, DH4 5QY.
We are governed by:
- Department of Health
- Care Quality Commission
- NHS England
We have achieved the Information Governance Statement of Compliance which gives us access to e-referral systems, NHS email accounts and the use of an N3 connection ensuring secure transfer of information. This compliance has to be completed and approved each year to ensure continued use of these systems.
We also follow the guidelines set out in the NHS Care Record Guarantee and NHS Code of Practice for Confidentiality
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Name: Rachael Chapman
Email address: firstname.lastname@example.org
Postal address: Matrix Health Services, e.Volve Business Centre, Cygnet Way, Rainton Bridge South Business Park, Houghton Le Spring, DH4 5QY
Telephone number: 0191 3055230
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO, so we request that you please contact us in the first instance.
Inform Us of Changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third Party Links
Our website http://matrixhealthservices.co.uk/ may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which include:
- first name, maiden name, last name, date of birth, gender, next of kin.
- Details of your appointments, clinic visits etc.
- Contact details including your address, email address and telephone numbers.
- Special Categories of Personal Data which includes details about your sexuality, race, religion or beliefs, disabilities, health and clinical notes and results.
Children and Vulnerable People
We may hold personal information relating to children in relation to work carried out on behalf of CCGs and Hospital Trusts.
If You Fail To Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
3. How is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by corresponding with us by post, phone, email or otherwise.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Directly from healthcare professionals;
- Referrals through the NHS National Network (N3);
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to.
Purposes For Which We Will Use Your Personal Data
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely upon to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending upon the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying upon to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Lawful basis for processing and special category condition for processing|
|To help inform decisions we make about your care
To ensure that your treatment is safe and effective
To work effectively with other organisations who may be involved in your care
(a) Processing is necessary for a contract we have with you, or you have asked us to take specific steps before entering into a contract
(b) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
(c) For emergency or life threatening situations, the processing will be necessary to protect your vital interests
(d) Compliance with a legal obligation
(e) Explicit consent (if applicable)
Special Category Condition
(a) Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment
(b) Explicit Consent (if applicable)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how the public use our products/services)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External Third Parties:
- NHS Digital in order to comply with our legal obligations.
- Hospital Trusts and other healthcare organisations – use of their data management systems.
- GP’s or other healthcare professionals.
- Care Quality Commission and other Health and Social Care organisations and regulatory bodies.
- Service providers and agents who process data on our behalf e.g. IT managed services, internet service and platform providers, payment processing providers and those organisations we engage to help us send communications to you.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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 third party 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.
6. International Transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7. Data Security
We have put in place appropriate 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.
8. Data Retention
How Long Will You Use My Personal Data For?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Patient records are kept for the length of time that is required by the Government in its code of practice.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us
In some circumstances you can ask us to delete your data: see Request Erasure below for further information.
9. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please view the Glossary at clause 10 below for further details.
If you wish to exercise any of the rights set out above, please contact us.
No Fee Usually Required
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.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). 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.
Time Limit Within Which To Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact upon you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact upon you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply With a Legal or Regulatory Obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
Request Access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request Correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request Erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object To Processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request Restriction of Processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the Transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw Consent at Any Time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
This version was last updated on 16th July 2018.