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Privacy Policy

Privacy Notice for Clients of The London Skin and Hair Clinic

This Privacy Notice sets out important details about information that London Real Skin and the aesthetic practitioners responsible for your care and treatment may collect and hold about you, how that information may be used and your legal rights.  You can contact us if you have any questions about its content.
We will review this Privacy Notice on a regular basis and we advise you to check our website for the latest version.

Who has information about me?

London Real Skin is the trading name for LONDON SKIN AND HAIR CLINIC LTD (company number 06962164). This company is registered with Companies House and the registered address is 233 High Holborn, London, England, WC1V 7DN. Other trading names used are The London Skin and Hair Clinic: Medical Dermatology Centre.
Each of these companies may, to the extent relevant, collect, retain and use information about you and we refer to these collectively as London Real Skin in this document.

External websites

We may from time to time include on our websites links to and from the websites of other organisations for the purpose of information or education.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies and notices before you submit any personal data to these websites.

Where did you get this information from and what information does London Real Skin hold about me?

We have information about you which you and others involved in your care and treatment or who have referred you to our clinic, or who are paying for your care and treatment have supplied to us.  This is likely to include your name and contact details (postal and email addresses and phone numbers), as well as emergency contact details, including your next of kin.

We may also hold more sensitive information about you, such as your current or previous physical or mental health, nationality, race and/or ethnicity and genetic or biometric data relating to you.  This may also include your photographs which are utilised to show client treatment progress and in some cases utilised for marketing purposes, whereby consent has been formally recorded. This may also include details of healthcare services provided previously by The London Skin and Hair Clinic and others such as GPs, Specialists or hospitals, laboratories and details of any medications you have been prescribed or taken.  We refer to this as ‘more sensitive information’ in this Privacy Notice.
We may collect information from you when you visit our websites or enquire about our products or services.  We may hold information about you contained in enquiry or booking forms, including through our ‘Send a Query’ or ‘Book a Consultation’ sections of our websites and through email correspondence where you may have shared information or images.  In addition we may hold information about you that you provide in surveys or in feedback or on consultation in Clinic in writing.
If you call our clinic or contact our live support via our website, these telephone calls or live chats may be recorded and retained for a limited period for training and monitoring purposes and to help improve our services.
In order for us to provide your care and treatment, we ask that you provide as much information to us as you can.  You are of course free not to disclose information to us and you should only provide such information as you feel comfortable doing so.  Please bear in mind, however, that if you are only willing to share limited information, we may not be able to provide you with the full range of care and treatment (as applicable), and that could mean being unable to see you at the clinic (since we may not be able to share your information in the way required in order to provide your care or treatment, or run our business (for example, billing) and comply with our legal obligations).

How will London Real Skin use the information it holds about me?

We use information about you in connection with your treatment and/or care. We will use this also in connection with payment of fees, including billing, invoicing and settlement of your account with us.
We may use your phone number (or email address where you have provided it to us) to contact you in advance of and after your appointment for reasons connected with your care or treatment.  Where you have provided us with your mobile number or email address, we may send you confirmations/reminders of your appointments via text message or email and we may respond to your email enquiries via email.
We may also use information about you for quality assurance, maintaining our business records, developing and improving our products and services and monitoring outcomes where we believe there is a business need to do so and our use of information about you does not cause harm to you.  This may include our workforce planning and workload management systems to help support our staff and clinicians to develop and plan the most appropriate levels of care to our clients and to ensure we have got the right levels of productivity and efficiency and good outcomes for clients.
We may also use information about you where there is a legal or regulatory obligation on us to do so (such as the prevention of fraud) or in connection with legal proceedings.
We may also use information about you where you have provided your consent to us doing so.
We do not carry out automated decision making or profiling.

Will London Real Skin share information about me with others?

Yes; we set out these reasons below and assure you that in each case, we share only such information as is appropriate.

Sharing information with those involved in your aesthetic treatment

We will share your medical information with our internal Dermatologists and Clinicians, nurses and clinical staff and specialists at London Skin and Hair Clinic, whom may be involved in your treatment plan through referral. Consultants (such as aesthetics Doctors and nurses) who are not employed by us permanently may have access to your information on site only.  We try to ensure there is a single client record for each client who is seen at our clinic and we ask consultants working at our clinic to ensure a copy of their records, including consultation records, is included in each client’s records at the clinic.
We will also share information about you with other members of staff involved in the delivery of your care (such as our clinic co-ordinators, administrators, typists and accounts team).
If we are concerned that you may be vulnerable or ‘at risk’, we may share information about you with the local Safeguarding Team, the specialist members of which come from the local authority and the police.
We may share information about you with anyone you have asked us to communicate with or whose details you have provided as an emergency contact (such as your next of kin).

Sharing information with third parties who are not involved in your health care or treatment

We may share information about you with external organisations such as our solicitors and accountants. We may also share information about you with third party suppliers, which provide us with a secure credit/debit card storage system, document scanning and storage facilities, electronic client and clinical staff administration and records systems and reporting systems.  We may also share information about you with those providing us with information technology systems, this includes an incident management and recording system as well as other clinical and non-clinical software applications (and related services) and website hosting. In each case, we would share only such information as was relevant.

Sharing your information with payments partners and debt collection agencies

If your bill is not paid on time, we may share information (such as copy invoices) with our payment partners and debt collection agencies.
Please be assured that your medical records would not be shared either with our payment partners or with debt collection agencies.

Sharing with regulators or because of a legal obligation

We may share information about you with our regulators, including the Care Quality Commission.  Other regulators with whom we may share information about you include the Medicines and Healthcare products Regulatory Agency (which ensures medicines and medical devices used in the UK work and are acceptably safe), and the Department of Health (the government department responsible for health and adult social care policy).
Sometimes, we are required to disclose information about you because we are legally required to do so.  This may be because of a court order or because a regulatory body has statutory powers to access clients’ records as part of their duties to investigate complaints, accidents or health professionals’ fitness to practise. Before any disclosure will be made, we will satisfy ourselves that any disclosure sought is required by law or can be justified in the public interest.   Information about you may also be shared with the police and other third parties where reasonably necessary for the prevention or detection of crime.  On occasion, this may include the Home Office and HMRC.

Audits, surveys and initiatives

In common with all clinics regulated by the Care Quality Commission we also look at the quality of the care we provide to clients and participate in national audits and initiatives to ensure that clients are getting the best possible outcomes from their treatment and care and to help clients make informed choices about the care they receive.  We can assure you that your personal information remains under our control at all times and we ensure any information we provide for national audits and initiatives outside of London Real Skin will not contain any information in which any client can be identified, unless it is required by law.  Any publishing of this data will be in anonymised statistical form.
Following your appointment you will be invited to complete a survey and share your views to help us improve the services we offer.  We offer the survey in an online format using the email address you provide to us. We limited the use of paper based data within our clinic and any documents you may complete are held for a short period before being scanned to our online system and the originals shredded. All client data is stored within a secure CRM system and clinic servers, regulated by GDPR regulations. No client data is removed from the clinic either in paper format or on portable electronic devices such as mobile phones, tablets, USB sticks or portable drives.

Where you have provided us with consent

During the registration process you may choose to opt in to receiving marketing information about other services London Real Skin offers by post, SMS or email.
Your consent or decision to opt in is entirely voluntary.  Should you decide not to consent or opt in or should you change your mind at any time, you do not need to give a reason and your treatment and legal rights will not be affected.  You can opt-out of marketing communications consent at any time.
Apart from these limited instances, we do not hold or share information about you based on (or at least solely on) consent.

Where and for how long does London Real Skin store information about me?

The information about you that we hold and use is held securely in the United Kingdom and stored in paper format and on our secure servers.  However, in some instances, your personal information may be processed for medical purposes or (particularly information not involving your medical information, because there is a legitimate interest or it is necessary for the performance of services to you) outside the European Union (“EU”) where the organisation paying for your care or treatment is based outside the EU or where one of our suppliers is operating outside the EU.  We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice and GDPR regulations.
We retain your records for certain periods (depending on the particular type of record) under our retention of records policy.  Legally we are bound to retain health records for the lifetime of a client and at least 10 years after death. This is to ensure that information is properly managed and is available whenever and wherever there is a justified need for that information, including to support client care and continuity of care; to support evidence-based clinical practice and to assist clinical and other audits; to support our legitimate interests, and to meet legal requirements.
If you would like more detailed information on this, please contact our Information Governance & Data Protection Officer (contact details below).

What rights do I have?

The law provides you and other clients with certain rights in relation to the information about you that we hold.  You may exercise these at any time by contacting our Information Governance & Data Protection Officer (contact details below) or as otherwise noted below and without adversely affecting your medical care.
There will not usually be a charge for handling a request to exercise your rights and if we cannot comply with your request, we will usually tell you why.  If you make a large number of requests or it is clear it is not reasonable for us to comply with a request, then we do not need to respond or we can charge for doing so.
As an aesthetic clinic we use digital photography to monitor and record to assist in diagnosis and treatment. Where clients request a copy of their photographs we will use a secure method for providing these photographs to them.

Clients who fill in consent to have their photographs taken, have the right to consent to these photographs being used for advertising purposes. Photographs of clients will not be utilised unless consent has been confirmed digitally or in writing.

Right of access

You have the right to access information held about you. This includes details of what information we hold about you and a copy of that information.  The information will be provided free of charge and, unless there are grounds for extending the statutory deadline, the information will be provided to you within one month of receipt of your request.  Please note we will generally also ask for confirmation of your identity and may need further information from you in order to locate the information, in which case the time period starts from the date we have that detail.  Please note that in some cases we may not be able to comply fully with your request, such as where your request also involves information about someone else and it would not be fair to that other person to provide the information to you.
Please contact the clinic should you wish to exercise this right.

Right to rectification

We take reasonable steps to ensure the information we hold about you is both accurate and complete.  However, you are entitled to have the information rectified if that is not the case.  Unless there are grounds for extending the statutory deadline, we will respond within one month of receipt of a rectification request.
Please contact the clinic should you wish to exercise this right.

Right to erasure (sometimes referred to as the right to be ‘forgotten’)

In some circumstances, you have a right to have information about you ‘erased’ and to prevent us using or holding information about you.  Please note that we do not have to comply with such a request where it is necessary to keep your information in order for us to perform tasks which are in the public interest (including public health) or for the purposes of establishing, making or defending legal claims.  If you make such a request and we comply with it, please be aware that we will retain a note of your name, the request made and the date we complied with it.
Please contact the clinic should you wish to exercise this right.

Right to restrict processing

In some situations, you have a right to ‘block’ or suppress our holding or using information about you.  As with the right to erasure, please note that we do not have to comply with such a request where it is necessary to keep your information in order for us to perform tasks which are in the public interest (including public health) or for the purposes of establishing, making or defending legal claims.
Please contact the clinic should you wish to exercise this right.

Right to data portability

You have the right to obtain and re-use your personal data for your own purposes across different services, allowing you to move, copy or transfer personal data from one IT environment to another.  This right, however, only applies to personal data you have provided to us, where the processing is based on your consent or for the performance of a contract; and when the processing is carried out by automated means.
Please contact the clinic should you wish to exercise this right.

Rights relating to automated decision making

You have the right not to be subject to a decision when it is based on automated processing (i.e. by a computer alone); and it produces a legal effect or a similarly significant effect on you.  As noted above, London Real Skin does not carry out automated decision-making in relation to clients.
Please contact the clinic should you wish to exercise this right.

Right to object or withdraw consent

You have the right to withdraw consent to us holding or using information about you, but only if consent is the basis for us holding or using your information.   Please click the ‘unsubscribe’ button in marketing materials or otherwise please contact the clinic on info@londonrealskin.com should you wish to exercise this right.

Right to complain to the Information Commissioner’s Office

You can complain to the Information Commissioner’s Office (ICO) if you are unhappy with the way we have dealt with a request from you to exercise any of your rights or if you think we have not complied with our legal obligations.  Whilst you do not have to do so, we would appreciate you making the Information Governance & Data Protection Officer aware of the issue and giving us an opportunity to respond and to address it before contacting the ICO.

Making a complaint will not affect any other legal rights or remedies that you have.  More information can be found on the ICO website: https://ico.org.uk/ and the Information Commissioner’s Office can be contacted by post, phone, fax or email as follows:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 7459 (if you prefer to use a national rate number)
Fax: 01625 524 510
Email: casework@ico.org.uk

Contacting London Real Skin and the Information Governance & Data Protection Officer

For further questions or to exercise any rights set out in this Privacy Notice, please contact London Real Skin’s Information Governance & Data Protection Officer:

Information Governance & Data Protection Officer
London Real Skin
233 High Holborn
London
WC1V 7DN
Email: info@londonrealskin.com

* Privacy Notice for Clients v2.0 January 2020.

 

 

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