Service Privacy Notice
This privacy notice provides you with details of how we collect and process your sensitive and personal data for our service.
Altum Health is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full details are:
Full name of legal entity: Altum Health
Email address: firstname.lastname@example.org
Postal address: Altum Health, 16 Upper Woburn Place, London, WC1H 0AF
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com.
2. How we use your sensitive and personal data
We are committed to protecting your personal data.
The data we collect is submitted by you on the New Client Form when contracting our services, and when completing questionnaires in session or via a secure platform (e.g. WriteUpp, Qualtrics). The sensitive data we collect includes ethnicity, address, gender, date of birth, contact details, email address, next of kin, education, employment, health data.
We will use your sensitive personal data (that is the data you complete in the forms) for the purposes of providing our services to you or if we need to comply with a legal obligation. We will only use your sensitive and or personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at firstname.lastname@example.org. Only with your explicit consent as our lawful basis, (Article 9(2)(a) and Article 6(1)(a) Data Protection Act 2018 ) we may process your anonymised sensitive and personal data for the purpose of research, service development and publication. Your consent will be explicitly sought and unambiguous.
We will use your non-sensitive personal data to (i) register you as a new client, (ii) manage payment, (iii) collect and recover monies owed to us (iv) to manage our relationship with you, (v) send you details of our goods and services.
Our legal grounds for processing your data are in relation to points (i) to (iv) above are for performance of a contract with you and in relation to (v) above, necessary for our legitimate interests to develop our products/services and grow our business.
We will not share your details with third parties for marketing purposes except with your express consent.
3. Disclosure of your sensitive and personal data
We may have to share your sensitive and/or personal data with (i) service providers who provide IT and system administration support, (ii) professional advisors including lawyers, bankers, auditors and insurers (iii) HMRC and other regulatory authorities (iv) third parties to whom we sell, transfer or merge parts of our business or our assets, (v) to other professionals for the purposes of discussing your treatment and/or (vi) with external organisations for research purposes.
We require all of these third parties to whom we transfer your data to respect the security of your sensitive and/or personal data and to treat it in accordance with the law. They are only allowed to process your sensitive and/or personal data on our instructions.
4. International Transfers
Some of our third-party providers are businesses outside of the EEA in countries which do not always offer the same levels of protection for your personal data. We do our best to ensure a similar degree of security by ensuring that contracts, code of conduct or certification are in place which give your personal data the same protection it has within Europe. If we are not able to do so, we will request your explicit consent to the transfer, and you can withdraw this consent at any time.
5. Data Security
Protecting your data is important to us and we have put in place security measures to prevent your sensitive and personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your sensitive and/or personal data to those employees, agents, contractors and other third parties who have a business need to know such data. 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 breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.
In certain circumstances, you can ask us to delete your data. See the section entitled ‘Your rights’ below for more information.
We may anonymise your sensitive and/or personal data (so that you can no longer be identified from such data) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
6. Data Retention
We will only keep your sensitive and personal data for as long as is necessary to fulfil the purposes for which we collected it. We may retain your data to satisfy any legal, accounting, research or reporting requirements. For example, we need to keep certain information about you for 6 years after you cease to be a client for tax purposes, and 10 years after you cease to be a client for research purposes.
You have the right to ask us to delete the personal data we hold about you in certain circumstances. See section 7 below.
7. Your Rights
You are able to exercise certain rights in relation to your personal data that we process. These are set out in more detail at http://bit.ly/2VAIqEP
In relation to a Subject Access Right request, you may request that we inform you of the data we hold about you and how we process it. We will not charge a fee for responding to this request unless your request is clearly unfounded, repetitive or excessive in which case we may charge a reasonable fee or decline to respond.
We will, in most cases, reply within one month of the date of the request unless your request is complex or you have made a large number of requests in which case we will notify you of any delay and will in any event reply within 3 months.
You may withdraw your consent for your sensitive and personal data to be used for research, service development and publication purposes by the point of anonymisation, following which it will not be possible to identify your data for withdrawal.
If you wish to make a Subject Access Request, please send the request to email email@example.com marked for the attention of the Data Compliance Officer.
8. Keeping your data up to date
We have a duty to keep your sensitive and personal data up to date and accurate so from time to time we will
contact you to ask you to confirm that your personal data is still accurate and up to date.
If there are any changes to your sensitive and personal data (such as a change of address) please let us know as soon as possible by writing to or emailing the addresses set out in section 7 above.
We are committed to protecting your sensitive and personal data, but if for some reason you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We should be grateful if you would contact us first, if you do have a complaint, so that we can try to resolve it for you.
We may change this Privacy Notice from time to time and shall notify you of any changes.