This Privacy Notice sets out details of the information that London Uroradiology LLP (LUR) may collect from you and how that information may be used. Please take your time to read this Privacy Notice carefully.
About Us:
In this Privacy Notice we use "we" or "us" or "our" or "LUR" to refer to London Uroradiology LLP who is processing your personal information.
London Uroradiology LLP Company No OC 398136
Registered Address: c/o Sandisson Eason & Co, Rex Buildings, Alderley Road, Wilmslow, Cheshire SK9 1HY
Mailing Address: 27 Westwood Street, London SW13 0LA
Information Commissioner Registration No: ZA323077
How to contact us
Our Contact Information (Data Controller)
Dr Miles Walkden, Managing Partner
27 Westwood Street, London SW13 0LA
Tel: 07971 781435
Email: miles@londonuroradiology.com
If you would like further information about any of the matters in this Privacy Notice or have any other questions about how we collect, store or use your personal information, please contact the Managing Partner, using the details above.
Privacy Notice:
LUR is a Data Controller under the terms of the EU Data Protection Regulation 2016 / 679 (“GDPR”) and UK Data Protection Act 2018.
The intention of this Privacy Notice is to:
• provide you with a detailed overview of how we will manage your data, from the point at which it is gathered and onwards.
• will give you all the details you need on how we use your information, and how we will comply with the law in doing so. We will never contact you with marketing materials.
• sets out your rights in respect of your personal information, and how to exercise them. You can, for instance, seek access to your medical information, object to us using your information in particular ways and request rectification of any information which is inaccurate.
We are also open to improvement; if you have any feedback on this notice contact our Data Protection Lead on miles@londonuroradiology.com.
Your Personal Data and Referring Clinicians
LUR is a chamber of Consultant Radiologists (“Radiologists”). With very few exceptions they are not the clinicians who manage the patient’s pathway with patients. Patients are referred to the Radiologists by a clinician (the “Referring Clinician”) in three different ways:
1. For a diagnostic or therapeutic exam (for example, Ultrasound), which the Radiologist will undertake “on” the patient. These exams take place at a hospital or clinic where the Radiologist is working under the clinical and information governance of the hospital or clinic.
2. For a diagnostic report where the patient will have been scanned at a hospital or imaging centre the Radiologist will report the scan, and the report will be returned to the Referring Clinician who ordered it. The patient remains under the management of the Referring Clinician, who may consult with the Radiologist on the clinical findings of the report. The Referring Clinician and Radiologist are operating under the clinical and information governance of the hospital and/ or imaging centre where the scan is performed.
3. In a limited number of instances the patient will be referred by the Referring Clinician to the Radiologist for the Radiologist to perform an interventional procedure on the patient. In these cases the patient may be under the direct management of the Radiologist. The Radiologist will perform this procedure under the clinical and information governance structure of the hospital.
In the majority of cases the patient will be under the overall management of the Referring Clinician. That Referring Clinician will have their own Privacy Policy as to how they handle and treat your personal data. You should ask them if you have any questions as to their policies and procedures. LUR is a service provider to them. They should ask you for your permission to forward data about you for the scan or procedure they are asking our Radiologist to report or perform.
Data Processors
Under the terms of the EU Data Protection Regulation 2016 / 679 (“GDPR”) and UK Data Protection Act 2018and other related legislation LUR act as Data Controller and have appointed two Data Processors to provide specialist services in the analysis and diagnosis of the scans we receive.
The Data Processors are Purview and 3D Biotronics and we have strict contractual arrangements in place with these organisations to ensure they only process data upon the specific instructions of LUR – the Data Controller.
Purview is the name of the system developed by Nimble LLC, whose principal place of business is 2001 Tidewater Colony Drive, Suite 203 Annapolis, MD, USA. Biotronics3D Limited, head office is at 5 Greenwich View Place, London E14 9NN, UK.
To provide a better service to both the Referring Clinician and patient, LUR has licensed Picture Archiving and Communication Systems (PACS), called from Purview and Biotronics3D Limited. A PACS is the system from which scans are reviewed and reported. The reason LUR has bought these licences is because our Radiologists believe it helps them provide the best analysis of a scan and thereby helps ensure the quality of their report. It is particularly useful when a patient is being monitored over a period of time where there will be multiple scans to review and compare. As individuals we have worked with Purview for approximately 10 years and Biotronics for 4 years. They have been excellent suppliers and have very stringent Privacy policies which can be viewed:
https://info.purview.net/hubfs...
http://www.biotronics3d.com/pu...
Transfers of data
In order to provide our services, we transfer your data to our data processors. Biotronics are based in the UK and Purview are based in the USA.
The data transfers sent to USA are covered by the US Privacy Shield and our contractual arrangements with Purview.
Security
We take security of your data seriously and have taken steps to ensure that the data processors involved in the provision of our services have industry standard security controls and procedures in place for the processing of sensitive medical data. Details of these controls can be obtained by contacting us directly.
What personal information do we collect and use from patients?
LUR does not in itself collect any personal data. It does receive personal patient data via the Referring Clinician’s referral form for the scan/ procedure (where they will lay out the clinical issues involved and what they are asking the Radiologist to assess), and from the scan images.
All scans have information on them which identify the patient, the date and time of the scan, and the specific sequences and images generated. Without these the Radiologist is unable to report the scan appropriately and ensure that the images relate to the right patient. This information is stored by the Data Processors .
If the Radiologist is performing an interventional procedure where they are directly responsible for the patient, they will keep all relevant clinical information as well as personal data – name, address, date of birth etc. This information will either be stored on the hospital system at which the patient is being treated or on LUR’s Practice Management system, called HeyDoc. Their security system is described at https://heydoc.co.uk/security
How will we communicate with you ?
LUR is unlikely to communicate with you directly. The Radiologist will communicate with you by the most appropriate of email or post.
What are the purposes for which your information is used ?
We may 'process' your information for a number of different purposes, which is essentially the language used by the law to mean using your data. Each time we use your data we must have a legal justification to do so. The particular justification will depend on the purpose of the proposed use of your data.
Generally we will rely on the following legal justification, or 'grounds':
• You have provided your consent to our use of your personal information.
• We have an appropriate business need (providing a radiology report, performing a procedure) to process your personal information and such business need does not cause harm to you. We will rely on this for activities such as quality assurance, maintaining our business records, developing and improving our products and services and monitoring outcomes.
• We have a legal or regulatory obligation to use such personal information.
• We need to use such personal information to establish, exercise or defend our legal rights.
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We provide further detail on these grounds in the sections below.
The right to object to other uses of your personal data
If you do not consent to your Referring Clinician sharing your personal information with us, we will not be able to provide the requested radiological service. In these circumstances we will not have information about you.
What marketing activities do we carry out ?
We will never market our services directly to you.
How long do we keep personal information for?
We keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Notice and in order to comply with our legal and regulatory obligations. We have a legal obligation to maintain your clinical data for 7 years
Your rights
Under data protection law you have certain rights in relation to the personal information that we hold about you. These include rights to know what information we hold about you and how it is used. You may exercise these rights at any time by contacting us using the details set out above at the top of the page.
There will not usually be a charge for handling a request to exercise your rights.
If we cannot comply with your request to exercise your rights we will tell you why.
There are some special rules about how these rights apply to health information as set out in legislation including the Data Protection Act (current and future), the General Data Protection Regulation as well as any secondary legislation which regulates the use of personal information.
Your Rights include the right to access your personal information
You are usually entitled to a copy of the personal information we hold about you and details about how we use it.
Your information will usually be provided to you in writing, unless otherwise requested. If you have made the request electronically (eg by email) the information will be provided to you by electronic means where possible.
Please note that in some cases we may not be able to fully comply with your request, for example if your request involves the personal data of another person and it would not be fair to that person to provide it to you.
The right to rectification
We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you do not believe this is the case, you can ask us to update or amend it.
The right to erasure (also known as the right to be forgotten)
In some circumstances, you have the right to request that we delete the personal information we hold about you. However, there are exceptions to this right and in certain circumstances we can refuse to delete the information in question.
The right to restriction of processing
In some circumstances, we must "pause" our use of your personal data if you ask us to. We do not have to comply with all requests to restrict our use of your personal information.
The right to data portability
In some circumstances, we must transfer personal information that you have provided to us to you or (if this is technically feasible another individual/ organisation of your choice). The information must be transferred in an electronic format.
The right to withdraw consent
In some cases we need your consent in order for our use of your personal information to comply with data protection legislation.
We have explained in the section entitled "What are the purposes for which your information is used?" where we rely on your consent in this way. Where we do this, you have the right to withdraw your consent to further use of your personal information. You can do this by contacting LUR’s Managing Partner whose details are at the top of the page.
The right to complain to the Information Commissioner's Office
You can complain to the Information Commissioner's Office if you are unhappy with the way that we have dealt with a request from you to exercise any of these rights, or if you think we have not complied with our legal obligations.
Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
01625 545 745
www.ico.org.uk
More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/
Making a complaint will not affect any other legal rights or remedies that you have.
This Privacy Notice is dated 25th February 2020.
