HumanMind Health Privacy Policy

Privacy Notice

This privacy notice tells you what to expect us to do with your personal information.

Contact details
What information we collect, use, and why
Lawful bases and data protection rights
Where we get personal information from
How long we keep information
Who we share information with
How to complain

Contact details

What information we collect, use, and why

We collect or use the following information to provide patient care, services, pharmaceutical products and other goods:

Name, address and contact details
Gender
Pronoun preferences
Date of birth
NHS/HSC/CHI number
Next of Kin details including any support networks
Emergency contact details
Health information (including medical conditions, allergies, medical requirements and Medical history)
Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
Payment details (including card or bank information for transfers and direct debits)
Insurance policy details
Records of meetings and decisions
Call recordings

We also collect the following information to provide patient care, services, pharmaceutical products and other goods:

Racial or ethnic origin
Religious or philosophical beliefs
Health information
Sex life information
Sexual orientation information

We collect or use the following information for safeguarding or public protection reasons:

Name, address and contact details
Emergency contact details
Health information (including medical conditions, allergies, medical requirements and medical history)
Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions)
Relevant information from previous investigations
Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
Records of meetings and decisions

We also collect the following information for safeguarding or public protection reasons:

Racial or ethnic origin
Religious or philosophical beliefs
Health information
Sex life information
Sexual orientation information

We collect or use the following personal information for patient app or portal functionality:

Names and contact details
Addresses
Medical history
Payment details
Account information, including registration details
Information used for security purposes
Marketing preferences

We collect or use the following personal information to comply with legal requirements:

Name
Contact information
Identification documents
Health and safety information
Financial information
Insurance details
Safeguarding information
Criminal offence data

We also collect the following information to comply with legal requirements:

Racial or ethnic origin
Health information
Sexual orientation information

We collect or use the following personal information for dealing with queries, complaints or claims:

Names and contact details
Address
Payment details
Account information
Purchase or service history
Call recordings
Witness statements and contact details
Relevant information from previous investigations
Customer or client accounts and records
Financial transaction information
Information relating to health and safety (including incident investigation details and reports and accident book records)
Correspondence

We also collect the following information for dealing with queries, complaints or claims:

Racial or ethnic origin
Religious or philosophical beliefs
Health information
Sex life information
Sexual orientation information

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website. Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

Your right of access You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
Your right to : rectification You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here. Your right to : erasure You have the right to ask us to delete your personal information. You can read more about this right here.
Your right to : restriction of processing You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
Your right to : object to processing You have the right to object to the processing of your personal data. You can read more about this right here.
Your right to : data portability You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
Your right to : withdraw consent When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

Consent we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interest: We collect only the information necessary to provide good care to the patient and inform clinical decision making. Our patients come to us for private mental health support and this requires sharing of personal health and demographic information

Our lawful bases for collecting or using personal information for safeguarding or public protection reasons are:

Contract we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
1. Where someone is considered a safeguarding risk, their information will be used to assess the risk to themself or others and to decide upon the appropriate action to take to mitigate the risk. This information may also help to identify when someone needs to be safeguarded.
Vital interests collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Public task we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

Lawful bases for collecting or using personal information for patient app or portal functionality are:

Consent we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legitimate interests we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
1. The patient portal functionality allows the patient to view and manage their care and information such as letters, notes and medications relating to their care. They are better informed and ableto give informed consent with this functionality and participate more meaningfully in their care.This is often considered a very positive part of our service by patients.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

Consent we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Vital interests collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability. Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
Consent we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- We have a duty to process and respond to complaints in a timely and professional manner. Good complaint handling demonstrates transparency and a desire to learn from mistakes and improve the service we provide. Complaints also give the opportunity to correct mistakes and apologise to the client where things haven't gone to plan. This can help clients feel happier if a positive resolution has been reached.
Public task we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

Where we get personal information from

Directly from you
Third parties:
- Referrers such as GPs or a booking broker such as TopDoctors will provide high level demographics and sometimes relevant clinical information in a referral but this will always be with the consent of the patient.

How long we keep information

We keep personal information from eight years after the time they are no longer needed for providing care.

Who we share information with

We have a joint controller relationship with Top Doctors. We process your personal information with that joint controller for the following reason: The are a website that advertises and provides reviews of private doctors and then takes bookings on their behalf and in this way they collect some demographic information for the patient and pass it to our organisation.

Others we share personal information with

Other health providers (eg GPs and consultants)
Insurance companies, brokers and other intermediaries
Care providers
Organisations we need to share information with for safeguarding reasons
Emergency services
Legal bodies or authorities
Relevant regulatory authorities
External auditors or inspectors
Organisations we’re legally obliged to share personal information with
Professional consultants

Duty of confidentiality

We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:

you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
we have a legal requirement (including court orders) to collect, share or use the data;
on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
If in England or Wales the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
If in Scotland we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.