Harley Street Specialist Hospital (HSSH) is a private healthcare hospital provider. Information that identifies you is termed ‘personal data’ and your medial history is termed ‘special category data’. Your information will be processed in accordance with the Data Protection Act 2018 and only selected individuals will have access to your information. Harley Street Specialist Hospital is registered with the UK regulatory body The Information Commissioner’s Office (ICO). The ICO governs the way organisations use and store personal and sensitive information. The hospitals registration number is ZA570645.
What personal data does HSSH collect about me?
We collect personal data about you and your health, such as name and contact details (address, postcode, email, phone) when you make an enquiry plus more detailed information when you access our services (date of birth, next of kin, insurer’s details, NHS number, national identity or passport number). This is processed under the lawful basis of the contract between you and the Hospital. We collect medical information such as medical health history, diagnosis, payment details and ethnicity when you are referred, refer yourself, register, make an appointment, receive treatment, or pay for your care and when we record your care. This is processed under the condition of ‘medical purposes by a treating clinician or someone under an equivalent duty of confidentiality’.
How does HSSH use the information about you?
We use your information to process enquiries, provide our healthcare services, administer your referral, registration, booking, treatment and payment, and improve our care and services. We also use it to respond to compliments, complaints or feedback, meet external reporting requirements and with your consent for medical research.
With whom does HSSH share my personal data?
- We only share your information as outlined under the terms of this privacy notice or with your express consent, except where necessary to protect your vital interests (such as in a medical emergency) or to meet a legal obligation as required by law. We share your personal data with your referrer: A summary of your care will be sent to the clinician who referred you or if not referred by a clinician to another medical practitioner e.g. your GP. Please inform us as soon as possible if you do not wish your information to be shared in this way.
- Professional advisors e.g. independent medical and healthcare professional: When you use our services, you agree that your information may be shared for treatment / payment purposes with clinical professionals with privileges to work in a private capacity at Harley Street Specialist Hospital. These may include specialist consultants, anaesthetists, and Resident Medical Officers who become involved in your care after referral.
- NHS / healthcare providers: We will share your information, at your request, with NHS or other healthcare providers or medical practices.
- Party funding your care / insurers: We will share some of your information with the party paying for all or part of your treatment cost, such as your insurer. Any sharing will be carried out in accordance with our duties under data protection legislation.
- Services by third parties: We use third party specialist services to support our business including IT software / hardware suppliers, clinical services such as specialist pathology. Where this includes access to personal data we carry out due diligence and apply strict contractual terms, including those instructing data processors, for confidentiality and security.
- Private Healthcare Information Network (PHIN): We share a summary of each treatment record (dates, treatment, clinician) with PHIN, a UK programme to improve patient information on quality outcomes of private healthcare. All personal data is removed. Data is not shared or analysed for any other purpose and patient identity is not shared so NHS Trusts have no detail of private care. High standards of confidentiality respect data protection laws and the duty of confidentiality, with information published in anonymised statistical form that does not identify individuals. For further detail see the PHIN Privacy Notice.
- Research: HSSH supports National Ethics committee approved clinical research to improve the effectiveness of medical care and further medical knowledge. If given the option to take part in a research project, you will be asked for your written consent and given a patient information sheet on how your information will be used or shared with researchers, organisations and regulatory agencies. All information collected for the purpose of clinical research is kept strictly confidential and only used in anonymised form.
- Clinical audit: HSSH is required to conduct audits of health records for quality assurance purposes. Your personal and medical information will be treated in accordance with guidance issued by regulatory bodies including the Care Quality Commission. We limit risk by restricting data to staff bound by a duty of confidentiality, using anonymised or pseudonymised data wherever possible (each patient is assigned a unique reference number “patient 1” etc. so data cannot be matched to them), only use for the stated purpose of clinical audit, and limit data to that needed to answer the audit objectives, reports and presentations do not identify clinicians by name unless agreed and completed audit forms are destroyed or de-identified / held for a limited term.
What rights do I have?
You have the right to request a copy of the information we hold about you by writing to Governance, Harley Street Specialist Hospital, 18-22 Queen Anne Street, London, W1G 8HU. We take steps to keep your personal information accurate and up to date, however please let us know if any details are incorrect or you would like us to remove information you think is inaccurate.
You can read more about your rights on the Information Commissioner’s Office website: https://ico.org.uk/your-data-matters/
How does HSSH keep my personal data safe?
We take protecting your personal data very seriously. We put in place appropriate organisational and technical measures to protect your information including encryption and using contracts and data sharing agreements with third parties. To reduce risk we keep any information we collect about you to the minimum needed for the purpose, we share it only on a need-to-know basis, keep it accurate and up to date, use it only for specific purposes for which it was collected and apply retention periods to keep records only as a long as is necessary.
Who can I speak to if I have any questions about anything in this notice?
If you have any questions about this policy, our use of your data, your rights of access, or wish to raise a data concern, please write to:
Harley Street Specialist Hospital
18-22 Queen Anne Street,
London, W1G 8HU.
Or email our Caldicott Guardian on: Caldicott@hssh.health
You also have a right of complaint to the Information Commissioner’s Office as the regulatory authority.