Privacy & Cookies Policy

OVERVIEW

This policy sets out our Privacy Notice for the processing of patient medical records in accordance with General Data Protection Regulations. 

BACKGROUND 

Current data privacy legislation requires data controllers to provide data subjects with information relating to the processing of their personal data under GDPR Article 13.

OBJECTIVES 

To provide data subjects with transparency about the information we collect and how we process it, allowing them to make informed choices.

SCOPE 

The processing of patient data collected via the website, phone call enquires or referred patients via corporate employee benefit programs and health insurance providers. 

BUSINESS DETAILS OF DATA CONTROLLER 

Check4Cancer Ltd is a company registered in England and Wales under company number 8866941 and with a registered office at Lower Court 3-4, Copley Hill Business Park, Cambridge Road, Cambridge, CB22 3GN (“Check4Cancer”) and includes the following trading names, BOWELHEALTH UK, BREASTHEALTH UK, GENEHEALTH UK, GYNAEHEALTH UK, LUNGHEALTH UK, PROSTATEHEALTH UK, SKINHEALTH UK.

DATA CONTROLLER AND LEGAL BASIS 

Check4Cancer Ltd is the Data Controller in relation to data we collect and process of patients.

When enquires are via the website we require your consent in accordance with the GDPR article 6 (a). This is managed via cookie consent banners on the webpage.

When enquires are via telephone calls, referrals or otherwise and you share medical data with us we will be relying on GDPR article 9 (a) and that we have recorded your explicit consent to process the data and GDPR article h) medical diagnosis.

COLLECTING PERSONAL INFORMATION 

We may collect, store and use the following kinds of personal information: 

  • information about your computer and about your visits to and use of our websites including your IP address, search terms, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths;
  • information that you provide to us when registering with our websites including your email address & contact details;
  • information that you provide when completing your profile on our websites, phone, online chat, or email including your name, address, gender, date of birth, relationship status, health records, employment records & payment details;
  • information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters;
  • information that you provide to us when using the services on our websites, or that is generated in the course of the services we provide including appointment times, medical data, doctors contact details etc.;
  • information relating to any purchase of services or any other transactions that you enter into through our websites, online chat or directly through our contact centre including your name, address, telephone number, email address and payment card details;
  • information that you provide when responding to customer service feedback or complaints;
  • information contained in or relating to any communication that you send to us or send through our websites, email or telephone calls (call recording) including the communication content and metadata associated with the communication; and
  • payment data when purchasing services online or over the phone.
  • information related to your medical history, family history and the results of any screening and/ or diagnostic services we provide at your request.
  • we also record phone calls for the purposes of staff training, mitigation of disputes and the evidence of consent from data subjects.
  • we may also record images relating skin conditions in delivering our services.
  • we may also record your GP’s details and the details of consultants you are referred to as part of your medical records.
  • we may record details of your mental state under the Safeguarding of Vulnerable Groups Act 2006, if we feel it is in your best interest, and details of your legal guardian if applicable.
  • your employer or insurance provider if applicable for billing purposes.

Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy. If consent cannot be reasonably obtained, or there is any concern around the capacity of the individual to give consent, we may decline to process your enquiry.

USING PERSONAL INFORMATION 

Personal information submitted to us through our websites, phone calls, emails or in person will be used for the purposes specified in this policy.

We may use your personal information to: 

  • administer our websites and business;
  • personalise our websites for you;
  • enable your use of our medical screening services;
  • send you information;
  • process payments;
  • send statements, invoices and payment reminders to you, and collect payments from you;
  • send you non-marketing commercial communications;
  • send you email notifications that you have specifically requested that form part of the service;
  • send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
  • send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
  • provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
  • deal with enquiries and complaints;
  • keep our websites secure and prevent fraud; and
  • verify compliance with the terms and conditions governing the use of our websites (including monitoring private messages sent through our websites private messaging service).
  • we may contact you for the purposes of customer feedback and marketing testimonials. If you object to this processing, then please do let us know. We do not currently pass any of your details to external customer review services. If this changes in future, we will seek your consent prior to sharing your details.
  • we will not, without your expressed consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing.
  • all our websites financial transactions are handled through our payment services provider. We will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our websites, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
  • data supplied by you for the purposes of our medical services is stored in our outsourced data centres. The data is stored in the EEA and the arrangements are managed under contract and EU legislation that protect your data.
  • some processing may require degrees of automation however these results are checked and audited to ensure accuracy of the results.
  • Please be aware that clinical information, including clinical photographs (obtained by Check4Cancer) will be stored by Check4Cancer (or service providers Check4Cancer may refer the client to). Check4Cancer may also use information in an anonymized way for educational, commercial or clinical publications. We ensure data subjects are aware of these processing arrangements via the website and Privacy Policy. 

DISCLOSING PERSONAL INFORMATION

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, consultants, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy and in the delivery of our services. 

For employees of corporate clients or customers of insurance providers,Check4Cancer will only provide information that a test has been performed for the purpose of invoicing and statistical management information relating to the effectiveness of the testing. We do not share the results of medical screening without your consent unless there is lawful basis requiring us to do so.

Please note where you are referred to a clinic, hospital or consultant they may be acting as Data Controllers in their own right, as such you are advised to request copies of their Privacy Policy.

For invoicing purposes and logistic of onsite clinics, it may be necessary to provide your name as evidence that a) a test has been conducted or b) providing attendee and non-attendee reports for onsite clinics.

We also send and receive information about you with the National Disease Registration Service (NDRS) at Public Health England (PHE) for the purposes of knowledge sharing and improving services to patients. PHE will provide Check4Cancer with cancer diagnosis data restricted to those cancers that we have clinical services for, as well as cancer staging and treatment data. This data is essential to allow Check4Cancer to perform a comprehensive and effective audit of all clients and patients who use our cancer screening and diagnostic services, and the pseudonymised data may be used for internal clinical reports that may be presented or published and compared to reference datasets or publications. You can find out more about the NDRS at PHE, and how they will process your data, here: https://www.ndrs.nhs.uk/

We may disclose your personal information to any member of our group of companies. This means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes set out in this policy.

We may also disclose your personal information: 

  • to the extent that we are required to do so by law;
  • in connection with any ongoing or prospective legal proceedings;
  • in order to establish, exercise or defend our legal rights including providing information to others for the purposes of fraud prevention;
  • to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
  • to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
  • except as provided in this policy, we will not provide your personal information to third parties.

INTERNATIONAL DATA TRANSFERS 

Your data will primarily be stored in the EEA. Occasional data may be transferred outside the EEA primarily for the purposes of screening samples. Those labs may retain your data for the purpose of compliance and audit to ensure they meet with their legal, regulatory and professional obligations.   

RETAINING PERSONAL INFORMATION 

This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information. Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

Without prejudice to other obligations set out in this notice or legal obligations, we will usually delete personal data falling within the categories set out below at the date/time set out below:

  • personal & sensitive data of a medical nature will be deleted 10 years from the last communication date with the patient; or
  • when you ask us to erase marketing data compliant with GDPR Article 17.

Notwithstanding the other provisions of this notice, we will retain documents & records containing personal data:  

  • to the extent that we are required to do so by law;
  • if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
  • in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

There is no statutory period defined in legislation, so our retention period is based on recommendations from Information Governance Alliance Records Management Code of Practice for Health and Social Care 2016.

SECURITY OF PERSONAL INFORMATION 

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We will store all the personal information you provide on our secure (password- and firewall-protected) servers.  All communications via our websites, payment transactions, electronic documents and database records will be protected by encryption technology.

You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You are responsible for keeping the password you use for accessing our websites confidential; we will not ask you for your password (except during authenticating access to electronic systems).

AMENDMENTS 

We may update this policy from time to time by publishing a new version on our websites. You should check this page occasionally to ensure you are happy with any changes to this policy. 

We may notify you of any changes to this policy by email.

Please let us know if the personal information that we hold about you needs to be corrected or updated for example a change to your address or GP details.

YOUR RIGHTS 

You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to: 

  • there is no payment required; and
  • the supply of appropriate evidence of your identity for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address.
  • we may withhold personal information that you request to the extent permitted by law.
  • you may instruct us at any time not to process your personal information as permitted by law.
  • you can instruct us to erase your data, compliant to GDPR Article 17. Please note, it is highly unlikely we will comply with any erasure requests of medical screening data given our statutory obligations.
  • you have the right to lodge a complaint with the Data Protection Authority if you consider your rights have been breached in anyway.

The UK Data Protection Authority  can be contacted on the following link:

https://ico.org.uk/global/contact-us/

THIRD-PARTY WEBSITES 

Our websites include hyperlinks to, and details of, third party websites.

We have no control over, and are not responsible for, the privacy policies and practices of third parties if you register with them independently. 

COOKIES AND TRACKERS 

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Our website records your consent to cookies and trackers via a consent banner.

DATA PROTECTION REGISTRATION 

Check4Cancer Ltd are registered with the UK Information Commissioner's Office & Care Quality Commission.

Our registration detail can be found here:

https://ico.org.uk/ESDWebPages/Entry/Z1201347  

https://www.cqc.org.uk/location/1-1794403643?referer-widget4

OUR DETAILS 

Our websites and call centre are owned and operated by Check4Cancer Limited. We are registered in England and Wales under registration number 8866941, and our registered office is at 1 The Mill, Copley Hill Business Park, Cambridge Road, Cambridge, CB22 3GN.

Our principal place of business is at Lower Court 3-4, Copley Hill Business Park, Cambridge Road, Cambridge, CB22 3GN.

You can contact us:

  • by post, using the postal address given above;
  • using our website contact forms;
  • by telephone, on the contact number published on our websites; or
  • by email, using the email address published on our websites;
  • by online live chat
  • Or you can contact our Data Protection Officer directly by email at This email address is being protected from spambots. You need JavaScript enabled to view it.; please note consent is granted to email directly for genuine customer enquiries only and for no other purpose.