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Privacy Policy

Disclaimer

The information contained on this website is general information only and is not intended to be or to replace professional advice. Upper Limb Ltd accepts no responsibility for loss that may arise from accessing or reliance on information contained on this website. Parts of the website link to external internet sites; and other external internet sites may link to this website. Upper Limb Ltd is not responsible for the content of any external internet sites.

Copyright

The information contained on this website is unless otherwise stated, the copyright of Upper Limb Ltd. Users are permitted to read and make copies of the information for their own personal use. Users may also provide copies to others for information purposes provided that they do so free of charge, that the content of the published material remains intact, that the user’s communication of the content must not be misleading or inaccurate and that the user must draw to the attention of recipients the warning in this notice. No other use of the materials published on this website is permitted without the express prior written consent of Upper Limb Ltd.

Privacy Notice

At Upper Limb Ltd we are committed to respecting and protecting your privacy at all times and take seriously our responsibilities under data protection legislation. This privacy notice outlines how we collect and use your personal information, how we keep it secure and your legal rights.

 

Who are we?

Upper Limb Ltd is a private limited company, providing orthopaedic healthcare services, which includes outpatient consulting and treatments, surgical services and diagnostic imaging services. We also provide practice management services (appointments, medical records management, clinical outcomes collection, secretarial services and billing). Clinicians make decisions about information they require about you, and may maintain their own set of medical records in relation to the treatment that they provide. They are a Data Controller in respect of the personal information that they hold within those records, meaning that they must comply with the data protection legislation and relevant guidance when handling your personal information. To the extent relevant to their practice, you can expect clinicians (including their medical secretaries) to handle your information in line with this Privacy Notice. This includes using your personal information as set out in more detail below.

 

Our registered office is:

Upper Limb Ltd

4a Church Street,
Market Harborough
Leicestershire LE16 7AA


Company Number: 07202502

 

What types of data do we collect and use? 

In order for Upper Limb Ltd and your clinician to provide your care and treatment we will collect certain types of personal and sensitive data about you.
The personal data we collect includes

  • Personal details including your full name, title, date of birth and gender
  • Your address and contact details, including email address and telephone numbers
  • Emergency contact details and/or next of kin
  • Your National Health Number
  • Details about other clinicians involved in your care or referral, e.g. your GP or physiotherapist
  • Financial information including your credit card or other bank details if you are responsible for the payment of all or part of the bills relating to your care
  • Your medical insurance details or information regarding other organisations responsible for funding your care

We also collect and hold data that is known as a special category of personal data which includes:

  • Details of your current and previous physical and mental health. This may include treatment you have received elsewhere and by other clinicians
  • Medical records including past treatments, results of investigations, tests and scans
  • Imaging such as X-rays, ultrasound and MRI scans and their reports, photographs and videos
  • Your religion, nationality, race and/or ethnicity
  • Sexual orientation
  • Genetic or biometric data relating to you

 

Where does this information come from?

The information, which is part of your medical record may be provided by either yourself, your GP, your referring clinician as well as by your consultant and any other health professionals involved in your care. Further information may also be provided by your insurer or others funding your treatment.

We also collect information directly from you when you visit our website and patient portals, including from Amplitude pro one clinical outcome system.

What legal basis does Upper Limb Ltd have for storing and using my personal data?

  • Under the General Data Protection Regulations Article 6 (1) and Article 9 (2) we have the right to process your data in the following ways
  • To support the provision of high quality treatment and clinical care appropriate to your needs
  • To communicate with you regarding your clinical care with us and to resolve any queries, concerns or complaints you may have
  • To communicate with other health professionals and referring clinicians regarding your care
  • To undertake clinical audit and statistical analysis to monitor the standard of care provided and improve clinical performance
  • In order to obtain payment for your treatment
  • To comply with legal obligations

 

How will Upper Limb Ltd use my personal data?

  • The personal data will be used for the following purposes
  • To ensure you are receiving appropriate clinical care for your needs.
  • Arranging appointments, investigations, scans, procedures and surgeries
  • To respond to your queries, complaints and concerns
  • Quality assurance through the evaluation of your treatment and outcomes
  • Processing of invoices and payment of fees in connection with your account with us and / or your consultant
  • Disclosure of details of your treatment with us to your referring physician or clinician or to another clinician for further treatment when required.  If you would prefer us not to share this information please notify us.

We will never market our services or pass on your information to a third party without your consent except in the circumstances in a section below.

 

Do I have to provide my personal information?

You are not obliged to share any information with us but limiting the information you do disclose may mean we are unable to offer a full range of services and therefore it may affect the service we can offer.

We will seek explicit consent to collect and process your data where is it required under data protection law.  You may withdraw your consent at any time by contacting the Upper Limb Ltd Data Protection Officer

 

Will my personal data that Upper Limb Ltd holds be shared with others?

Under certain circumstances your data will be shared with others but we will only share such information as is appropriate and in the following situations

  1. Sharing information with those involved in your health care. This would include:
    1. Consultants, anaesthetists, radiologists and other health professionals, such as physiotherapists
    2. External companies that provide Upper Limb Ltd with services as part of your care pathway, such as blood tests, radiological imaging, archiving and reporting.
    3. Specialist companies that provide bespoke medical devices such as prostheses and these may be based outside of the European Union
    4. Another hospital provider that provides Upper Limb Ltd with services as part of your care pathway, such as pharmacy services
    5. Your GP and / or other referring clinician(s)
    6. Other members of staff such as administrators, receptionists and medical secretaries
    7. If we feel you are vulnerable or “at risk” we have an obligation to share information about you with the local Safeguarding Team, the specialist members of which come from the local authority, NHS organisations and the police
    8. Anyone you have asked us to communicate with or whose details you have provided as an emergency contact.
  2. Sharing Information with those involved in the administration of your care such as
    1. Your private medical insurer or other organisation paying for your care
    2. Debt collection agencies if your bill is not paid in accordance with our credit terms. The information shared would only include contact details and copy invoices. We would not share your medical record.
  3. Sharing information with 3rd parties not involved in your care. We share personal information with external organisations as required to ensure business functions are able to operate and to ensure the security and integrity of these functions.  In each case only information relevant to them is shared. The 3rd parties can include
    1. Software providers of clinical and non clinical systems
    2. Document scanning and storage facilities
    3. Legal and professional advisors, including auditors
    4. Additionally, pseudonymised, anonymised and aggregated data may be shared as part of our quality assurance process. Sharing information with regulatory bodies or due to a legal obligation
  4. We may disclose personal information where we have a statutory or legal obligation to do so, such as in the following situations
    1. With our regulators, such as the Care Quality Commission who inspect healthcare providers in England, the Medicines and Healthcare products Regulatory Authority and with professional regulatory bodies such as the General Medical Council.
    2. When instructed by court order or by the police and other crime agencies for the detection and prevention of crime
    3. Limited information is shared with the Private Healthcare Information Network (PHIN) which publishes information on the quality and cost of privately funded healthcare. It is a mandatory requirement for us to provide information to PHIN and we will comply with all data processing laws when doing so.
  5. Sharing of personal data for research and marketing
    1. We will never use your personal data for marketing purposes without your consent and we will never sell your personal data to a third party.
    2. Upper Limb Ltd is committed to furthering research and education in orthopaedics and musculoskeletal conditions and treatments. We may therefore use your personal data for clinical research and education but we will seek your explicit consent to do in line with research ethics requirements and data protection laws.
  6. Sharing data with your consent. With your consent we may disclose your personal information to other parties including
    1. at your request, for example to a company handling a claim on your behalf
    2. to National Registries who monitor the outcome of treatment provided

 

For how long will you keep my data?

We will only keep your personal data for as long as is necessary to comply with the purposes outlined in this privacy notice and to comply with legal and regulatory requirements. The retention periods are in line with the Information Governance Alliance Records Management Code of Practice for Health and Social Care 2016.

 

Is my data secure?

BMI and Ramsay Hospitals, Clanwilliam Health and Amplitude Clinical are all I.T. service provider for Upper Limb Ltd. All these companies have implemented their own technical controls to ensure that the confidentiality, the integrity and the availability of the data that is being processed are preserved at all times.

Backups are performed on a daily basis in order to keep it readily available in the event of a natural disaster or a technical issue. This measure is also critical for proper business continuity and to ensure an exemplary level of customer service.

Encryption controls have been implemented for data that is in transit. This ensures that the data being transmitted over email is kept secure and that it is only accessible by the intended recipient(s).

All machines are built to a standard following a strict process and pre-defined requirements. This ensures that the machine is secure with the appropriate user level and approved tools from the beginning of its lifecycle. In addition to that, all machines are password protected to restrict access to authorised personnel only.

 

What rights do I have as a data subject?

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you, which will be provided free of charge and within one month of receipt of your request.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete and we will respond within one month of the receipt of your request.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply you have a right to restrict the processing of information we hold about you.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that Upper Limb Ltd refuses your request under rights of access, we will provide you with a reason as to why.

If you exercise any of your rights in a situation where a third party is involved we will forward your request to them.

Should you have any queries or wish to exercise any rights set out in this notice you can contact the Upper Limb Ltd Data Protection Officer at the address below. If you make a data request you will be required to provide identification and Upper Limb Ltd will accept the following forms of identification: passport, driving licence, utility bill from the last three months or another form of photo ID.

You can complain to the Information Commissioner’s Office (ICO) if you are unhappy with the way we have dealt with a request from you to exercise any of your rights or if you think we have not complied with our legal obligations. Whilst you do not have to do so, we would appreciate you making the Data Protection Officer aware of the issue and giving us an opportunity to respond and to address it before contacting the ICO. Making a complaint will not affect any other legal rights or remedies that you have.  More information can be found on the ICO website: https://ico.org.uk https://ico.org.uk/ and the Information Commissioner’s Office can be contacted by post, phone, fax or email as follows:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Telephone: 0303 123 1113 (local rate) or 01625 545 7459 (national rate)
Email: casework@ico.org.uk

 

How do I complain?

In the event that you wish to make a complaint about how your personal data is being processed by Upper Limb Ltd please contact the Data Protection officer at Upper Limb Ltd. You also have the right to complain directly to the Information Commissioner’s Office.

The details for each of these contacts are:

Information Commissioner’s Office   
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Telephone: 0303 123 1113 (local rate) or 01625 545 7459 (national rate)

Email:  Casework@ico.org.uk

 

Data Protection Officer
Upper Limb Ltd
4a Church Street
Market Harborough
Leicestershire LE16 7AA
United KingdomCompany Number: 07202502

Email: enquiries@upperlimb.co.uk

 

Changes to our Privacy Policy

Any changes to our privacy policy in the future will be posted to the website and, where appropriate, sent to you by e-mail notification.

 

Additional information relating to our Website

We will also collect and use some personal data when you visit our website or use our other digital services, such as our patient portal.

 

What information do you collect and how is this used?

In addition to the information already mentioned we collect the following information through the website

  • Visits to our website
  • Information provided in our enquiry and feedback forms
  • Survey information
  • Enquiries or calls made via the website about our services

We use this in the following ways

  • To analyse the website to provide the optimal user experience for example ensuring that web pages are easy to read and information is well presented
  • To notify you about changes to products and services
  • To provide you with information about our products and services where you have consented to be contacted, for example where you have subscribed to receive information regarding our events

 

How secure is my data?

Any personal information held by Upper Limb Ltd is held on secure servers and encrypted. However, the transmission of information via the internet is not completely secure. During transmission of data, whether by forms or email, we cannot guarantee the security of your data and doing so is at your own risk.

 

Cookies

Like most other websites, the Upper Limb Ltd website may deploy cookies, which are small files stored on your hard drive to monitor your use of our website. Cookies remember your settings during and between visits to our site and also improve the speed and security of the website.

 

How do we use cookies?

Cookies are small data files that can identify you when you visit a website. Cookies remember your settings during and between visits to our site and also improve the speed and security of the website.

We use cookies on our website to improve the visitor’s experience, ensuring our website is responsive, fast and shows the information that you need. It enables us to improve the website and our marketing.

We do not use cookies to collect any personally identifiable information about you, and do not pass personally identifiable data to third parties. You can disable cookies in your browser settings. If your browser settings are set to accept cookies we take this as agreement.

If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.

Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of the Website.

To find out more about cookies please visit: www.allaboutcookies.org or see www.youronlinechoices.eu which contains further information about behavioural advertising and online privacy.

 

Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have asked for, such as remembering your login details or shopping basket items, cannot be provided.

 

Performance Cookies

These cookies collect anonymous information on how people use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.

 

Functionality Cookies

These cookies remember choices you make such as the country you visit our Website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

 

Social Media Cookies

These cookies allow you to share what you’ve been doing on the Website on social media such as Instagram and Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.

 

Which cookies do you use? 

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These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

 
Do you share my data?

When you complete an online enquiry form, this information is shared only with Upper Limb Ltd. We do not share your information with any third parties, unless you have given us permission to do so.

When you send an email or complete a referral form, Upper Limb Ltd will not share your email address with anyone outside the clinic, with the exception of those directly involved with providing the services about which you are enquiring. If you sign up for one of our emailing lists, and opt in to receive communication from us, we will only send you information in the format you have requested.

 

Are all downloads checked for viruses?

Although every reasonable effort is made to ensure that files are free of defects and viruses, no warranty or guarantee is given by Upper Limb Ltd regarding files downloaded or accessed.

If you have any comments, queries or feedback about this privacy notice please email enquiries@upperlimb.co.uk


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