Privacy Policy
Privacy & Cookie Policy
Services & Website Privacy Policy
1. Introduction
This is The Geoghegan Group Privacy Policy.
The Geoghegan Group (“We”, “Us” and “Our”) is made up of the following subsidiary companies; The Old Rectory (Ewhurst) Co Ltd and The Clavadel (Guildford) CO Ltd, and as such this Privacy Policy applies directly to all of the above named companies.
This Privacy Policy provides you with details of how we collect and process your personal data (and in some instances, the friends and/or relatives of our Patients ) as part of the services we offer and/or through your use of this website (or any other affiliated Geoghegan Group website), including any information you may provide when you purchase a product or service, make an enquiry by phone or by filling out an electronic form.
We are committed to providing transparent information on why we need your personal data and what we do with it. This Privacy Policy will also explain your rights when it comes to your data.
“Processing” can mean collecting, recording, organising, storing, sharing or destroying data.
Contact Details
Our contact details are:
Email address: alice.c@ggroup.co.uk
Telephone: 01483 561944
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by informing us in writing.
2. What data do we collect about you
Personal data means any information capable of identifying an individual. It does not include anonymised data.
Patients
For those individuals who seek to be, are, or were our patients or through your use of our website, we may process certain types of personal data about you as follows:
Identity Data may include your first name, last name, username, title, date of birth, next of kin and gender.
Contact Data may include your billing address, email address and telephone numbers.
Financial & Transactional Data may include your bank account and details about payments between us and other details of purchases made by you.
Technical Data may include your internet protocol (IP) addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
Usage Data may include information about how you use our website, products and services.
Marketing and Communications Data may include your preferences in receiving marketing communications from us and your communication preferences.
We also record the following data which is classified as “special category”:
Health and social care data about you, which might include:
Medical Records (physical and mental health data)
Past Medical History
Medications
NHS Number
Risk Assessments
Your race and/or ethnic origin as well as any religious affiliation
Aggregated Data
We may also process Aggregated Data from your personal data, but this data does not reveal your identity and as such is not in itself personal data. An example of this is where we review your Usage Data to work out the number of patients that availed of our services in a given month. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
Why do we have this data?
We require this data so that we can provide high-quality care and support, including establishing and managing your relationship with us. By law, we need to have a lawful basis for processing your personal data.
We process your data where:
We need to assess whether we are able to assist you;
We are required to do so in our performance of a public task;
We are required to do so in order to fulfil a contract that we have with you;
It is necessary for our legitimate interests in recovering debts owed to us;
We have a legal obligation to do so – generally under the Health and Social Care Act 2012 or Mental Capacity Act 2005;
It is necessary due to social security and social protection law (safeguarding instances);
It is necessary for us to provide and manage social care services;
We are required to provide data to our regulator, the Care Quality Commission (CQC), as part of our public interest obligations;
Such other purposes as are reasonably required by us.
Friends/Relatives
What data do we have?
As part of our work providing high-quality care and support, it might be necessary that we hold the following information on you:
Your basic details and contact information e.g. your name and address;
Why do we have this data?
By law, we need to have a lawful basis for processing your personal data.
We process your data because we have a legitimate business interest in holding next of kin and lasting power of attorney information about the individuals who use our service
We may also process your data with your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent.
3. How do we collect your personal data
We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our site or by communicating with us by post, phone, email or otherwise, including:
When you Purchase or enquire about our services;
During the course of the services we provide
Third Parties: We may also receive personal data from:
Parents, relatives or carers
General Practitioners (GPs)
Other NHS trusts, hospitals, clinics or hospices
Ambulance trusts
Local authorities
Private healthcare providers
Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. Please see our cookie policy below for further details.
4. How do we use your personal data
We will only use your personal data when legally permitted. The most common uses of your personal data are:
Where we need to perform the contract between us.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Can we use your information for marketing our products and services?
We may send you email newsletters if you opt-in to receive such correspondence. We may also send you details of new services but only if it is within our legitimate interest to do so.
We will always let you know that you can opt out from receiving marketing material and you can let us know at any time if you no longer wish to receive direct marketing offers from us. You can do so by emailing us at alice.c@ggroup.co.uk.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at alice.c@ggroup.co.uk.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing. We may process your personal data without your knowledge or consent where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal information with our employees and other parties who require such information (who may in turn process your data) to assist us with managing the service we provide to you.
This includes but is not limited to sharing your data with the following:
the NHS;
your doctor;
pharmacies;
social services;
the local authority;
hospitals;
emergency services;
the District Nurse;
all clinical multi-disciplinary teams;
specific external suppliers such as systems providers (e.g. of our health and safety reporting and financial systems), IT consultants, legal advisers and auditors.
Also, your personal information may be disclosed:
as permitted or required by applicable law or regulatory requirements;
to comply with valid legal processes;
as part of our reporting activities;
to protect the rights and property of the company;
during emergency situations or where necessary to protect the safety of a person or group of persons;
where the personal information is publicly available; or
with your consent where such consent is required by law.
In any such a case, we will not disclose more personal information than is required in the circumstances and, except under compulsion of law, we will not disclose without your consent any legal advice which is the subject of a duty of confidence owed to you.
For further details of our data processors, please do not hesitate to contact your Data Protection Officer.
6. Notification & Consent
Privacy laws do not generally require us to obtain your consent for the collection, use or disclosure of personal information for the purpose of establishing and managing our relationship with you. In addition, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
Where your consent is required, this will be requested and recorded in a clear unambiguous way. Where your consent is required for our collection, use or disclosure of your personal information, you may, at any time, subject to legal or contractual restrictions and to reasonable notice, withdraw your consent. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to the Company.
7.Data security
We have put in place appropriate security measures including firewalls & encryption as well as various systems and procedures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
Your personal information will not normally be processed outside the UK. We also use data sharing agreements, data processing agreements and the standard contractual clauses to protect your data where it is being shared, processed and/or transferred to a third country.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
We will retain your personal information only for as long as we believe is necessary to fulfil the purposes for which the personal information was collected. As a minimum that will be until one year after the expiry of the legal limitation period for bringing a legal claim against the company in respect of the services provided. However, we may notify you that we will retain your personal information for a longer period for the purposes of maintaining our records of the services provided.
In most cases personal information which is maintained by us will be deleted 8 years after the discharge of all fees incurred in your care or at the end of any service we have provided to you, whichever is the later.
All health records are retained in accordance with national guidelines which vary depending on the specific records held.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Specific retention periods
We retain and securely destroy records in accordance with legal, regulatory, and professional guidance. The following retention periods apply:
• Clinical and care records: retained for 8 years from the end of care or discharge, unless a longer period is required by law or national guidance.
• Staff personnel files: retained for 6 years after employment ends, in line with employment and limitation requirements.
• Financial and operational records: retained for 6 years to comply with accounting, tax, and audit obligations.
• Controlled drug records and logs: retained for 2 years, in accordance with controlled drugs legislation.
At the end of the applicable retention period, records are securely destroyed or permanently anonymised, unless there is a lawful reason to retain them for longer (for example, ongoing legal proceedings or regulatory requirements).
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
Request access to your personal data.
Request correction of your personal data. You can also request that we restrict all processing of your data while we consider your rectification request;
Request erasure of your personal data which is no longer necessary for the purpose we originally collected it for.
Object to processing of your personal data.
You may also request that we restrict processing if we no longer require your personal data for the purpose we originally collected it for, but you do not wish for it to be erased.
Request transfer of your personal data.
Right to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at alice.c@ggroup.co.uk.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Cookies
What’s a cookie?
A “cookie” is a piece of information that is stored on your computer’s hard drive and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
Cookies are used by nearly all websites and do not harm your system.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
How do we use cookies?
We use cookies to track your use of our website. This enables us to understand how you use the site and track any patterns with regards how you are using our website. This helps us to develop and improve our website as well as products and / or services in response to what you might need or want.
Cookies are either:
Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or
Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. For example, we use persistent cookies for Google Analytics.
Cookies can also be categorised as follows:
Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
Google Analytics
Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
Third Party Applications
This site uses code droplets to share content from other websites, such as Twitter, YouTube and Google maps etc. We do this so that our site is easier for you to use, and the content from these other websites is displayed automatically on the page.
We sometimes use code droplets to measure the effectiveness of our various advertising campaigns through third party applications.
These third-party applications use cookies. By accepting our privacy policy, you agree to the use of these cookies by third parties.
Links to other sites
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control or endorse these third-party websites and are not responsible for their content or privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.