Push Doctor
Privacy Notice

If you are not happy for your information to be used in the ways described here, you should stop using Push Doctor and cancel any appointments you have. If you have any questions about the use of your data please get in touch with us at dpo@pushdoctor.com

This privacy notice tells you what to expect us to do with your personal information when you contact us or use one of our services. It applies to everyone who uses Push Doctor, whether you:

Personal information is any information that can be linked to you or another living person.

This notice is split into sections:

We have used links to help you get to the information you are interested in.

In some places we have provided links to other websites, for example the Information Commissioner's website. We are not responsible for the accuracy of any other websites.

Our details

Push Doctor is responsible for keeping the personal information we use safe and making decisions about how it can be used. Our formal name is Push Doctor Limited and our headquarters are at Arkwright House, Parsonage Gardens, Manchester, M3 2LF.

You can contact our Data Protection Officer at dpo@pushdoctor.com or by writing to the Data Protection Officer, at the address above for any queries about your personal information.

What does Push Doctor use my personal information for?

We use your personal information to:

If you have agreed, we may also use your personal information to let you know more about our services and offers, or those of third parties and to understand the effectiveness of our advertising. This may include using your medical information, so we can offer services that are relevant to you. For example, we may ask you some questions relating to your general health, or you may choose to share your data from wearable devices, monitors or other apps with us. If you are paying for Push Doctor services and we hold your medical data, you may also choose to allow us to use this to personalise recommendations from Push Doctor and selected third parties. You can control how we use your personal information through your communication preference centre.

We may sometimes need to use your personal information for other purposes

We may sometimes need to use your personal information to:

And if you are not paying for Push Doctor services

If you are an NHS patient we also provide information back to your GP surgery, so that they have a record of what we have done. That personal information will be handled in accordance with your GP surgery's policies.

We may also use your information to help other organisations delivering NHS or social care to provide you with services.

And if you are paying for Push Doctor services

If you are not an NHS patient we may also use your personal information to:

Under data protection laws, each purpose for which we use your personal information must comply with one of the conditions for processing. You can find out more about the conditions we rely on below

The Information Commissioner's Office (ICO) is responsible for ensuring that organisations comply with data protection rules. You can find out more about what the conditions for processing are on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing.

When we are using personal information we must meet one of the conditions set out in Article 6 of the General Data Protection Regulation (GDPR).

Under the GDPR there is some personal information that is so sensitive that it gets extra protection. This special data is any personal information about someone's:

It also includes genetic data and biometric data if that information is used to identify an individual.

When we are using special data we must also meet one of the conditions set out in Article 9.

We have set out in the table below which conditions we are relying on when we use your personal information.

We have set out below the conditions that we are relying on in order to use your data.

Purpose

Article 6 condition

Article 9 condition

All patients

co-operate with regulators, like the Care Quality Commission

Article 6(1)(e) – public task

Article 6(1)(c) – compliance with a legal obligation

Article 9(2)(g) – substantial public interest

comply with a legal obligation, like a court order requiring us to release information

Article 6(1)(c) – compliance with a legal obligation

Article 9(2)(f) – establishment, exercise or defence of legal claims

Article 9(2)(g) – substantial public interest

deal with disputes and legal claims, for example if you make a legal claim against one of our GPs

Article 6(1)(f) – legitimate interests (we have a legitimate interest in being able to deal with disputes and legal claims)

Article 9(2)(f) – establishment, exercise or defence of legal claims

deal appropriately with any risk to public health

 

Article 6(1)(e) - public task

Article 6(1)(c) – compliance with a legal obligation

Article 9(2)(h) – healthcare and social care purposes

Article 9(2)(i) – public health

NHS patients

provide you with Push Doctor services

Article 6(1)(e) - public task

Article 9(2)(h) – healthcare and social care purposes

help maintain the quality of and improve Push Doctor services

 

Article 6(1)(e) - public task

Article c(1)(f) – legitimate interests (we have a legitimate interest in maintaining and improving the quality of Push Doctor services)

Article 9(2)(h) – healthcare and social care purposes

Provide information back to your NHS GP surgery

Article 6(1)(e) - public task

Article 9(2)(h) – healthcare and social care purposes

We may also use your information to help other organisations delivering NHS or social care to provide you with services.

Article 6(1)(e) - public task

Article 9(2)(h) – healthcare and social care purposes

let you know more about our services and offers

Article 6(1)(a) - consent

Article 9(2)(a) – consent

let you know more about the products and services of third parties that may be relevant to you

Article 6(1)(a) - consent

Article 9(2)(a) – consent

Non NHS patients

provide you with Push Doctor services

Article 6(1)(b) – performance of a contract

Article 9(2)(h) – healthcare and social care purposes

help maintain the quality of and improve Push Doctor services

 

Article 6(1)(f) – legitimate interests (we have a legitimate interest in maintaining and improving the quality of Push Doctor services)

Article 9(2)(h) – healthcare and social care purposes

carry out credit checks

Article 6(1)(b) – performance of a contract

No special data used

obtain payment from you for our services

Article 6(1)(b) – performance of a contract

No special data used

let you know more about our services and offers

Article 6(1)(a) - consent

 

 Article 9(2)(a) – consent

let you know more about the products and services of third parties that may be relevant to you

Article 6(1)(a) - consent

Article 9(2)(a) – consent

There are extra rules that apply to information about criminal allegations and convictions. We do not use this type of information very often, for example you might tell us about a drug-related conviction or time in prison. Our use complies with Article 10 of the GDPR because it meets the condition set out in the Data Protection Act 2018, Schedule 1, Part 1, paragraph 2 (health or social care purposes).

How does Push Doctor get my personal information?

Most of the personal information we use is provided to us directly by you so that you can access our services. For example, you provide us with your contact details. Please let us know if there are any changes to your personal details while you are registered with us

This includes personal data you provide when you:

If you agree, we may use information about your health from health technology companies

If you agree, we may use information about your health from programmes like Microsoft HealthVault or Google Health that individuals use to collect, store and analyse information about their health.

If you agree, we may use information about your health from smart devices. For example, smart watches can keep a record of your heart rate.

You can choose to stop sharing this data with us at any time.

We also gather technical information about your visit, like what device you are using to access Push Doctor services. More detail about what we collect is set out in the section below (What personal information about me does Push Doctor use?)

We automatically collect this personal data by using cookies, server logs, application data caches, browser web storage and other similar technologies. We may also receive data about you if you visit other websites that use our cookies. Please see our cookie policy for further details.

We collect information about your location if you are using a computer, tablet or mobile phone that has GPS enabled.

We use information about your location to advise you where your nearest pharmacy is.

You can stop us using your location information at any time by turning off the GPS setting in your device

If you do not pay for Push Doctor services, then we will access information about you that is stored on your NHS GP's records. We will ask for your agreement before we do this.

We access NHS systems so that we can see your full medical record. This means that we can see any information that your NHS GP can see. This will include contact information and detailed health information like family health history, past diagnoses, treatment plans, medication, body measurements and test results.

If you do not pay for Push Doctor services, then the medical record of your appointment (including any diagnosis or treatment prescribed by the Push Doctor GP) will be stored in your NHS medical record that is held by your GP practice. However, Push Doctor GPs do provide us with summary information about your online appointment.

Push Doctor GPs log the following information with Push Doctor:

If you pay for Push Doctor services we may access information about you from credit referencing agencies, advertising networks and partner organisations that help us process payments.

If you pay for Push Doctor services you will provide us with information about your health (because we are not able to access this information from NHS records). Push Doctor GPs store the medical record of your appointment (including any diagnosis or treatment prescribed by the Push Doctor GP) on our systems.

What personal information about me does Push Doctor use?

We use the following personal information:

This includes the information that you provide us with when you register and other profile information

This includes:

This is information like your date of birth, nationality, gender, marital status and dependants

This includes:

Health tracking programmes allow you to combine data from multiple apps or devices. By doing so, you can track your health and fitness activities against your goals to provide you with a comprehensive view of your health and fitness.

This information can include all of the information listed below in examples of data from smart devices and health apps. Information may be combined from several sources to provide you with a more personalised view of your health and lifestyle.

This information can include indicators of activity such as heart rate or blood pressure, exercise summaries, nutritional intake, weight and sleep cycles.

This includes their contact details, relevant medical history if required and emergency contact information.

This includes referrals, prescriptions and fit notes

This includes:

This includes your I.P. address, any unique device identifiers placed by us or our service providers, the unique identifier assigned by Push Doctor to your computer, mobile phone or tablet

This includes full uniform resource locators (URL); clickstream to, through and from the Push Doctor app and website (including date and time); services you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks and mouse-overs); methods used to browse away from the page

We use information about your location to advise you where your nearest pharmacy is.

You can stop us using your location information at any time by turning off the GPS setting in your device

This may include demographic information, such as where you live and your income, if you choose to provide it. It may also include your opinions about our services.

We anonymise this information before we use it to improve our services.

You can control your settings in your communications preference centre.

And if do not pay for Push Doctor services

And if you pay for Push Doctor services

This includes your purchases and orders, the charges you have incurred, payments you have made, your payment card details, any credit reference checks and any information from debt collection agencies

Who does Push Doctor share my personal information with?

To provide you with Push Doctor services we need to share your personal information with Push Doctor GPs and our medical team.

We also need to share information with partner organisations that help administer Push Doctor accounts.

For example:

We have vetted these organisations to ensure that they will deal with your personal information responsibly.

We do not allow these partner organisations to use your personal information for their own purposes. We only permit them to use your personal in accordance with our instructions.

We may also share information with our partner organisations who provide data analysis services, to help improve our services. This does not include information about your health.

Sometimes we need to share information with regulators like the Care Quality Commission, the General Medical Council, NHS Digital, the Information Commissioner's Office and the Health Service Ombudsman.

With your agreement, information can be shared with relatives, partners or friends who act as a carer for you. We will only share information once the person you have asked us to share the information with has provided us with proof of their identity. We may share information with anyone you have given as an emergency contact, for example your next of kin. You can find out more by contacting us at support@pushdoctor.co.uk, 0330 808 4702 or writing to us at Push Doctor, Arkwright House, Parsonage Gardens, Manchester M3 2LF

We may also share information with anyone else that you authorise us to e.g. your employer or (if you are not an NHS patient) your insurer. However, Push Doctor GPs will not discuss individual cases with employers, insurers or other third parties.

There are some other rare occasions where we may share your data with other organisations.

The other organisations that we share information with depend on whether you are paying for Push Doctor services or not.

If you do not pay for Push Doctor services, then we may share your personal information with other organisations that help provide NHS or social care.

These organisations include:

If you do not pay for Push Doctor services and you have agreed to receive information about our services and offers, we may share your information with marketing organisations.

For example we may share you contact information with companies that we use to send marketing emails. Although we will not share information about your health with these organisations, it may be possible for them to infer this information due to the content of the marketing email. For example, if we are sending you information about how we can help you manage your diabetes, our partners will be able to infer that you have this condition. You can control your settings in your communications preference centre.

If you do not pay for Push Doctor services and you have agreed to receive information about the products and services of third parties that may be relevant to you, we won't share information about you with those third parties. Instead we will let you know information about them so that you can use their products or services if you wish.

If you pay for Push Doctor services

Our app and the website include some social media features, such as the Facebook button and the 'Share This' button. You can use these features to share information about your use of Push Doctor through social media. The relevant social media site(s) control how these features work. If you want to find out more about this you should read the privacy policy of the relevant social media site.

Where is my data stored?

Most of the time your personal information stays within the European Union.

Sometimes your personal information may be transferred to our partners in the United States. Our US partners have signed up to the EU-US Privacy Shield. This ensures that your personal information and your privacy rights are protected.

The European Commission (part of the European Union) has ruled that the EU-US Privacy Shield provides adequate protection to allow personal information to be transferred to the United States.

You can read more about the Privacy Shield here [link to ICO website]. if you would like more information about partners we may use who store data outside of the EU please contact us.

How long does Push Doctor keep my personal information for?

Medical information

If you do not pay for Push Doctor services, clinical information will be stored on your GP practice's electronic patient record system. For information about how long that information is stored, please refer to your GP practice's privacy notice. You can usually find this on their website. Neither Push Doctor nor your Push Doctor GP keeps any medical records about your on-line appointment.

If you pay for Push Doctor services, clinical information will be stored on Push Doctor systems. This information will be deleted in accordance with the Records Management Code of Practice for Health and Social Care.

Other information

Account information for individuals (including people who have completed the on-line registration process) who have not used our consultation services will be deleted after two years, unless we are required to retain such information for any legal or regulatory reason.

Account information about individuals (for example your name, log in details, summary details of the Push Doctor services you have used, any complaints you have made about our service) who have accessed our services will be kept until two years after they last accessed the services or communicated with us, whichever is later.

If you pay for Push Doctor services and you have let us know through your communication preference centre that you are happy to receive marketing information, we keep the information we need for marketing for a maximum of 2 years from when you last accessed the Push Doctor website or app.

How does Push Doctor keep my information secure?

At Push Doctor we take security and the secure storage of personal data seriously. We encrypt and store all personal data on secure servers using the latest technologies which are protected by several layers of security.

We do not store any of your personal health data on your mobile device or within your web browser storage permanently. We may collect some personal data and store it temporarily on your mobile device or within your web browser storage (e.g. your post-code during the sign-up process) but this data is not kept on your device after the process for which it is being used has ended.

When using the Push Doctor app or website, all your personal data is transmitted through the internet using Secure Socket Layers (SSL) technology. SSL is an industry standard technology designed to prevent any third party from capturing and viewing your personal data while in transit.

You are required to go through a two-step identity verification process to create your account. Access to your account is protected with a password that you create. You are responsible for keeping this password confidential. We strongly recommend that you do not disclose your password to anyone else and Push Doctor will never ask you for your password in any unsolicited communication (including unsolicited correspondence such as letters, phone calls, emails or text messages). You will only ever be able to reset your password using a two-step identity verification process.

For more information on how we keep your data secure, please contact us at support@pushdoctor.co.uk or contact our helpline on 0330 808 4702.

What rights do I have over my personal information?

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information.

If you do not pay for Push Doctor services and you want to exercise any of these rights regarding information held in your medical records, you should contact your GP practice. This is because it is your GP practice who holds those records and has control over them.

Your right of access

You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which mean you may not always receive all the information we have about you. You can read more about this right here (https://ico.org.uk/your-data-matters/your-right-of-access).

To access a copy of your electronic medical records or other information that Push Doctor holds about you, please contact us at support@pushdoctor.co.uk, 0330 808 4702 or use our live chat feature at https://www.pushdoctor.co.uk/contact

Your right to rectification

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about this right here (https://ico.org.uk/your-data-matters/your-right-to-get-your-data-corrected).

We will not usually amend medical records. This is because it is important that we have a copy of the information available to doctors at the time they are treating you. Instead we usually add a note to your record to highlight the information you consider to be incorrect.

Your right to erasure

You have the right to ask us to erase your personal information in certain circumstances. You can read more about this right here (https://ico.org.uk/your-data-matters/your-right-to-get-your-data-deleted).

Again, we will not normally delete information from medical records. This is because it is important that we have a copy of the information available to doctors at the time they are treating you.

Your right to restriction of processing

You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about this right here (https://ico.org.uk/your-data-matters/your-right-to-limit-how-organisations-use-your-data/)

Your right to object to processing

You have the right to object to processing if we are able to process your information because the process forms part of public tasks or is in our legitimate interests. You can read more about this right here.

Your right to data portability

This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about this right here.

Your right to withdraw consent

You can control whether or not your personal information is used for marketing in your communication preference centre which can be accessed under 'my account' within the Push Doctor app or website. All accounts are set up so that the user does not agree to the use of their personal information for marketing unless they opt in using the preference centre.

You have the right to withdraw your agreement to the use of your personal information for marketing at any time. You can do this by changing your settings in the preference centre. Doing this means that we cannot use your personal information in the future unless you use the preference centre to opt in again.

You are not required to pay any charge for exercising your rights.

Please contact us at support@pushdoctor.co.uk if you wish to make a request, or contact our helpline on 0330 808 4702.

We may ask you to provide us with identification so that we can be sure that we are dealing with the right person. This is a security measure. We may also contact you to ask you to put your request into writing and/ or for further information in relation to your request to speed up our response.

We try to respond to 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 these cases, we will notify you and keep you up to date about when we expect to be able to respond.

Contact us

If you have any questions, want to exercise your rights or need further information about what we do with personal information, our Data Protection Officer can be contacted by email at dpo@pushdr.com.

You can find also out more about our legal obligations and your privacy rights from the Information Commissioner's Office ("the ICO"). The ICO oversees compliance with privacy laws in the UK.

The ICO can be contacted at:

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

Tel: 0303 123 1113

www.ico.org.uk

Complaints

You have the right to make a complaint at any time to the ICO if you are not happy with the way that we have dealt with your personal data or a request from you to exercise your privacy rights.

We would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us at support@pushdoctor.co.uk or 0330 808 4702 in the first instance.

Updating this notice

We may update this notice from time to time. If we plan to update the policy we will let you know through the Push Doctor website or the Push Doctor app. When you log on to your account we will also let you know if the notice has been updated since you last accessed Push Doctor services. You should stop using our website and apps if you do not agree to any changes.

This notice was most recently updated on 5th September 2018. To obtain an historic version of this notice please contact us at support@pushdoctor.co.uk or 0330 808 4702.

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