SOFTWARE OF EXCELLENCE UK LIMITED

                                                  

PATIENT PORTAL PRIVACY POLICY

 

We are committed to protecting and respecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

 

Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, generic, mental, economic, cultural or social identity of that natural person.

 

1. PURPOSE OF THIS PRIVACY POLICY

1.1 This policy together with the terms of use available here (“Terms of Use”) apply to the use of the patient Portal (“Portal”). The Portal provides a means of collecting important information from you and securely passing that information to your dental care provider, which includes both dental practices and referral centres where applicable (“Dental Care Provider”). The Portal is provided by Software of Excellence (“We”, “Us”).

1.2. We are registered in England and Wales under company number 02940919 and have our registered office and main trading address at Medcare South Bailey Drive, Gillingham Business Park, Gillingham, Kent, ME8 0PZ.

1.3. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

1.4. We will only process personal data for the specific purposes set out in this policy or for any other purposes specifically permitted by the applicable data protection legislation and will only process such data in accordance with the requirements of the applicable data protection legislation.

1.5.Please read the following carefully to understand our views and practices regarding personal data and how we will treat it. By using the Portal, you consent to the collection, use, storage and disclosure of personal information as set out in this policy.

2.INFORMATION WE COLLECT FROM YOU

2.1. We will collect and process the personal data you give us. This is information about you that is given to us when you fill in forms on the Portal, or when you provide us with information by any other means. The information you give us may include, but is not limited to, your name, address, e-mail address and phone number, date of birth, username, password and other registration information, financial, credit card and other payment information and other personal or medical information required by forms on the Portal.

2.2. We may monitor, record, store and use any telephone, email or other communication with you in order to check any instruction given to us, for training purposes, for crime prevention and to improve the quality of the Portal.

3.HOW IS YOUR PERSONAL DATA COLLECTED?

3.1. Your personal data will only be collected in accordance with this policy.

3.2. Your personal data will be collected by completing the forms on the Portal.

3.3. Personal data may be extracted from your practice records to assist you with the completion of the forms on the Portal.

4. USES MADE OF YOUR INFORMATION

4.1. We will only use your personal data in the following ways:

4.1.1.When the law allows us to. This includes in instances where we need to comply with a legal or regulatory obligation; and

4.1.2. In accordance with the Terms of Use.

4.1.3. To perform our obligations under our contract with your Dental Care Provider. Specifically, we will supply the data that you submit via the forms on the portal to your Dental Care Provider to enable them to deliver dental services to you.

4.1.4. In the additional specific ways:

Purpose/Activity Type of Data Basis for processing including basis of legitimate interest.   

To enable third parties to carry out technical, logistical or other function on our or your Dental Care Provider’s behalf.

Please refer to clause 5 of this policy for details of third parties.

Data submitted to the Portal, but only to the extent that is necessary. Data anonymised where possible. Please refer to clause 5 for details of third-parties and the reasoning as to why your data may be shared with them.
To improve the Portal and ensure it is as effective as possible. Data submitted to the Portal, but only to the extent that is necessary. Data anonymised where possible.

Necessary for our legitimate business interests.

In compliance with a legal obligation.

To administer and protect our business and for internal operations (including troubleshooting, data analysis, test, system maintenance, support, operational reporting/analysis and ensuring that the Portal is safe and secure). Data submitted to the Portal, but only to the extent that is necessary. Data anonymised where possible.

Necessary for our legitimate business interests.

In compliance with a legal obligation.

4.2. Use of the Portal is taken as your consent to the use of your personal data in accordance with this policy.

4.3. You have the right to withdraw consent to data being used by us in accordance with this policy at any time by contacting us at support@soeuk.com. Please note that we need up to 30 working days to update our systems and for your opt-out to take effect (“Opt-out”). If you Opt-out, you will no longer be able to use the Portal.

4.4. 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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us UKDPO@soeuk.com.

4.4.1. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

4.4.2.Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURE OF YOUR INFORMATION

5.1. You agree that we have the right to share your personal information with your Dental Care Provider in accordance with this policy.

5.2. We may also disclose your personal information to third parties in the following circumstances:

5.2.1. If Software of Excellence UK Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about users of the portal will be one of the transferred assets;

5.2.2. If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.

5.2.3. In relation to other selected third parties including:

 

Recipient Category of Data Purpose
Analytics and search engine providers Aggregate anonymised information about users of the Portal Improvement and optimisation of the Portal where necessary for the legitimate running of the business.

In compliance with a legal obligation.

Legal counsel Personal data – anonymised where possible. In the event of any litigation where personal data entered on the Portal is relevant to such litigation.

Where necessary for the legitimate running of our business.

In compliance with a legal obligation.

Suppliers or sub-contractors Data as required in the performance of a contract with us to deliver any part of the Portal or to facilitate the continuing development of the Portal. Where necessary for the legitimate running of our business to deliver and develop the Portal.
Payment providers Name, postcode, email address and payment card details. In circumstances where payment is necessary.

6. INTERNATIONAL TRANSFERS

6.1. Your data that we collect will be processed and stored at, a destination inside the European Economic Area (EEA), or the UK or countries, such as New Zealand, who are recognised by the European Commission as having equivalent data protection standards.

6.2. In the event that we cannot ensure that your data remains inside the areas as defined in paragraph 6.1 above, we will ensure that the amount of personal information exposed is minimised and clear warnings will be presented to the patient at point of use as to the extent of the exposure. It may also be processed by staff operating outside the areas as defined in paragraph 6.1 above who work for us or for one of our business partners, suppliers or sub-contractors.

7. SECURITY

7.1. We have put in place appropriate security measures 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. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

7.2. We have put in place policies and 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. HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?

8.1. We will not hold onto your personal data for longer than is necessary for the purpose for which it was collected.

8.2. In some circumstances you can ask us to delete your data: see clause 1.3 of this policy for further information.

8.3. We will take all reasonable steps to destroy or erase from our system, all data which is no longer required.

9. YOUR LEGAL RIGHTS

9.1. You have certain rights under data protection legislation including the following:

9.1.1. Request access: to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

9.1.2.  Request correction:of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

9.1.3. Request erasure:  of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

9.1.4.Object to processing:of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

9.1.5. Request restriction of processing:of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

9.1.6. Request the transfer: of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

9.1.7. Withdraw consent at any time:where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

9.1.8.Right to lodge a complaint with a supervisory authority: You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you wish to exercise any of the rights set out above, please contact us at UKDPO@soeuk.com

9.2. 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.

9.3. 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.

9.4. 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 multiple requests. In this case, we will notify you and keep you updated.

10. CHANGES TO PRIVACY POLICY

You will be notified of any changes to this policy and, where necessary, be required to read and accept the changes upon entering the Portal.

11. HOW TO CONTACT US

11.1. SOE is a company incorporated in England and Wales with company number 02940919 whose registered office is at Medcare South Bailey Drive, Gillingham Business Park, Gillingham, Kent, ME8 0PZ, England.

11.2. We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

11.3. If you have any concerns or questions about how your personal data is used, please contact us:

By post:     by writing to The Data Protection Officer at Medcare South Bailey Drive, Gillingham Business Park, Gillingham, Kent, ME8 0PZ, England; or

By email:    by emailing us at UKDPO@soeuk.com