WHO ARE WE?
Medigold Health Consultancy Limited (including its group companies or subsidiaries) ("Medigold Health") has its registered office at Medigold House, Queensbridge, Northampton NN4 7BF.
We can act as both data processor (we undertake the processing on behalf and on the instruction of the data controller) and data controller (we decide how your personal data is processed and for what purposes).
At the time this policy was produced Medigold Health’s group companies included:
- Ablemed Health Limited
- IMASS Group Limited
- Hampton Knight
OUR DATA PROTECTION OFFICER
Our Data Protection Officer is Mrs G Foster, you can contact her using the following email address: firstname.lastname@example.org
PERSONAL DATA – WHAT IS IT?
Personal data means information from which a living individual can be identified. Identification can take place using the information alone or in conjunction with any other information in the data controller’s possession or likely to come into the data controller’s possession. The processing of personal data is governed by the Data Protection Act 1998 and the General Data Protection Regulation (EU) 2016/679 (the "GDPR") (when the latter comes into force).
SENSITIVE DATA – WHAT IS IT?
Personal data of an individual, the data subject, relating to any of the following:
- racial or ethnic origin;
- political opinions;
- religious or philosophical beliefs;
- trade union membership;
- data concerning health;
- data concerning sex life or sexual orientation;
- genetic data; or
- biometric data where processed to uniquely identify the data subject.
THE PURPOSE OF PROCESSING YOUR PERSONAL DATA
HOW AND WHY WE USE YOUR PERSONAL DATA?
Medigold Health carries out a range of occupational health services. We collect health information where this is necessary for the protection of health and safety, to prevent discrimination on the grounds of disability, and to provide advice to your employer on fitness to work or medical advice on applications for early retirement due to ill health.
WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
We collect information about you and your health when you are referred to us as part of your employer’s occupational health service, as part of your application of early retirement due to ill health or when you access any of our medical services including role specific medicals (for example, for work in confined spaces), statutory health and safety requirements (for example, relating to hand arm vibration) or wellbeing events or for the provision of other services such as alcohol and drug testing, or wellness events.
WHERE DO WE OBTAIN YOUR PERSONAL DATA?
Your personal data may come to us via a referral from your employer, an application from your Pension Scheme, or, with your consent, your GP or Consultant or a provider of additional services such as physiotherapy or counselling. Alternatively, we may obtain personal data directly from you.
HOW DO WE PROCESS YOUR PERSONAL DATA?
Medigold Health complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of personal data; by protecting personal data from loss, misuse, unauthorised access and disclosure; and by ensuring that appropriate technical measures are in place to protect personal data.
SHARING YOUR PERSONAL DATA
Your personal data will be treated as strictly confidential, and will only be shared with third party clinicians or providers of services such as counselling, physiotherapy or additional assessments. We will only share your personal data with third parties if you provide us with your consent, the sharing of your personal data is required by law, there is a substantial public interest for us to do so (such as a danger to the wider public), or the disclosure of your personal data is of overall benefit to you when we believe that you lack the capacity to consent. Where we do not rely on your consent to share your information data we will only disclose the minimum amount of information necessary, avoiding releasing personal data where possible.
HOW LONG WILL WE KEEP YOUR PERSONAL DATA
Medigold Health will retain your personal data, your occupational health file, only for as long as we need that personal data for the purposes of the processing. At the most, we will retain your personal data in accordance with statutory requirements and / or your employer’s or your pension scheme’s retention policy.
WHERE DO WE PROCESS YOUR PERSONAL DATA
We do not process any of your personal data outside of the European Economic Area.
WHO IS THE DATA CONTROLLER?
The Data Controller will normally be your employer, the Trustees or Trustee Representatives or Administrators of your Pension Scheme or Plan or those Pension organisations authorised by the Secretary of State.
Medigold Health will seek your explicit consent to process your personal data with regards to occupational health and pension applications. This is the legal basis on which we will rely on to process your personal data.
You have the right to withdraw your consent at any time. Please note that should you withdraw your consent, your employer or pension scheme may choose to act on the information they have to hand.
Please note that failure to provide appropriate information may lead to our clinicians being unable to provide a medical opinion on fitness or adjustments.
WHAT ARE YOUR RIGHTS?
Right of access. The GDPR gives you the right to access copies of the personal data held about you. Your right of access can be exercised in accordance with the GDPR. The first copy of the personal data held about you will be provided free of charge but any subsequent copy will be subject to a reasonable fee based on the administrative costs of providing copies of the personal data to you.
Right to portability (the right to request an electronic copy of your personal data). Where you provide personal data you have the right to be provided with a structured, commonly used and machine-readable copy and have the right, in certain circumstances, to ensure that we transmit that personal data to another data controller without hindrance (the right to data portability).
Right to correct (rectification). You have the right to ensure that we correct the records of any personal data held about you which are inaccurate. You also have the right to ensure that we complete any incomplete personal data held about you.
Right to erasure. You have the right to ensure that we erase your personal data (the right to be forgotten).
Right to restrict processing. In certain circumstances, such as where you have contested the accuracy of personal data, you have the right to restrict our processing of your personal data. That means that we will hold your personal data on file but that we cannot process that personal data. We will inform you if for any reason the restriction on processing your personal data is lifted. Where any rectification or erasure of personal data or restriction of processing has taken place we shall communicate any rectification to you or erasure or restriction of processing to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort. We shall, if you request, inform you about those recipients.
Exercising your rights. If you wish to exercise any of your rights, or if at any point you believe the personal data we process is incorrect, you can request to see this personal data. If you would like a copy of the personal data about you that we process, or if you wish to have that personal data transferred to another company or organisation, please contact us at: email@example.com or accessing our online portal at https://www.medigoldone.com/Display/DataRightsRequest/
If you wish to raise a complaint on how we have handled your personal data, please contact our Data Protection Officer, Mrs G Foster, at firstname.lastname@example.org
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). https://ico.org.uk/
Further information about how we process your personal data can be accessed via our website www.medigold-health.com
This policy was updated on 08 May 2018
A downloadable version of this policy can be found here