Primary Care Privacy Policy

Purpose of this policy

This policy describes how we collect and use personal information about you, in accordance with the General Data Protection Regulation (GDPR) 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (Data Protection Legislation).

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.


About us

Clarity Informatics Limited (“we”, “us”, “our” and “ours”) is a provider of knowledge, software, and services in the healthcare sector. We are registered in England and Wales under company number: 04133376 and our registered office is at Unit 18 Jessops Riverside, 800 Brightside Lane, Sheffield, England.For the purpose of the Data Protection Legislation and this policy, when:

  1. we have a direct contract with you for our products and services or where you provide your personal data to us outside of any business relationship we have with your employer (or other similar organisation) we are the “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.
  2. where we have a contract with your employer or other similar organisation for our products and services (instead of directly with you), we are a “data processor”.  In these circumstances, your employer (or other similar organisation) will be the “data controller” and it is responsible for deciding how we hold and use personal data about you.  Our use of your personal data is governed by the terms of that contract.


We are required under the Data Protection Legislation to notify you of the information contained in this privacy policy.

We have appointed a Data Protection Officer. Our Data Protection Officer is responsible for assisting with enquiries in relation to this privacy policy or your treatment of personal data. Should you wish to contact our Data Protection Officer, you can do so using the contact details noted at paragraph 12 (Contact Us), below.


How we may collect your personal information

We may collect and process information that you provide by filling in forms on our website. This includes information provided at the time of registering to use our site or subscribing to any of our services (“Registration Data”).  We also collect and process material contributed through any interactive service (“User Generated Content”) which, of course, includes information that you (and/or where applicable your employer or other similar organisation) input into our products and services.

If you contact us, we may keep a record of that correspondence.


The kind of information we hold about you

When we are acting as the data controller, the information we hold about you may include the following:

  • your personal details (such as your name, address, email address, phone number(s));
  • details of contact we have had with you (for example, when providing you with a quote for our products or services);
  • details of any products or services you have received from us, as well as any associated payment-related information;
  • information about any complaints and enquiries you make to us;
  • tracking cookie data (please see our cookies policy); and, of course,
  • the information you input into our products and services.  In this respect please note that it is your responsibility, when inputting personal data relating to a third party (such as a patient’s contact details for electronic Patient Satisfaction Questionnaires) to always ensure that you have obtained the necessary prior consents to enable you to do so.  You must not input any other patient-related information.


When we are acting as a data processor, the information we hold may include the following:

  • business contact details and your users personal details (such as name, address, email address, phone number(s));
  • details of contact we have had with you (for example, when providing you with a quote for our products or services);
  • details of any products or services you have received from us, as well as any associated payment-related information;
  • information about any complaints and enquiries made to us;
  • tracking cookie data (please see our cookies policy); and, of course,
  • the information that you and your users input into our products and services.


When TeamNet is purchased by your employer or other similar organisation, the information may also include diaries and scheduling-related information, NHS smartcard information and HR-related information such as NI number, DBS status, training and disciplinary records.  It may also include health-related information such as immunisation and absence records. 

Please note that (i) it is your and your users responsibility to ensure that, when inputting personal data relating to a third party (such as a patient’s contact details for electronic Patient Satisfaction Questionnaires) to always ensure that they have given their prior consent to enable you and your users to do so; (ii) information inputted in relation to complaints must be appropriately pseudonymised; and (iii) you must not (and you must ensure your users do not) input any other patient-related information into any of our products and services.  The only exception to this is our Mortality Review product which is designed to include, as a specific function, the recording of such information.


How we use information we hold about you

Where we are acting as a data controller:

  • We may process your personal data for purposes necessary for the performance of our contract with you and to comply with our legal obligations.
  • We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
  • We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.


Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Where we are acting as a data processor:

  • Your employer (or other similar organisation) is responsible for providing us with instructions as to which types of personal data we are permitted to process; and
  • The ground(s) upon which your employer (or other similar organisation) is entitled to process your personal data is determined by them not us (and may vary from organisation to organisation); and
  • We process that personal data in accordance with their instructions and for the purposes of enabling us to perform our obligations under our contract with them (i.e. for the purposes of our own legitimate interests as a provider of products and services to your employer (or other similar organisation)) and to comply with our legal obligations.  


Situations in which we will use your personal information

We may use your information in order to:

  • carry out our obligations arising from any agreements entered into between you OR your employer and us (for example, for the provision of our products and services);
  • provide you with information related to products or services that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
  • seek your thoughts and opinions on the services we provide; and
  • notify you about any changes to our products or services.


In some circumstances we may anonymise the personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

We may also process your personal information without your knowledge or consent, in accordance with this policy, where we are legally required or permitted to do so.


Data Retention

Where we are acting as a data controller, we will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.  Where we are acting as a data processor, we will retain your personal data for the period agreed by your employer (or other similar organisation) in our contract with them.

If we are responsible for assessing what retention period is appropriate for your personal data, we take into consideration:

  • the purposes for which we originally collected the personal data;
  • the lawful grounds on which we based our processing;
  • the types of personal data we have collected;
  • the amount and categories of your personal data; and
  • whether the purpose of the processing could reasonably be fulfilled by other means.

Change of purpose

Where we are acting as a data controller and we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal information where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

Data sharing

Generally

We do not share your information with third parties, save as set out below.


Our group

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

Sharing with your employer (or other similar organisation)

Where we are a data processor and you are using our products and services in connection with a contract that we have with your employer (or other similar organisation) we will share your personal data with that employer (or other similar organisation) and vice versa.


Sharing of information within TeamNet

TeamNet can be used by our TeamNet customers (who are the data controllers) to share personally identifiable information where a member of staff works in more than one organisation. This includes individual staff records which contain absences, training and immunisation records and DBS checks. The reason for this is to allow individuals who may be working across several sites to ensure that their relevant employment details are available to their employer in those sites.

Our TeamNet customers are responsible for ensuring that each employee who works across different organisations is made aware that this information will be visible to the primary contact and HR manager at all organisations where they have been added as a TeamNet user so, if you are such an employee (or are otherwise engaged by a TeamNet customer) please note that this is the case.

It is for TeamNet users to themselves always ensure they have the appropriate consents from data subjects whose personal data is being shared using TeamNet.  This is a very important user responsibility.


What about other third parties?

We may share your personal information with other third parties, for example in order to enable the processing of payments for any of our products or services or where we subcontract any of our services to another data processor or in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.


Transferring information outside the EU

We will not transfer the personal information we collect about you outside of the EU without your agreement.


Data security

We have put in place commercially reasonable and appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and where we are acting as a data controller we will notify you and any applicable regulator of a suspected breach where we are legally required to do so.  Where there is a suspected data security breach but we are acting as a data processor and not a data controller, the contract between us and your employer (or other similar organisation) will govern what each of us is required to do, in those circumstances. 


Right of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Should your personal information change, please notify us, using the contact details below (or, where applicable, notify your employer or the entity that has engaged you) of any changes of which we/they need to be made aware.


Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information. This enables you to receive details of the personal information we hold about you and to check that we are processing it lawfully.
  • Request correction of the personal information that we hold about you.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to exercise any of the above rights, please email [email protected] or, (where applicable) please contact your employer (or other similar organisation) (and please note that, where we are acting as a data processor, we will always notify your employer (or other similar organisation) of your request and we will pass on the details of the request, to them).

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.  

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email [email protected]

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.


Changes to this policy

Any changes we may make to our privacy policy in the future will be notified on our website (https://staging.agiliosoftware.com)

This policy was last updated on 7th February 2022.

Contact us

If you have any questions regarding this policy or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Officer: [email protected] also have the right to make a complaint to the Information Commissioner’s Office (ICO: https://ico.org.uk), the UK supervisory authority for data protection issues, at any time.

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