Health Navigator – Data Privacy Statement

We are committed to safeguarding the privacy of patients enrolled in our services. The following statement is aimed at all patients receiving our health coaching. However, If you are a participant in our research study please scroll to the bottom of the page (or click here).

 

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); 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, genetic, mental, economic, cultural or social identity of that natural person”

 

How we use your information

This privacy notice tells you how we, Health Navigator, will collect and use your personal data and data from your health records during the time who receive our service.

 

Why does Health Navigator need to collect and store personal data?

In order for us to provide you with our health coaching we need to collect your personal data from you and data from your health records so that our health coaches can provide you with the support you need. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an unnecessary invasion of your privacy.

 

Will Health Navigator share my personal data with anyone else?

No. However, with your permission, we will inform your General Practitioner/Family doctor (GP) that you are receiving our health coaching service.

 

How will Health Navigator use the personal data it collects about me?

Health Navigator will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Health Navigator is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

 

Can I find out the personal data that the organisation holds about me?

Health Navigator at your request, can confirm what information we hold about you and how it is processed. If Health Navigator does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
  • Contact details of the data protection officer.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Health Navigator or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

Data privacy statement for participants of our research study

Health and care research should serve the public interest, which means that we have to demonstrate that our research serves the interests of society as a whole. We do this by following the UK Policy Framework for Health and Social Care Research.

We use personally-identifiable information to conduct research to improve health and care. As a health care service company we have a legitimate interest in using information relating to your health and care for research studies, when you agree to take part in a research study. This means that we will use your data, collected in the course of a research study, in the ways needed to conduct and analyse the research study. Your rights to access, change or move your information are limited, as we need to manage your information in specific ways in order for the research to be reliable and accurate. If you withdraw from the study, we will keep the information about you that we have already obtained. To safeguard your rights, we will use the minimum personally-identifiable information possible.

At regular intervals during your participation in the study, we will also share your personally-identifiable information (i.e. NHS Number) with either NHS Digital or the Clinical Commissioning Group (CCG) responsible for you in order to obtain pseudonomised (i.e. non-identifiable) data about the health care you receive. This non-identifiable data will allow us to test the effectiveness of the health coaching intervention on a group level.

Contact

If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter. If you are not satisfied with our response or believe we are processing your personal data in a way that is not lawful you can complain to the Information Commissioner’s Office (ICO; https://ico.org.uk/for-the-public/raising-concerns/)

Our Data Protection Officer is Philipp Ludersdorfer and you can contact him at philipp.ludersdorfer@health-navigator.co.uk.