ASCLEPIUS OHS WEB SITE PRIVACY POLICY

BACKGROUND:

Asclepius OHS Ltd, trading as Asclepius Occupational Health, understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our Clients and their Employees and will only collect and use personal data in ways that are described here and in a way that is consistent with our obligations and your rights under the law.

  1. Information About Us:

Asclepius OHS Ltd.

Asclepius OHS Ltd. is a Limited Company registered in England under Company Number 08433175.

Registered Address: 377-399 London Rd, Camberley GU15 3HL

VAT number: 231 191 052.

Data Protection Officer: Mike King, CEO and Clinical Operations Director.

Email address: mike.king@a-ohs.co.uk.

Telephone number: 0203 940 8700.

Postal address: 377-399 London Rd, Camberley GU15 3HL

We are regulated by Data Protection Act 2018 (DPA) and the General Data Protection Regulations (GDPR) 2018. Our ICO Data Protection Registration Number ZA015225.

 

2. What Does This Notice Cover?

This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your Personal Data.

 

3.What Is Personal Data?

Personal Data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “The Data Protection Legislation”) as ‘any information relating to an identifiable natural person who can be directly or indirectly identified in particular by reference to an identifier’. See Part 11.

Personal Data is, in simpler terms, any information about you that enables you to be identified. Personal Data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data and other online identifiers.

The Personal Data that we use is set out in Part 5, below.

 

4.What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your Personal Data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part

b) The right to access the Personal Data we hold about you. Part 10 will tell you how to do this.

c) The right to have your Personal Data rectified if any of your Personal Data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your Personal Data that we hold; Your request will be passed to the Data Protection Officer who may want to discuss this with you. Sometimes Occupational Health records form important medico-legal documents for the exercise or defence of legal claims, such as with Health Surveillance records where such assessment is a statutory requirement. In such cases, we may not be able to agree to the erasure of your personal information. Please contact us using the details in Part 11 to find out more.

e) The right to restrict (i.e. prevent) the processing of your Personal Data.

f) The right to object to us using your Personal Data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your Personal Data, you are free to withdraw that consent at any time.

h) The right to Data portability. This means that: The Data Subject shall have the right to receive the Personal Data concerning him or her, which he or she has provided to a Controller, in a structured, commonly used and machine-readable format and have the right to transmit those Data to another Controller without hindrance from the Controller to which the Personal Data have been provided, where:

(a) The processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1).

and

(b) The processing is carried out by automated means.

i) Rights relating to automated decision-making and profiling. We do not use your Personal Data in this way.

 

For more information about our use of your Personal Data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your Personal Data is kept accurate and up to date. If any of the Personal Data we hold about you changes, please keep us informed as long as we have that Data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your Personal Data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves. Please contact us first, using the details in Part 11.

 

5. What Personal Data Do You Collect and How?

We may collect and hold some or all of the Personal Data set out in the table below, using the methods also set out in the table.

General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (United Kingdom General Data Protection Regulation).

Article 9 of Regulation (EU). 

(Paragraph 1) Processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation shall be prohibited.

Paragraph 2 (h) Processing is necessary for the purposes of preventive or Occupational Medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of domestic law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3.

In paragraph 3, ‘national competent bodies’ means competent bodies of the United Kingdom or a part of the United Kingdom.

(Paragraph 3) A ‘competent body’ is a professional regulatory body named in the Safeguarding Vulnerable Groups Act 2006 or the Safeguarding Vulnerable Groups (Northern Ireland) Order 2007.

The Disclosure and Barring Service (DBS) must use competent body ‘findings of fact’ as facts in barring decision-making processes.

Findings of fact may be made in proceedings before one of the following bodies or any of its committees:

  • the General Teaching Council for Wales
  • the Council of the Pharmaceutical Society of Great Britain
  • the General Medical Council
  • the General Dental Council
  • the General Optical Council
  • the General Osteopathic Council
  • the General Chiropractic Council
  • the Nursing and Midwifery Council
  • the Health and Care Professions Council
  • the General Social Care Council
  • Social Care Wales
  • Social Work England
  • the General Teaching Council for Northern Ireland
  • the Council of the Pharmaceutical Society of Northern Ireland
  • the Health Professions Council
  • the Northern Ireland Social Care Council

Data Collected

How We Collect the Data

Identity Information including Name, Title, Date of Birth, Gender.

Supplied by The Employer using Apollo.Direct Occupational Health Software. Employees may supply supplementary information or request an amendment to the information supplied by The Employer.

Contact information including Address, Email Address, Telephone Numbers.

Supplied by The Employer using Apollo.Direct Occupational Health Software. Employees may supply supplementary information or request an amendment to the information supplied by The Employer.

Business information including Business Name, Job Title, Profession.

Supplied by The Employer using Apollo.Direct Occupational Health Software. Employees may supply supplementary information or request an amendment to the information supplied by The Employer.

National Insurance Number

Supplied by The Employer using Apollo.Direct Occupational Health Software. Employees may supply supplementary information or request an amendment to the information supplied by The Employer.

Personal Medical Information

Supplied by Employer or Employee during Referral Process and Consultation. This is collected verbally, electronically or in writing, as part of The Referral and Consultation Process.

 

6. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using Personal Data. The following table describes how we will use your Personal Data and our lawful bases for doing so:

What We Do

What Data We Use

Our Lawful Basis

Administering our business.

As in the above table.

Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee

Provision of Occupational Health Services.

As in the above table.

Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee

Use of National Insurance Numbers.

National Insurance Number.

Used in Health Surveillance (HSE Requirement).

Communicating with you.

We may use Addresses, emails or telephone (Land line or Mobile).

Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee.

Supplying you with information by email and post that you have opted-in-to (you may opt-out at any time by unsubscribing)

Email Address and Postal Address

Processing is necessary for the purposes of preventive or occupational medicine.

With your permission and/or where permitted by law, we may also use your Personal Data for marketing purposes, which may include contacting you by email, telephone or post with information, news and offers on our Services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003 and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

We will only use your Personal Data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your Personal Data for that purpose. If we do use your Personal Data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your Personal Data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your Personal Data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

 

7. How Long Will You Keep My Personal Data?

We will not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected. Your Personal Data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept:

Type of Data

How Long We Keep It

Management Referral.

6 years, after the Employee has left their job or reaching 75 years of age, (whichever is soonest), as recommended by the British Medical Association (BMA) and Facility of Occupational Medicine (FOM).

New Employment.

Discarded after 2 years, if The Employee does not take up the offer of the job.

Health Surveillance.

40 years as required by the Health and Safety Executive (HSE).

 

8. How and Where Do You Store or Transfer My Personal Data?

We will only store your Personal Data, on Cloud Servers in the UK.

The security of your Personal Data is essential to us and to protect your Data, we take a number of important measures, including the following:

  • Limiting access to your Personal Data to those Employees, Agents, Contractors, and other Third Parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality.
  • Procedures for dealing with Data Breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your Personal Data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

 

9. Do You Share My Personal Data?

We will not share any of your Personal Data with any Third Parties for any purposes, subject to the following exception(s).

If we sell, transfer, or merge parts of our Business or Assets, your Personal Data may be transferred to a Third Party. Any new Owner of our Business may continue to use your Personal Data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain Personal Data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, such as a Court Order.

If any of your Personal Data is shared with a Third Party, as described above, we will take steps to ensure that your Personal Data is handled safely, securely and in accordance with your rights, our obligations and the Third Party’s obligations under the law, as described above in Part 8.

If any Personal Data is transferred outside of the UK, we will take suitable steps in order to ensure that your Personal Data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.

 

10. How Can I Access My Personal Data?

If you want to know what Personal Data we have about you, you can ask us for details of that Personal Data and for a copy of it (where any such Personal Data is held). This is known as a “Subject Access Request”.

All Subject Access Requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a Subject Access Request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our Administrative Costs in responding.

We will respond to your Subject Access Request, without undue delay and within One Calendar Month of receiving it. Normally, we aim to provide a complete response, including a copy of your Personal Data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of Three Months from the date we receive your request. You will be kept fully informed of our progress.

 

11. Right of Erasure.

Data stored is deemed as confidential and falls within the Special Category data as defined by the ICO, with regards to ‘Right to Erasure’ and therefore will not be erased within the normal storage timeframes, as detailed in section 7.

 

12. How Do I Contact You?

To contact us about anything to do with your Personal Data and Data Protection, including to make a Subject Access Request, please use the following details for the attention of Data Protection Officer:

Mike King, CEO and Clinical Operations Director.

Email address: mike.king@a-ohs.co.uk

Telephone number: 0203 940 8700.

Postal Address: 377-399 London Rd, Camberley GU15 3HL.

 

13. If you have any questions about this Privacy Notice or how we handle your Personal Information, please contact Asclepius Occupational Health, details as in Part 11. 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. Further information can be found on their website at ico.org.uk

Our ICO Data Protection registration number ZA015225.

 

14. Changes to this Privacy Notice:

We may change this Privacy Notice from time to time. This may be necessary, for example, if the Law changes, or if we change our Business in a way that affects Personal Data Protection.

 

Any changes will be made available on The Company Occupational Health Software, (Apollo.Direct). This Privacy Notice was last updated on 2 January 2024