Document title: Privacy Policy
Version number: 1.1
Date: Jan 22
Authors: Bernard Seymour
Date of Review October 2023 Performed by Dr Martin Harris (Medical
Director) and Elliott Hambling (Operations
Manager)
Date of Review September 2025 Performed by Dr Martin Harris (Medical
Director) and Elliott Hambling (Operations
Manager)
Next Review date: September 2027
Record of change:
Version Date Change Authorisation
1.0 Jan 22 Issue Registered Manager –
Elliott Hambling
1.1 July 22 Incorporate National Opt
Out information.
Registered Manager –
Elliott Hambling
1. Introduction.
This privacy policy sets out the way Hatzola Edgware process your personal
information. It deals with how we collect information, what we do with it, how we
protect it and what controls or rights you have.
We are committed to protecting the privacy of anyone who interacts with us and our
patients, members, responders and supporters and will treat all information you give
us with care.
We promise to:
• Tell you why we collect personal information, how we do this and what we
use it for.
• Only collect the information we need to deliver the service to you.
• Keep the personal information up to date and ensure it is safe and secure.
Please read this Privacy Policy carefully to understand how we process your
personal data. By providing your personal data to us or by using our services or this
website you are accepting or consenting to the practices in this Privacy Policy.
We may change this policy from time to time. The date this policy was last updated
is shown at the end of this document.
As a data controller, we fully comply with the Data Protection Act 2018, the Privacy
and Electronic Communications Regulations 2003 and the UK General Data
Protection Regulations (UKGDPR). We will also comply with all applicable clinical
confidentiality guidelines.
We are recorded on the ICO Data Protection Register under registration number
ZA762130.
2. Who we are.
In this policy references to Hatzola Edgware or Hatzola
are to First Floor, Mowbray House, 58-70 Edgware Wy, Edgware HA8 8DJ
The data controller is Hatzola Edgware Ltd.
3. What information we collect.
We collect personal information about you to enable us to provide the services or
fulfil a role with us. This may include:
• Name and address, marital status, family history and details of any lasting
powers of attorney.
• Email address and telephone numbers.
• The country you live in, your gender, date of birth, national insurance
number passport number and where relevant the language you speak.
• Details of your employment.
• The name and contact details of your next of kin. It is your responsibility to
ensure that if you provide us with any information about another person that
they are aware of the terms of this privacy policy.
• From your parent or guardian if you are under 16. This may include details of
any educational establishment you attend.
• Recordings of telephone calls or video calls we receive or make.
• Your photograph and photographs for care and treatment.
• CCTV recordings in our ambulance.
• Details of services and treatments you may have received from us.
• Reports or notes on your health or any treatment and care you have received
or need.
• Patient feedback and treatment outcome information you provide.
• Information about complaints and incidents.
• When you visit our website, we collect information about your IP address and
pages you visit. This does not tell us who you are or your address, unless you
choose to provide that information.
• Your payment information (e.g., credit card details) provided when you make
a payment to us.
• Information from patient surveys, promotions or competitions that you take
part in.
• The result of any DBS or anti-fraud checks we have made on you.
We will also collect Special category data – sometimes called sensitive personal
information. This includes:
• Information about your race, ethnic origin and religion.
• Information about your physical or mental health, genetic data or biometric
data.
• Information about your sex life or sexual orientation.
• Information about risk and safeguarding.
• Information about criminal offences.
4. How do we collect Personal Information?
We collect the personal information in the following ways:
• When you enquire about one of our services or treatments.
• When you provide information by filling in a form on registration or
information provided at any other time.
• When you correspond with us by email, phone or other ways.
• During the course of the provision of services to you.
• Contact us by email, telephone, social media or in any other way.
• When you visit our website.
• Fill in a form or survey for us.
• Information form emergency services, local authority and other public
organisations.
• Information from third parties including business partners, service providers,
technical sub-contractors, payment and delivery services, advertisers when
you have given permission to share it with us
• From publicly available services to keep your information up to date for
example the NHS national data base]
• When you participate in discussion forums or other social media on our site
or sites managed by us.
• When you take part in a social event.
• When you enter a competition, promotion or survey
5. Personal Information Provided by other Sources
We may collect personal data about you from other sources and these can include:
• From your next of kin or other family member.
• Provided by doctors, other clinicians and health care professional, hospitals,
clinics and other health care providers.
• Your employer when they provide information.
• Translators and interpreters.
• Any health professional or organisation who provides information for the
continuity of your care.
• Information from a Local Authority or the Police.
• Fraud and credit reference agencies and on DBS checks.
6. How we use the information and why we need it.
We use the personal information to provide the direct health services to individual
patients and services with others and to meet our contractual commitments to you.
This may include:
• Processing – this will include using the information to fulfil any request made
by you or someone on your behalf to receive one of our health or care
services, become a member, responder or volunteer, or renewing
membership]
• Contract – if we have a contract with you, we will process your personal
information to fulfil that contract.
• Consent – generally we will only ask for your consent to process your
personal information if there is no other legal ground to process. Where we
need your consent, we will ensure you are as fully informed as possible and
use that consent solely for the reason you have given it to us. You will be able
to change your mind at any time by contacting us at the address in paragraph
15. Any direct marketing email or text to you will have a link to let you do so.
• Public interest task – we will process your personal information when
carrying out the performance of a task in the public interest which includes
the provision of direct health care or social care. This also includes processing
personal information to train and educate health care professionals.
• Necessary for the purpose of preventative or occupational medicine – to
assess whether you are able to work, the provision to you of health or social
care, a medical diagnosis, or the management of health and social care
systems.
• Necessary to defend legal claims or a court action.
• Vital interests – where it is necessary to protect your vital interests or those
of another person.
• Employment – when necessary to fulfil our duties under employment law.
• Public interest – this is usually in line with any applicable laws such as
protecting against dishonesty, malpractice or other seriously improper
behaviour.
• Information you have made public.
• Marketing – in addition to processing we will use your personal information
to provide you with information about services you have requested or would
reasonably expect to receive from us. You will be able to change your mind at
any time and we will keep your preferences up to date. Any email or text to
you about marketing will have a link to let you unsubscribe.
• Profiling – we may make use of profiling and screening methods to provide a
better service to patients. Profiling helps us target resources more effectively
through gaining an insight into the background of patients and helping us
build relationships that are appropriate to their needs.
7. Legitimate interests
Hatzola Edgware also processes your data when it is in our legitimate interest to do
this and when these interests do not override your rights. These legitimate interests
include: –
• providing you with information on services, membership, fundraising,
competitions, campaigning, appeals and feedback.
• Keeping our records up to date.
• For statistical research and analysis and to enable us to monitor and improve
services.
• To monitor how we are meeting our clinical and non-clinical performance in
the case of health care providers.
• Sharing your personal information with people or organisations in order to
comply with any legal or regulatory obligations or to enable us to run our
organisation.
• To fulfil laws that apply to us and the third parties we work with.
• To take part in or be the subject of any merger.
• Managing our relationships with you and third parties who assist us to
provide the services to you.
8. Who will see the information?
Your information will only be accessible to our staff and only where it is appropriate
in respect of the role they are carrying out. We will never sell your information or let
other organisations use it for their own purposes.
We will only share your personal information:
• If consent is necessary, we will have taken your consent to us doing so and
will provide information for the specific reason your consent was given. You
will have the opportunity to withhold consent when you complete the form
on which we collect the data or you can do so by contacting us at the address
in paragraph 14, at any time.
• Doctors, clinicians, hospitals, clinics, diagnostic and treatment centres and
other health care providers to provide our services and continuity of health
care. This also includes processing personal information to train and educate
health care professionals.
• Your GP – where clinically necessary we may share your information with
your GP. You can ask us not to do so and we will respect this unless legally
required to provide the information. You should be aware it may be
detrimental to your health if your GP does not have your full medical history.
• First responders, ambulance service, safeguarding, undertakers, coroner and
care homes.
• Where it is necessary to protect your vital interest (i.e. your life or health)
• Other organisations you belong to confirm your entitlement to our services.
• Organisations or people who by law or regulations we must share your
personal information with. This can be national data bases, screening
registers government authorities and NHS organisations.
• The police or other law enforcement agencies to assist them perform their
duties if we must do this by law or under a court order.
• Where we use other organisations to provide services on our behalf for
processing, mailing, delivering, answering patients, members, responders
and supporters’ questions about services, sending mail and emails, data
analysis, assessment and profiling or processing credit/debit card payments.
• To organisations who you have requested us to supply information so that
they can provide services or products you have requested.
• To any organisation requesting a reference when you have applied for a
position with the organisation or to join the organisation in some capacity.
• Organisations providing IT systems, IT support and hosting in relation to IT
systems on which information is stored.
• When using auditors and professional advisors.
• When we are legally required to, or because of a lawful request by a
governmental or law enforcement authority.
• If we merge with another organisation or form a new entity,
Where a third-party data processor is used, we ensure they operate under a contract
which includes confidentiality and security of personal data and their obligations under the
Data Protection legislation.
9. Security.
The security of your personal information is very important to us. We protect all
personal data we hold and ensure we have appropriate organisational and technical
measures in place to prevent unauthorised access or unlawful processing of personal
data and to prevent data being lost, destroyed or damaged.
All information you provide to us is stored on our secure servers. Where we have given
you (or where you have chosen) a password which enables you to access certain parts
of our site, you are responsible for keeping this password confidential. We ask you not
to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely
secure. Although we will do our best to protect your personal data, we cannot
guarantee the security of your data transmitted to our site; any transmission is at your
own risk. Once we have received your information, we will use strict procedures and
security features to try to prevent unauthorised access.
All the personal data is processed in the UK however for IT hosting and maintenance
your information may be situated outside the European Economic Area (EEA).
You might find links to third party websites on our website. These websites should
have their own privacy policies, which you should check. We do not accept any
responsibility or liability for their policies whatsoever as we have no control over
them.
10. Your rights.
You have the following rights:
• Transparency over how we use your personal information (right to be
informed).
• To request a copy of the personal information we hold about you, which will
be provided to you within one month (right of access).
• An update or amendment of the personal information we hold about you (right
of rectification).
• To ask us to stop using personal information (right to restrict processing).
• Ask us to remove your personal information from our records (right to be
forgotten).
• Request us to remove your personal information for marketing purposes (right
to object).
• To obtain and reuse your personal data for your own purposes (right to
portability).
• Not to be subject to a decision based on automated processing.
You can contact to us about any of these rights at the address in paragraph 14. To
protect your privacy, we may ask you to prove your identity before we agree to respond to
any request. There is no charge for a request, and we will respond to the request within one
month.
If you are not satisfied with the way in which we deal with your request, you can contact the
Information Commissioners Office on 0303 123 1113 or at their website www.ico.org.uk.
11. Cookies.
Our website uses cookies to distinguish you from other users of our website. This helps
us to provide you with a good experience when you browse our website and allows us
to improve our site. By continuing to browse the site, you are agreeing to our use of
cookies.
A cookie is a small file of letters and numbers that we store on your browser or the
hard drive of your computer if you agree. Cookies contain information that is
transferred to your computer’s hard drive.
We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the
operation of our website. They include, for example, cookies that enable you
to log into secure areas of our website, use a shopping cart or make use of e-
billing services.
• Analytical/performance cookies. These allow us to recognise and count the
number of visitors and to see how visitors move around our website when they
are using it. This helps us to improve the way our website works, for example,
by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our
website. This enables us to personalise our content for you, greet you by name
and remember your preferences (for example, your choice of language or
region).
• Targeting cookies. These cookies record your visit to our website, the pages
you have visited and the links you have followed. We will use this information
to make our website and the advertising displayed on it more relevant to your
interests. We may also share this information with third parties for this
purpose.
12. Retention of information.
We hold your information only for as long as necessary for each purpose we use it.
We use the following guidelines: –
• Any time limits set by law or recommended by regulators professional bodies
or associations.
• Time limits for making a claim.
• For as long as we have a reasonable need for managing our relationship with
you or running our organisation.
13. CCTV
Our premises and ambulance are monitored by CCTV for the safety of patient’s,
visitors and staff.
14. NATIONAL OPT-OUT
Whenever you use a health or care service, important information about you is
collected in a patient record. Collecting this information helps to ensure you get the
best possible care and treatment.
The information collected about you when you use these services can also be provided
to other organisations for purposes beyond your individual care, for instance to help
with:
• improving the quality and standards of care provided
• research into the development of new treatments
• preventing illness and diseases
• monitoring safety
• planning services
Most of the time, anonymised data is used for research and planning so that you
cannot be identified in which case your confidential patient information is not needed.
Sometimes, for research and planning your confidential patient information will be
needed. You have a choice about whether you want your confidential patient
information to be used in this way. If you are happy with this use of your information
you do not need to do anything. If you do not wish your information to be used, you
can opt out. If you do choose to opt out your confidential patient information will still
be used to support your individual care.
To find out more please visit www.nhs.uk/your-nhs-data-matters. On this web page
you will:
• See what is meant by confidential patient information
• Find examples of when confidential patient information is used for individual
care and examples of when it is used for purposes beyond individual care
• Find out more about the benefits of sharing data
• Understand more about who uses the data
• Find out how your data is protected
• Be able to access the system to view, set or change your opt-out setting
• Find the contact telephone number if you want to know any more or to
set/change your opt-out by phone
• See the situations where the opt-out will not apply
If you wish to register your choice to opt out with Hatzola, please contact us at the
address in paragraph [15].
You can change your mind about your choice at any time.
Our organisation is compliant with the national data opt-out policy.
15. How to contact us.
If you have any questions about this privacy policy or your rights regarding processing
your personal information, or wish to make a complaint please contact:
Hatzola Edgware, First Floor, Mowbray House, 58-70 Edgware Way, Edgware HA8 8DJ