GenderCare

1. INTRODUCTION

This privacy notice provides you with details of how I collect and process your personal data within my part of GenderCare.

By providing your data, you warrant to me that you are over 13 years of age. Note that I do not accept patients who are under 18.
  
I am the data controller and am responsible for your personal data (referred to as “I”, “me” or “my” in this privacy notice).

Contact Details

My full details are:

Dr Stuart Lorimer (in GenderCare)
drlorimer@gendercare.co.uk
Box 39
101 Clapham High Street
Clapham
London
SW4 7TB
    
It is very important that the information I hold about you is accurate and up to date. Please let me know if at any time your personal information changes by emailing me at drlorimer@gendercare.co.uk

2. WHAT DATA DO I COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND I PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymised data.

I may process the following categories of personal data about you:

• Communication Data that includes any communication that you send to me whether that be through email, text, social media messaging, social media posting or any other communication that you send me. I process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. My lawful ground for this processing is my legitimate interests which in this case are to reply to communications sent to me, to keep records and to establish, pursue or defend legal claims.
  
  
• Customer Data that includes data relating to any purchases of services such as your name, title, postal address email address, 'phone number, contact details, purchase details and your bank transfer or PayPal details. I process this data to supply the services you have purchased and to keep records of such transactions. My lawful ground for this processing is the performance of a contract between you and I and/or taking steps at your request to enter into such a contract.
  
  
• User Data that includes data about how you use the GenderCare website. I process this data to operate the website and ensure relevant content is provided to you, to ensure the security of the website, to maintain back-ups of the website and/or databases and to enable publication and administration of the website. My lawful ground for this processing is my legitimate interests which in this case are to enable me to properly administer the GenderCare website.
  
  
• Technical Data that includes data about your use of the GenderCare website such as your IP address, details about your browser, length of visit to pages on the website, page views and navigation paths, details about the number of times you use the website, time zone settings and other technology on the devices you use to access our website. The source of this data is from the analytics tracking system. I process this data to analyse your use of the website, to administer and protect the website and to deliver relevant website content to you. My lawful ground for this processing is my legitimate interests which in this case are to enable me to properly administer the website and our business and to grow GenderCare and to decide any overall expansion strategy.

Sensitive Data

Where specifically relevant, I may need to collect the following sensitive data about you in order to assess and meet your gender related needs:

Data concerning health
Data concerning sex life or sexual orientation
Data consisting of racial or ethnic origin
Data concerning religious or philosophical beliefs

I require your explicit consent for processing sensitive data, so when you submit your details, I will send you a further communication asking you to confirm your consent to this processing.

Where I am required to collect personal data under law or under the terms of the contract between us and you do not provide me with that data when requested, I may not be able to perform the contract (for example, to provide services to you). If you don't provide me with the requested data, I may have to cancel a service you have purchased but if I do, I will notify you at the time.

I will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary (for example, if I have to forward your details to another medical provider). For more information on this please email me at drlorimer@gendercare.co.uk. In case I need to use your details for an unrelated new purpose I will let you know and explain the legal grounds for processing.

I may process your personal data without your knowledge or consent where this is required or permitted by law.

I do not carry out automated decision making or any type of automated profiling.

3. HOW I COLLECT YOUR PERSONAL DATA

I may collect data about you by you providing the data directly to us (for example by completing a paper form or sending me emails). We may automatically collect certain statistical data from you as you use our website but no cookies are collected.

I may receive data from third parties such as your GP if they make a formal referral to me, or from other clinical colleagues.

4. DISCLOSURES OF YOUR PERSONAL DATA

I may have to share your personal data with the parties set out below:

• Colleagues within GenderCare, for example if second opinions or further discussion is needed,
  
  
• Other clinical providers, for example your GP or medical colleagues who provide endocrine, surgical, speech and language or psychological input,
  
  
• Administrative staff, for example my personal assistant(s) or receptionists at the locations of my clinics,
  
  
• Service providers who provide IT and system administration services.

I require all third parties to whom I transfer your data to respect the security of your personal data and to treat it in accordance with the law. I only allow such third parties to process your personal data for specified purposes and in accordance with my instructions.

5. INTERNATIONAL TRANSFERS

I am subject to the provisions of the General Data Protection Regulations that protect your personal data. Where I transfer your data to third parties outside of the EEA (for example, surgical providers based in other countries), I will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

• I may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
  
  
• If I use US-based providers that are part of EU-US Privacy Shield, I may transfer data to them, as they have equivalent safeguards in place; or
  
  
• Where I use certain service providers who are established outside of the EEA, I may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission, which give personal data the same protection it has in Europe.

If none of the above safeguards is available, I may request your explicit consent to the specific transfer of data. You will have the right to withdraw this consent at any time.

6. DATA SECURITY

I have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. I also allow access to your personal data only to those employees and partners who have a specific need to know such data. They will only process your personal data on my instructions and they must keep it confidential.

I have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if I am legally required to.

7. DATA RETENTION

I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for I look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires me to keep basic information about my clients (including Contact, Identity, Financial and Transaction Data) for six years after they stop being clients.

In almost all circumstances I would anonymise your personal data for research or statistical purposes in which case I may use this information indefinitely without further notice to you.

8. YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email me at drlorimer@gendercare.co.uk.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or refuse to comply with your request in these circumstances.
  
I may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up my response.
  
I try to respond to all legitimate data requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you.

If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would be grateful if you would contact me first if you do have a complaint so that I can try to resolve it for you.

9. THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and am not responsible for their privacy statements. When you leave the GenderCare website, I encourage you to read the privacy notice of every website you visit.

10. COOKIES