Privacy & Security

Smarta Healthcare understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits: www.smartahealthcare.co.uk and http://www.smartapharmacy.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.  Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of our site and the services we offer.  You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

Definitions and Interpretation
In this Policy the following terms shall have the following meanings:

What Does This Policy Cover?

This Privacy Policy applies only to your use of our site. Our site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

• Your Rights
• As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
• The right to be informed about Our collection and use of personal data
• The right of access to the personal data
• The right to rectification if any personal data We hold about you is inaccurate or incomplete
• The right to be forgotten – i.e. the right to ask us to delete any personal data.  We hold about you (We only hold your personal data for a limited time
• The right to restrict (i.e. prevent) the processing of your personal data
• The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation)
• The right to object to Us using your personal data for particular purpose
• Rights with respect to automated decision making and profiling

If you have any cause for complaint about our use of your personal data, please contact us using the details provided and we will do our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

What Data Do We Collect?
We process your personal data as listed below from other pharmacy and health care services we provide to you (including, for example, pharmacy medicines, medicine use reviews, flu vaccinations and stop smoking services) for the purposes of:

Your Care
Providing pharmacy services and care to you and, as appropriate, sharing your information with your GP and others in the wider NHS;

Our Payments
Sharing your information with the NHS Business Services Authority, others in the wider NHS, and sometimes Local Authorities, and only limited information to those external to the NHS who negotiate and check the accuracy of our payments; and,

Management
Sharing only limited information with the NHS Business Services Authority and others in the wider NHS, and sometimes Local Authorities; as well as those external to the NHS who ensure we maintain appropriate professional and service standards and that your declarations and ours are accurate.

We hold your information for as long as advised by the NHS. You have a right to a copy of the information we hold about you, generally without charge. You may seek to correct any inaccurate information.  We may collect some or all of the following personal data.

1. name;
2. date of birth;
3. gender;
4. business/company name
5. job title;
6. profession;
7. contact information such as email addresses and telephone numbers;
8. NHS number,
9. Your doctor surgery and healthcare information such as Pharmacy medicines, Medicine Use Reviews

How Do We Use Your Data?
We process your personal data in the performance of a task in the public interest, for the provision of healthcare and treatment and the management of healthcare systems.  A pharmacist is responsible for the confidentiality of your information. You may object to us holding your information. You may also lodge a complaint with the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Please contact us if you require more information.

• All personal data is processed and stored securely, for no longer than is necessary as advised by the NHS. We will comply with our obligations and safeguard your rights under the GDPR at all times.
• Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
• Providing and managing your account;
• Providing and managing your access to our site;
• Personalising and tailoring your experience on our site;
• Supplying products and healthcare services to you
• Personalising and tailoring Our products and services for you;
• Replying to emails from you;
• Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time
• With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
• You have the right to withdraw your consent to us using your personal data at any time.  You may seek to correct any inaccurate information

How and Where Do We Store Your Data?
We only keep your personal data for as long as we need to in order to use it as described above and/or for as long as we have your permission to keep it.

• Your data may be within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Data security is very important to Us, and to protect your data we have taken suitable measures to safeguard and secure data collected through Our Site.
• Steps We take to secure and protect your data include:
• Information collected through the website is stored with our trusted web hosted company based in UK.
• All pages use SSL certifcate

Do We Share Your Data?

• In certain circumstances, We may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
• We may share your data with other third party health and social care professionals for purpose of providing advice and health and social for our patients.
• We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
• We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
• The third party data processors used by us and listed with in EEA. We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR
• In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

What Happens If Our Business Changes Hands?

• We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
• In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.

How Can You Control Your Data?

• In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
• You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

Your Right to Withhold Information

• You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
• You may restrict Our use of Cookies. For more information, see section 13 and Our Cookie Policy .

How Can You Access Your Data

You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact us for more details at services@localhost.

Our Use of Cookies

• Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
• All Cookies used by and on Our Site are used in accordance with current Cookie Law.
• Before Cookies are placed on your computer or device, you will be shown a requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.
• Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below, your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
• The following first party Cookies may be placed on your computer or device

Our Site uses analytics services provided by Google Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

1. The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
2. The analytics service(s) used by Our Site use(s) the following Cookies:

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.]

Telephone Recording System
The purpose of this policy is to govern the procedures for call recording within Smarta Healthcare and the management of access and use of telephone call recordings. The implementation of recording of telephone calls was agreed in order to support effective training and delivery of excellent customer service, and to enable Smarta Healthcare to deal efficiently with internal or external complaints.

The policy aims to minimise intrusion by restricting access to and use of recordings to limited and specified purposes only. This policy outlines:
* Recorded information
* Purposes of call recording
* Access and availability
* Information Security (incl Data Protection and Notification)
* Monitoring and review

Recorded Information
All calls received or made from nominated extensions will be recorded utilising the Ring Central call recording system and may be stored Ring Central servers for up to thirteen months.  Telephone calls currently included in the call recording scope are in the following services: Pharmacy Services Calls where the caller provides details of a payment card for the purpose of making a payment to Smarta Healthcare will only be recorded in-part to comply with Payment Card Industry Security Standards (PCiDSS).

Purpose of Call Recording
The purpose of call recording is to provide an exact record of the call which can: • help protect staff from abusive or nuisance calls; • establish the facts in the event of a complaint either by a customer or a member of staff and so assist in resolving it; • help identify staff training needs and to support training new and existing Officers; and • assist in the councils quality control to identify any issues in council processes, with a view to improving them. In addition, recordings may provide evidence for crime prevention purposes.

INTERNAL ACCESS AND AVAILABILITY
Access and playback of recordings will be carefully controlled as per the requirements of the Smarta Healthcare data protection policy. Only those with the appropriate authority can access calls. They are required to maintain a secure and private password, which is auditable and traceable within the software. Access to calls may be for a number of reasons. We anticipate that the three main reasons will be for checking accuracy, answering complaints, and for training to improve service and skills

They have been identified by a member of the Smarta Healthcare team as valuable for staff training. In this case the recording will be retained until it is no longer useful for this purpose.
Identified as evidence for the record-keeping requirements of the Smarta Healthcare procedure for dealing with unacceptable behaviour towards staff and unreasonably persistent complainants. Customers / callers have the right to listen to or have copies of recordings made of their own calls, requests for access need to be made via the Smarta Healthcare Subject Access Request (SAR) procedures. These recordings will be located by reference to the date and time of the call and the operator’s identity. Callers asking for the recordings of their calls will have to provide the reason for the request and enough information about date, time and operator to enable them to be found. Call Recording Policy All reasonable attempts will be made to confirm that the identity of the individual making the subject access request matches the identity of the caller. If in doubt the final decision will be made by Smarta Healthcare data protection officer. The data protection officer will also balance the privacy of the caller or HDC Officer with the rights of the individual making a subject access request when coming to a decision. A permanent copy of the recording will be provided in a format Smarta Healthcare can reasonably expect the enquirer will be able to use taking account of the individual’s preference (if any) and practicality and cost of preparation. Formats could include WAV, MP3 or other digital format, or a transcript Approval

This policy has been approved by the undersigned and will be reviewed at least annually.

Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at services@localhost by post at 5 Stephenson Court, Fraser Road, Priory Business Park, Bedford, MK44 3WJ. Please ensure that your query is clear, particularly if it is a request for information about the data. We hold about you.

Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.