Patient Data & Communications

This page explains, in clear and practical terms, how patient data is handled on the Healthera platform, including who is allowed to communicate with which patients and why.

Healthera powers pharmacy services across multiple channels: pharmacy-branded websites and apps, the Healthera app, and third-party referral partners (such as myGP, eConsult, and Uber). Because patients can originate through different routes, the data-controller relationship is not the same in every case. This usually aligns with the service or brand the patient feels they are dealing with when accessing care.

This policy exists to remove ambiguity for pharmacies and to protect patients from inappropriate or unlawful contact.

This policy should be read alongside:

• Healthera Privacy Policy
• Healthera Pharmacy Terms & Conditions

Pharmacies communicate with patients where they are the data controller for the relevant relationship and are responsible for the associated patient data. This includes patients who use the pharmacy’s own branded website or app, or who have explicitly selected the pharmacy as their primary pharmacy.

In these situations, pharmacies may contact patients as part of normal pharmacy care and service delivery, in line with consent and legal requirements.

Where a patient is referred to a pharmacy by Healthera, or originates through a third-party platform such as myGP or eConsult, the pharmacy’s role is limited to fulfilling the specific order or service requested. Contact with the patient is therefore limited to what is necessary to complete that service and does not extend to marketing or unrelated communications.

Data controller status is determined by how a patient accesses services and care through Healthera’s platform, and by the context in which their data is processed.

A patient’s prior offline relationship with a pharmacy does not, on its own, determine the controller relationship for services accessed through the platform.

Who controls the data: Pharmacy
Healthera role: Data processor

Permitted pharmacy communications:

• Prescription and order updates
• Service notifications
• Health advice and promotions (where consent exists)
• Direct messaging via the platform

Not permitted:

• None beyond standard GDPR restrictions

Who controls the data: Pharmacy
Healthera role: Data processor

Permitted pharmacy communications:

• As per pharmacy-branded website
• Push notifications and in-app messages
• Loyalty and location-based communications (with consent)

Not permitted:

• None beyond standard GDPR restrictions

These are patients who use the Healthera app and explicitly select or are invited by a pharmacy.

Controller relationship

Healthera and the selected pharmacy act as joint data controllers, with clearly defined and limited roles:

• The selected pharmacy is the data controller for:
  • the ongoing pharmacy-patient relationship
  • NHS prescription supply and dispensing
  • pharmacy-specific services and communications
• Healthera is the data controller for:
  • operating the Healthera platform
  • prioritising the selected pharmacy’s content and services
  • enabling access to additional optional services available through the Healthera network

Where a patient chooses to use optional services provided by other pharmacies, those pharmacies act only as data processors for the specific transaction, on Healthera’s instructions, and do not acquire an ongoing patient relationship.

Permitted pharmacy communications (selected pharmacy only):

• Prescription, order, and service-related updates
• Promotional or service communications only where enabled and consented

Important limits and clarifications:

• The selected pharmacy is the exclusive supplier of prescriptions unless the patient actively changes their nominated pharmacy
• Other pharmacies do not obtain an independent patient relationship through optional services (for example, where a patient uses the Healthera website to book a service from another pharmacy)

This includes patients who place an order or book a service through:

• the Healthera app without having designated a permanent nominated pharmacy on the app or the Healthera website

Controller relationship: Healthera is the data controller for the patient relationship and referral process. The pharmacy acts as an independent data controller solely for the purpose of fulfilling the specific order or service.

The pharmacy receives patient data solely to fulfil the specific order or service.

Permitted pharmacy communications:

• Order status updates
• Queries strictly necessary to complete the order or service

Explicitly NOT permitted:

• Marketing or promotional messages
• Invitations to transfer pharmacies
• Contact about unrelated services
• Adding the patient to mailing lists or CRM systems

Contacting these patients outside the scope of the order constitutes unauthorised data processing under GDPR and may result in enforcement action.

This includes patients who place an order through:

• Third-party integrations (for example myGP, eConsult, or Uber)

Controller relationship: The Third Party is the data controller for the patient relationship and referral process. Healthera is the data processor that acts as the technology provider to route the patient’s order to a pharmacy. The pharmacy acts as an independent data controller solely for the purpose of fulfilling the specific order or service.

The pharmacy receives patient data solely to fulfil the specific order or service.

Permitted pharmacy communications:

• Order status updates
• Queries strictly necessary to complete the order or service

Explicitly NOT permitted:

• Marketing or promotional messages
• Invitations to transfer pharmacies
• Contact about unrelated services
• Adding the patient to mailing lists or CRM systems

Attempting to contact these patients outside the scope of the order may constitute a reportable data breach.

These are patients added by pharmacies for operational purposes, typically to automate prescription ordering for patients who have an existing offline relationship with the pharmacy.

Lawful basis: The pharmacy must have obtained appropriate consent or have a legitimate interest (for example continuity of care for regular repeat prescription patients).

Important: Adding a patient to digital services does not automatically create consent for marketing communications. Enhanced consent is required for promotional content.

Who controls the data: Pharmacy
Healthera role: Processor

Permitted pharmacy communications:

• Prescription automation notifications
• Service interruption or safety notices
• Invitations to take control of their account

Not permitted:

• Promotional or non-essential communications without explicit consent

For Categories A, B, F (pharmacy-controlled patients):

• Healthera acts as a data processor and sends communications only on the pharmacy's behalf or as essential platform notifications.

For Categories C, D (Healthera platform patients), Healthera may send:

• Service updates about platform features
• Health service recommendations available through the platform
• Promotional content prioritising the patient’s preferred pharmacy (with appropriate consent)

Regardless of patient type, Healthera may contact patients for:

• Transactional emails (although this will be branded to the pharmacy where the pharmacy is the data controller)
• Essential service notifications
• Platform functionality and safety updates
• Customer support responses

Healthera does not sell or permit cross-pharmacy marketing of patient data.

Pharmacies are contractually required to:

• respect patient origination and controller boundaries
• limit communications to their lawful role
• follow Healthera guidance on data use

Breaches may result in:

• suspension of messaging privileges
• contractual remedies
• regulatory reporting where required

If you are unsure whether a patient can be contacted, assume they cannot, and contact Healthera support for clarification before taking action. This protects patient and pharmacy privacy.

When pharmacy services end or change, patient data may be exported only where this is necessary to support continuity of care and where the pharmacy is acting as the patient’s data controller.

• Pharmacies may export patient data for dispensing, ongoing care, system migration, or regulatory record-keeping where they are the primary data controllers for that patient (Categories A/B/F).
• Where a pharmacy’s involvement was limited to fulfilment of a specific order or service (Categories D/E), data must be used only for that purpose and not retained or reused beyond it.
• Exporting data does not create additional rights to contact patients or establish new services outside the original scope of care.

Patients may withdraw consent for communications at any time by:

• Using unsubscribe links in emails
• Adjusting preferences in their account settings
• Contacting the pharmacy or Healthera directly

When a patient withdraws consent:

• The pharmacy must immediately cease marketing communications
• The patient's data may still be retained for regulatory or clinical purposes
• Transactional communications (for example prescription ready notifications) may continue under legitimate interest