User Privacy – Pharmacist

Detailed Wording and Content

Your privacy rights when you are a Pharmacist working with Healthera

The purpose of this notice is to explain how Healthera Limited collects and uses personal information and how we comply with data protection law. Where Healthera determines the reasons how we use your personal information and the means of processing your personal information, it is the data controller.

The Healthera Connect platform enables authorised Pharmacists to process repeat prescriptions, and requests for pharmacy services that have been ordered by their patients who are registered with the Healthera App. A secure messaging service is also provided so that Pharmacists can easily communicate with their patients.

In this notice, we explain some things about the personal information Healthera holds, and your rights regarding this information. It’s important that you read it carefully, together with any other privacy notices and information that we provide you, from time to time.

About your personal information and where we obtain it

What information do we use and where do we obtain it

We collect and receive different types of personal information about you, in order to enable us to administer your Healthera Connect account. Personal information we hold about you includes any information that identifies you (e.g. name, email address etc).

You can find more details about the type of information we hold about you in “What personal information we use and how long we keep it” below.

We will have been requested by your employer to send you a email to register you as a Healthera Connect user. As part of the registration process you provided us with some personal information about you.

Please note: The personal information you provide to us, as well as that we collect about you, is necessary for us to administer your Healthera Connect account and action your requests. Without it we may not be able to do so.

How we’ll use your personal information

Administration of your Healthera Connect account

In order to administer your Healthera Connect service we will use your personal information to:

• Create your Healthera Connect account
• Manage changes to your Connect account
• Communicate and interact with you in relation to your Connect account. This can be by phone, web messaging, SMS, email, post, secure email, app
• Provide you with support so that technical problems can be fixed
• Enable you to invite your patients to register for the Healthera App
• To access prescriptions requested by patients
• To access records of patient details entered by Healthera App users
• Facilitate the receipt and processing of repeat prescription’s for Healthera App users and their dependants, who are registered for the service by the Healthera App user
• Facilitate the receipt and processing of pharmacy services for Healthera App users and their dependants, who are registered for service by the Healthera App user
• Enable you to communicate with your patients via secure App messages
• Inform you about changes to the service
• Monitor your use of the messaging service
• Improve our service offering including through surveys and research activities
• Record your preferences for receiving notifications on new messages, new appointments, new repeat prescriptions and new patients registered
  
  

The lawful basis for processing is the performance of a contact with the pharmacy and necessity for our legitimate interests (e.g. to provide the Healthera App service, to provide the Healthera Connect service, to provide customer support, to troubleshoot problems etc)

Marketing activity

We’ll use your personal information to provide you with information about our services.

The lawful basis for processing is our legitimate interests (e.g. to inform you about changes to the service, how to use the service, etc)

Use of Cookies

If you use our website, you’ll see a message asking you to consent to the use of non-essential cookies, at your first visit. If you consent to the use of cookies, we’ll also use your personal information to monitor the traffic, security and performance of our website.

If you want more information about cookies we use or if you’d like to change your cookie settings, please go to our cookies policy page.

For research purposes

From time to time, Healthera may conduct research and surveys.  

We will use anonymisation techniques and aggregated datasets (so that personal data can no longer be associated with an individual) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

The lawful basis for processing is our legitimate interests (e.g. in order to help with improving our service and research into the quality of treatment.

What personal information we use and how long we keep it

Data we use

Forename, Surname, Login email address, IP address, Pharmacy name & address, messages, emails, Date of account creation. Date of account cancellation.

How long we keep it for   

We’ll keep your Healthera Connect account information for as long as you remain a user.

Messages and emails will be stored for 6 years after which they will be deleted.

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

Any other personal information not described above

Data we use

Any other personal information we collect, not described in any of the categories above will be brought to your attention with a message at the point of collection from you.

How long we keep it for

We’ll keep it for 6 years.

In addition, we may keep your personal information for a longer period of time than mentioned above for archiving or research purposes, or in the event of ongoing disputes, claims, complaints or data migration. In such cases, we’ll consider the nature, degree of sensitivity, and volume of your personal information that needs to be kept. We’ll also take into consideration the purpose for extending the retention period and whether this purpose could be achieved through other means.

Passing on your personal information to third parties

From time to time, we may need to pass your personal information to third parties. The third parties we may share information with are:

For Administration of your Healthera App account 

Most of our administration is carried out by Healthera staff in the UK.

In the course of providing Healthera services, we also use other processors such as:

• fax service providers operating in E.E.A
  
  

Where this occurs, Healthera requires sufficient guarantees that appropriate technical and organisational measures are in place with all processors and that their standard of security with regard to the processing of your personal information is satisfactory to Healthera.

In certain circumstances, we may need to disclose your personal information to other trusted third parties, who will receive it as controllers in their own right (such as auditors, consultants and legal advisers. In such cases, we will ensure that the appropriate contracts and safeguards are in place.

Supply of Medicines and Pharmacy services

When you use our Healthera Connect service we’ll need to share some of your personal information with GP’s and CCG’s as the named pharmacist processing a particular prescription of pharmacy service.

Third party processors for website analytics purposes

Healthera uses website analytics in order to provide valuable information and insight into the performance, security and use of our website. We also share information about your use of our site with those web analytics providers. You’ll find more information in our cookies policy.

From that page, you will also be able to manage your preferences and be able to opt in or out from cookies that are not essential to the operation of the website.

For compliance purposes 

In order to comply with our legal, regulatory and statutory obligations, sometimes we also need to pass your personal information to 3rd parties, such as the Department of Health, CCG, courts, law enforcement agencies, our insurers, our auditors, and our professional advisers.

Security and safe storage of your personal information

The security of your personal information is very important to us and we take this matter very seriously.  We’ll use appropriate procedures and security features to process and protect your information.  We have in place a robust framework to ensure the security of your data.

Transfers outside the European Economic Area (E.E.A)

Some of the organisations that we share your personal information with may process it overseas. If any sharing means that your personal information will be transferred outside the E.E.A, we will only make that transfer if:

• the country to which the personal information is to be transferred ensures an adequate level of protection for personal information
• we have put in place appropriate safeguards to protect your personal information, such as an appropriate contract (like the contract terms sometimes called Model Contract Clauses issued by the European Commission) with the recipient
• the transfer is necessary for one of the reasons specified in data protection law
• sometimes, we will request your consent to the transfer
  
  

How you can access and correct your personal information

How you can correct or rectify your personal information

In order to administer your Healthera Connect Account and enable you to utilise the available services, it is important that we have accurate and complete information about you.

You can correct the information we hold about you by logging into your Healthera Connect account, then selecting “edit your profile”.

We encourage you to notify us of any changes regarding your personal information, as mentioned just below.

You can also contact us at Healthera Limited , St John’s Innovation Centre, Cowley Road  Cambridge, United Kingdom CB4 0WS or email us at support@healthera.co.uk.

How you can access your personal information and exercise your rights

Subject to certain conditions, you have the right to request access to the personal information that we hold about you. This is commonly called a “data subject access request” or in its abbreviated form, a “DSAR”.

If possible, you should specify the type of information you would like to see to ensure that our disclosure meets your expectations. We must be able to verify your identity. Your request shall not impact the rights and freedoms of other people, e.g. privacy and confidentiality rights of other individuals.

In addition to your right to request access to or rectification of the personal information we hold about you, you’ll have the right, under certain circumstances, to make a request to:

• restrict or object to the processing of the personal information we hold about you (see Note1)
• erase your personal information (see Note1)
• receive personal information about you that you have provided to us in a structured, commonly used, machine-readable format where we use it with your consent (‘right to data portability’)(see Note2)
• withdraw your consent for us to process your personal information, where based on consent (see Note3)
  
  

Note1:  It is important to note that your request to restrict or object to processing, or erase your personal information doesn’t automatically lead to a requirement for the processing to stop, or for your personal information to be deleted. For instance, we may not be in a position to erase your personal data, if for example, we need it to (i) comply with a legal obligation, or (ii) exercise or defend legal claims.

Note2:  In addition, the right to data portability only applies in certain circumstances such as where the processing relies on consent.

Note3:  If you do decide to withdraw your consent we will stop processing your personal information for that purpose going forward, unless there is another lawful basis we rely on – in which case, we will let you know.

To make a request under these rights you can:

• write to us at  Healthera  Limited , St John’s Innovation Centre, Cowley Road  Cambridge, United Kingdom CB4 0WS   or
• email us at support@healthera.co.uk
  
  

Queries and further information
   

Further information

The information provided in this privacy notice is in addition to any other privacy information we may give you on this website or via other channels (paper communication, secure message, webchat, telephone etc.).

We may update this notice from time to time. We will keep updated you on material changes to this notice. We also encourage you to check this notice on a regular basis.

If you want more information about the use of cookies on the Healthera website or Healthera App, please view our cookies policy.

Contact us

If you want to contact us, you can

• write to us at Healthera  Limited, St John’s Innovation Centre, Cowley Road  Cambridge, United Kingdom CB4 0WS  
• email us at support@healthera.co.uk
• contact our data protection officer at dpo@healthera.co.uk
  
  

Raise a complaint with ICO          

If you have concerns about the way we handle your personal information and you think we haven’t dealt with them properly, you can contact the Information Commissioner’s Office or raise a complaint.

We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office so please contact us in the first instance.

The Information Commissioner’s Office can be contacted:

• by phone on +44 303 123 1113
• by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
• via their website at https://www.ico.org.uk/concerns
  
  

Last updated on 15 October 2018