Who we are

Our website address is: https://www.londonspine.com.

This Privacy Policy explains what London Spine Unit Limited do with your personal data, whether we are providing you with a service or you are visiting our website.

This privacy policy describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you.

This privacy policy applies to the personal data of our Prospective Employees, Website Users, Clients and Suppliers.

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), the company responsible for your personal data is (“London Spine Unit Limited” or “us”).

1. WHAT KIND OF PERSONAL DATA DO WE COLLECT?

Clients:

In order to provide the best possible service to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you.

Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to offer you employment opportunities which are relevant to you. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions:

• Name;
• Age/date of birth;
• Sex/gender;
• Photograph;
• Marital status;
• Contact details;
• Employment history;
• Emergency contacts and details of any dependants;
• NHS number;
• Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information;
• Extra information that you choose to tell us;
• IP address;
• The dates, times and frequency with which you access our services; and
• CCTV footage if you attend our premises.

*Please note that the above list of categories of personal data we may collect is not exhaustive.

Suppliers:

Usually all we require is contact details of relevant individuals who have expressed an interest in the services that we provide and that the supplier has obtained appropriate consent for their details to be shared with us.

Website Users:

We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular.

Prospective Employees:

In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you.

Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to offer you employment opportunities which are relevant to you. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions:

• Name;
• Age/date of birth;
• Sex/gender;
• Photograph;
• Marital status;
• Contact details;
• Education details;
• Employment history;
• Emergency contacts and details of any dependants;
• Referee details;
• Immigration status (whether you need a work permit);
• Nationality/citizenship/place of birth;
• A copy of your driving licence and/or passport/identity card;
• Financial information (where we need to carry out financial background checks);
• National Insurance number;
• Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information;
• Details of any criminal convictions if this is required for a role that you are interested in applying for;
• Details about your current remuneration, pensions and benefits arrangements;
• Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website;
• Extra information that you choose to tell us;
• Extra information that your referees chooses to tell us about you;
• Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites;
• IP address;
• The dates, times and frequency with which you access our services; and
• CCTV footage if you attend our premises.

*Please note that the above list of categories of personal data we may collect is not exhaustive.

Other Users, such as Referees and Emergency Contacts:

In order to provide Candidates and Staff with suitable employment opportunities, we require some basic background information (such as name, email address and telephone number). We only ask for very basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our Candidates or Staff members.

2. HOW DO WE COLLECT YOUR PERSONAL DATA?

Clients:

We collect personal data in two ways:

• Personal data that we receive directly from you;
• Personal data that we receive from suppliers

Personal Data That We Receive Directly From You

We will receive data directly from you in two ways:

• Where you contact us proactively, usually by phone, website form fill or email; and/or
• Where we contact you, either by phone or email.

Personal Data That We Receive From Suppliers

We will receive data directly from suppliers in one ways:

• Using London Spine Unit Limited’s secure web services;

Website Users:

We collect your data automatically via cookies when you visit our website, in line with cookie settings in your browser. When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via the website.

Prospective Employees:

There are two main ways in which we collect your personal data:

• Directly from you; and
• From third parties

Via the below methods:

• Personal data that you, the Prospective Employee has given to us;
• Personal data that we collect automatically.

Personal Data You Give To Us

There are numerous ways you can share your information with us. It all depends on what suits you. These may include

• Entering your details on the London Spine Unit Limited website;
• Emailing your CV to London Spine Unit Limited;
• Applying for jobs through a job boards; which London Spine Unit Limited use to advertise their roles Personal data we receive from other sources We also receive personal data about Prospective Employees from other sources. Depending on the relevant circumstances, these may include personal data received in the following situations:
• Your referees may disclose personal information about you;
• We may obtain information about you from searching for potential Prospective Employees from third party sources, such as LinkedIn and other job sites;
• If you ‘like’ our page on Facebook or ‘follow’ us on Twitter we will receive your personal information from those sites; and
• If you were referred to us through an RPO or an MSP supplier, they may share personal information about you with us.

Personal Data We Collect Automatically

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.

Prospective Employee:

There are two main ways in which we collect your personal data:

• Directly from you; and
• From third parties (e.g. our Candidates) and other limited sources (e.g. online and offline media).

3. HOW DO WE USE YOUR PERSONAL DATA?

Clients:

The main reason for using your personal details is to help inform you of the services that we provide and to provide said service that may be suitable for you. The more information we have about you, your circumstances and your medical history, the more we can tailor our services to your requirements. We may also use your personal data for things like marketing, profiling and diversity monitoring. Where appropriate, we will seek your consent to undertake some of these activities.

We generally use Client data in three ways:

• Provision of Products & Services;
• Marketing Activities; and
• To help us to establish, exercise or defend legal claims.

Provision of Products & Services

Our main area of work is to provide cosmetic surgery and treatment procedures in the UK. We’ve listed below various ways in which we may use and process your personal data for this purpose.

• Collecting your data from you and other sources;
• Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to procedures of interest;
• Providing you with our services and to facilitate the delivery of those services;
• Assessing data about you for procedures which we think may be suitable for you;
• Carrying out our obligations arising from any contracts entered into between us;
• Carrying out our obligations arising from any contracts entered into between London Spine Unit Limited and third parties in relation to your procedures;
• Facilitating our payroll and invoicing processes;
• Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; and
• Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.

*Please note that this list is not exhaustive.

Marketing Activities

We may periodically send you information that we think you may find interesting. In particular, we may wish to use your data for the purposes listed below to:

• enable us to develop and market other products and services;
• market our full range of procedures to you;

*Please note that this list is not exhaustive.

We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in or soft-opt-in.

Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a form fill on our website), and we are marketing other procedure-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other procedures complementary to you alongside the specific one you enquired for. For other types of e-marketing, we are required to obtain your explicit consent.

4. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice, where there is a legal requirement, or in performance of our contractual requirements.

Our clinic is based at The Harley Street Hospital so we share your information with The Harley Street Hospital https://theharleystreethospital.co.uk

Service Delivery, Legal & Regulatory

• Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
• Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as surgeons, hospitals, anaesthetists, lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
• Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
• Regulatory bodies and suppliers;

5. HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.

If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately.

6.HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

Clients:

How long we retain personal data depends on if the client has entered into a contract, the type of procedure contracted for and the level of recent substantial contact with or from the client.

When we refer to “substantial contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. We will also consider it substantial contact if you communicate with us about a procedure, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as substantial contact – this will only occur in cases where you click-through or reply directly.

• Attended Procedures or Goods Purchased

In the event of a contract for procedure(s) existing we will delete your personal data from our systems if the last transaction date (appointment, payment or procedure) in relation to the contract is over 10 years old for surgical procedures or 8 years for treatment procedures and we have not had substantial contact with you for a period of one year.

• Attended Consultation Only

In the event of a client having only attended for a consultation(s) in relation to the services we provide we will delete your personal data from our systems if the last consultation date is over 2 years old and we have not had substantial contact with you for a period of one year.

• Expression of Interest Only

In the event of a client having only expressed an interest in our services and not attended any appointments in relation to the services we provide we will delete your personal data from our systems if the last substantial contact with is not within a period of one year.

We will delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.

• Prospective Employees:

We will delete your personal data from our systems if you have not been successful in your application after a period of 6 months from the date of your application.

7. HOW CAN YOU ACCESS, AMEND OR WITHDRAW THE PERSONAL DATA THAT WE STORE?

GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy.

This means that you retain various rights in respect of your data, even once you have given it to us. As detailed below.

To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled).

*Please note that we may keep a record of your communications to help us resolve any issues which you raise.

Right to Object:

• If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
• This right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
• The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our Website Users and Clients. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
  • We can show that we have compelling legitimate grounds for processing which overrides your interests; or
  • We are processing your data for the establishment, exercise or defence of a legal claim.
    • If your objection relates to direct marketing, we must act on your objection by ceasing this activity.

Right to Withdraw Consent:

Where we have obtained your consent to process your personal data for certain activities (for example, for the provision of a procedure), or consent to market to you, you may withdraw your consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.

Data Access Requests:

You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.

Right to Remove:

In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “remove” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.

Normally, the information must meet one of the following criteria:

• the data is no longer necessary for the purpose for which we originally collected and/or processed them;
• where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
• the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
• it is necessary for the data to be deleted in order for us to comply with our legal obligations as a data controller; or
• if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

We would only be entitled to refuse to comply with your request for one of the following reasons:

• to exercise the right of freedom of expression and information;
• to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
• for public health reasons in the public interest;
• for archival, research or statistical purposes; or
• to exercise or defend a legal claim.

When complying with a valid request for the removal of data we will take all reasonably practicable steps to delete the relevant data. If we have shared your personal data with third parties, we will notify them about the request for the removal of data unless this is impossible or involves disproportionate effort.

Right to Restrict Processing:

You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.

The circumstances in which you are entitled to request that we restrict the processing of your personal data are:

• where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
• where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
• where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
• where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.

If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

Right to Rectification:

You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

8. OUR LEGAL BASES FOR PROCESSING YOUR DATA

We use three of the legal bases set out in GDPR.

Contract:

Article 6 (1) (b) of the GDPR says that we can process your data where it “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”. In plain language, this will apply if:

• you attend an appointment with us;
• purchase goods from our online shop;
• agree to proceed with services provided by us.

Legitimate Interests:

Article 6 (1) (f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”

We don’t think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service, so everyone’s a winner! However, you do have the right to object to us processing your personal data on this basis.

Consent:

In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent. Typically we would seek consent prior to the end of the legitimate interest period in order to continue processing data for direct marketing purposes.

Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” In plain language, this means that:

• you have to give us your consent freely, without us putting you under any type of pressure;
• you have to know what you are consenting to – so we’ll make sure we give you enough information;
• you should have control over which processing activities you consent to and which you don’t. We provide these finer controls within our privacy preference centre; and
• you need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.

We will keep records of the consents that you have given in this way.

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding consenting to receive marketing materials. For more information in relation to your jurisdiction, please click here.

As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found here.

9. WHAT ARE COOKIES AND HOW DO WE USE THEM?

A “cookie” is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.

If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.

Most web browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some, or reject cookies in your browser’s privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.

Cookies can also be categorised as follows:

• Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
• Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
• Functionality cookies: These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.

10. KEEPING INFORMATION SECURE

We invest significant resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and so we cannot be held responsible for unauthorised or unintended access that is beyond our control.

11.COMPLAINTS PROCESS

If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint.

12. TERMS OF USE

This Privacy Policy governs the ways in which we collect and use information about you through the Site. For the terms and conditions which apply to your use of this Site, please refer to the Terms of Use.

13. UPDATES

We keep this Policy under regular review and update it from time to time. Please review this policy periodically for changes.

If you do not accept the amended Policy, please stop using this Site.

14. CONTACT

If you have any questions about this Policy, or would like to exercise your rights with respect to your personal information, please contact our Data Protection Officer (DPO) via medsec@londonspine.com or contact us on 0844 589 2020.

Please note we will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others, or have your permission to do so.

Sensitive Information. Because email communications are not always secure, please do not include credit card or other sensitive Data (such as racial or ethnic origin, political opinions, religion, health, or the like) in your emails to us.