Privacy policy
Introduction
Welcome to the privacy policy of Dr Philip Hu
We respect your privacy and are committed to protecting your personal data in accordance with our obligations under the General Data Protection Regulation ((EU) 2016/679)) and the Data Protection Act 2018 (referred to in this privacy policy as “Data Protection Law”).
This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how Data Protection Law protects you.
1. Important information and who we are.
Purpose of this privacy policy
This privacy policy aims to give you information on how Dr Philip Hu collects and processes your personal data when carrying out its services and functions.
Controller
Dr Philip Hu is the controller responsible for your personal data (referred to as “"we", "us" or "our" in this privacy policy).
Contact details
If you have any questions about this privacy policy, including any request to exercise your legal rights, please contact our Data Protection Officer (“DPO”), in the following ways:
Email address: Office@painmedicine.ie
Postal address: Suite A33, Beacon Court, Sandyford, D18 DR77
You have the right to make a complaint at any time to the Data Protection Commission, the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so we would ask that you please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes.
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, title, date of birth and gender.
Contact Data includes postal address, email address, telephone numbers and next-of-kin contact details.
Financial Data such as payment card details.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website, www.lifespantherapy.ie.
Special Categories of Personal Data is personal data of a particularly sensitive nature, and includes information concerning a person’s health, their sex life or sexual orientation, or their religious and philosophical beliefs. Due to the nature of our work, we may handle your health information and other special categories of personal data when carrying out our services and functions. For the purpose of this privacy policy, the types of personal data detailed in this paragraph are referred to as “Sensitive Data”.
Like all other types of personal data, we handle Sensitive Data only when we have a lawful basis for doing so (as described in more detail in section 4 below) and strictly in compliance with all of our obligations under Data Protection Law.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your personal data by engaging with us face-to-face or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
make an appointment with us;
attend a consultation with us;
give us feedback or contact us.
Third parties. We may receive personal data about you from certain third parties in circumstances including:
From your General Practitioner (“GP”) or other medical professional when they have referred you to us, or when we need information regarding any other health care, treatment or advice that has been provided to you so that we can carry out our services and functions.
From other third-party sources such as family members.
Where a person is engaging with our services, they may provide your personal data to us when receiving care, treatment or advice from us.
4. How we use your personal data
We will only use your personal data when we have a lawful basis for doing so, which means when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform a contract to deliver services to you.
Where we need to protect your vital interests or the vital interests of another person.
Where we need to comply with a legal obligation.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Most commonly, we will use your Sensitive Data in the following circumstances:
Where processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services.
Where we need to protect your vital interests or the vital interests of another person where you are physically or legally incapable of giving consent.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Purposes for which we will use your personal data
We may use your personal data for purposes including:
To verify your identity.
To create your medical file.
To arrange appointments with you and to contact you regarding appointments.
To provide the medical services that have been requested.
To attend consultations and carry out medical assessments.
To provide appropriate care, treatment and advice.
To make referrals to other medical professionals if we consider it to be necessary or appropriate.
To respond to queries and provide support.
5. Your personal data and third parties
We may share your personal data with third party service providers who perform services and functions at our direction and on our behalf. Such third-party services providers include administrative service providers, accountants, legal advisers, IT service providers, payment service providers and security services providers engaged by us.
We require all third parties to respect the confidentiality and security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes, and we only permit them to process your personal data for specified purposes and in accordance with our instructions.
It may be necessary or appropriate to refer you to other medical professionals for further care, treatment or advice and we may share your personal data with such other medical professionals for such purposes. It may also be necessary to provide your personal data to your referring practitioner so that they are fully aware of your treatment and can provide you with appropriate medical care.
We may share your personal data with these organisations and bodies where there is a serious concern regarding your vital interests or the vital interests of others, or where we are required to do so by law.
6. International transfers
We might transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as an area that provides for an equivalent level of protection for personal data as is provided for in the European Union. If, and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission. If you would like to receive further details of the measures that we have taken in this regard, please contact us at office@painmedicine.ie
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to only those who have a strict need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period if we have a legitimate interest in retaining such information that is not outweighed by your fundamental rights and freedoms, where we have statutory or regulatory obligations to retain personal data for a longer period, or where we may need to retain the information in the event of a legal claim.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
9. Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful, but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at the details set out above.
No fee usually required.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We 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. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Updates
We may update this privacy policy from time to time. Any updates will be made available and, where appropriate, notified to you.