Last Updated: 25/05/2018
Our privacy notice describes the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the requirements of the General Data Protection Regulation (GDPR).
We take privacy seriously and you can find out more here about your privacy rights and how we gather, use and share your personal information – that includes the personal information we already hold about you now and the further personal information we might collect about you either from you or from a third party. How we use your personal information will depend on the products and services we provide to you.
Our Data Protection Officer (DPO) provides help and guidance to make sure we apply the best standards to protecting your information. Our DPO can be reached by post at Lynstock House, Lynstock Way, Bolton, BL6 4SA or by e-mail on GDPR@cohenschemist.co.uk if you have any questions about how we use your personal information.
This privacy notice provides up to data information about how we use your personal information and will replace any previous information we have given you about using your personal information. If we make any changes affecting how we use your personal information, we will update on the date displayed at the top of this webpage, so please check back regularly for updates. Our website will always show the most up to date version of our privacy notice.
We are a controller of personal information we gather and use. When we say we or us in this privacy notice we mean the companies Gorgemead Limited, Prinwest Limited, Mantle Property Services Limited and Medihealth Northern Limited. These companies are all registered with the data protection supervisory authority, The Information Commissioners Office (ICO) as data controllers.
Your privacy rights
You have the right to object to how we use your personal information. You also have the right to see what personal information we hold about you, to ask us to correct any inaccuracies and to ask for some of your personal information to be provided to someone else. In addition, when permitted by law, you can ask us to delete or restrict personal information we hold about you.
To exercise any of your rights in relation to your personal information, please contact our DPO by post at Lynstock House, Lynstock Way, Bolton, BL6 4SA or by e-mail on GDPR@cohenschemist.co.uk
You can contact our DPO to exercise any of your other privacy rights as follows:
- Right to object – you can object to our processing of your personal information by providing details of your objection to the DPO
- Access to your personal information – you can request access to a copy of your personal information that we hold, along with information on what personal information we use, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge by contacting our DPO by post at Lynstock House, Lynstock Way, Bolton, BL6 4SA or by e-mail on GDPR@cohenschemist.co.uk . Please make all requests in writing and provide us with evidence of your identity. See Proof of identity checklist – https://www.gov.uk/government/publications/proof-of-identity-checklist/proof-of-identity-checklist for information on documents you will need to provide.
- Right to withdraw consent – if you have given us your consent to use personal information, you can withdraw your consent at any time
- Rectification – you can ask us to change or complete any inaccurate or incomplete personal information we hold about you
- Erasure – you can ask us to delete your personal information where it is no longer necessary for use to use it, you have withdrawn consent or where we have no lawful basis for keeping it. We have the right to refuse to comply with a request for erasure where the personal data is processed for one of the following reasons:
- We need to use the information to perform a task carried out in the public interest, to provide healthcare or treatment or it is necessary for the reasons of public health in the public health arena;
- We need to use the information to comply with our legal obligations;
- Archiving purposes in the public interest, scientific research, historical research or statistical purposes; or
- The exercise or defence of legal claims.
- Portability – you can ask us to provide you or a third party with some personal information that we hold about you in a structured, commonly used, electronic form so it can be easily transferred
- Restriction – you can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it
- Make a complaint – you can make a complaint about how we have used your personal information to us, by contacting our DPO by post at Lynstock House, Lynstock Way, Bolton, BL6 4SA or by e-mail on GDPR@cohenschemist.co.uk You can also make a complaint to the data protection supervisory, the ICO at https://ico.org.uk/
We will not make any charge for responding to any initial request from you to exercise your privacy rights and we will respond to your requests in accordance with our obligations under data protection law.
What kinds of personal information we use
We use a variety of personal information depending on the products and services we deliver to you;
- To provide most of our products and services we need to know your name, address, date of birth, contact details (phone number and e-mail address) and details of your GP / Surgery
- To provide many of our products and our services which are pharmacy or healthcare related we will need information about your health, your medication and your NHS number; and
- To provide our products and services to you we may need to obtain your payment details. No credit/ debit card payment details are stored by us
Sometimes where we ask for your personal information it is needed to fulfil a contract with you or to meet a legal obligation (such as dispensing a prescription) and we will not be able to provide some of our products or services without that information.
How we gather your personal information
- Directly from you, for example when you fill out a consent form to receive a product or service, when you have a prescription dispensed in one of our pharmacies or when you use our digital services for dispensing prescriptions or providing products and services where we ask you to give us related information online
- We collect certain usage information when you utilise our website such as Internet Protocol (IP) addresses, log files, unique device identifiers, pages viewed, browser type, any links you click on to leave or interact with our website and the products and services we offer, and other usage information collected from cookies and other tracking technologies. For example we collect IP addresses to track and aggregate non-personal information, such as using IP addresses to monitor the regions from which users navigate our website. We may also collect IP addresses from users when they log in to our website as part of our log in and security features
- From other organisations which hold commercially-available data such as the electoral roll and companies that collate and update data. This helps us to keep our records up to date and learn more about our customers so we can improve our products and services
- From NHS bodies such as your GP/surgery or hospital and, if we have your consent to do so, from viewing your Summary Care Record
- Information provided by other people on your behalf, for example, if someone books an appointment on your behalf. We will need to ask them basic details about you, which may include health details such as family history of diseases. We will always check with you that any such details provided are accurate when you come to see us
- If you are a customer of a pharmacy business that has been taken over by us, we will receive your personal information as part of the handover process. Where this happens, we will place a notice in store to tell you that your personal information is changing hands.
We may also use CCTV on our premise ensure the safety and security of our staff and customers.
How we use your personal information
We use your personal information:
- To provide our products and services, respond to queries and comments, to collaborate with others to improve our products and services and to provide you with the best level of customer service. We may use it to contact you about appointments you have booked or to send you reminders (e.g. about repeat prescriptions or notification that your prescriptions are ready for collection)
- To learn more about you. We’ll consolidate the information we hold about you across the different channels you use to interact with us (e.g. In store, by phone, correspondence, etc.)we do this to keep our records accurate and up to date, provide you with a seamless and consistent service and to build a clearer picture of our customers, both individually and as a group. By understanding you better we can offer you the best and most personalised service we can. However, we will only send you marketing material if you have agreed we can
- To protect our customers, our staff and our business. We may use your personal information to help prevent and detect crime. We use CCTV to record images in our stores and other facilities and if requested may pass it on to the police
- To fulfil our contractual requirements with the NHS. We need to share your personal information with your GP and others in the wider NHS, such as the NHS Business Services Authority, and sometimes local authorities to provide you with NHS or Local Authority funded services, to negotiate and check the accuracy of our payments with the NHS and to ensure that we maintain appropriate professional and service standards and that your declarations and ours are accurate
Automated Decision making
We do not use any automated decision making processes.
Our legal basis for using your personal information
We only use your personal information where that is permitted by the laws that protect your privacy rights. We only use personal information where –
- We have your consent (if consent is needed)
- We need to use the information to perform a task carried out in the public interest, to provide health care or treatment or if necessary for reasons of public health in the public health arena
- We need to use the information to comply with our legal obligations
- We need to use the information to perform a contract with you
- It is fair to use the personal information either in our interests or someone else’s interests where there is no disadvantage to you
Special protection is given to certain kinds of personal information that is particularly sensitive. This is information about your health status, medication, racial or ethnic origin, religious or similar beliefs and sex life or sexual orientation. We will only use this kind of information where –
- Required to deliver pharmacy and healthcare products and services to you
- We have a legal obligation to do so (e.g. to protect vulnerable people)
- It is necessary for us to do so to protect your vital interests (for example if you have a severe and immediate medical need whilst on our premises)
- It is in the substantial public interest
- You have specifically given us explicit consent to use the information
Health and medication information
We will use your health and medication information provided to –
- Dispense and deliver your prescriptions or provide other healthcare products and services you have requested. We will never use information about your prescriptions for marketing, although we may use it to advise you of other health services / products that might be useful or relevant to you such as a Medicine Use Review
- Provide you with urgent medical assistance when you are on our premises
- Sometimes prescriptions we dispense for you will reveal special categories of information, such as health status, religious beliefs and sex life or sexual orientation. This information may be processed by us to dispense your prescriptions to you and will not be used for any other purpose.
Sharing your personal information with or getting your personal information from others
We will share personal information with other organisations where we need to do to make our products and services available to you, to contact you about appropriate products and services, to meet or enforce a legal obligation or where it is fair or reasonable for us to do so. We will only share your information to the extent needed for those purposes.
Who we share your personal information with depends on the products and services we provide to you and the purposes we use your personal information for. For some products and services we will share your personal information with our service providers such as couriers, manufacturers and suppliers.
Most of the time the personal information we have about you is information you have given us, or is gathered by us in the course of providing products and services to you. We also sometimes gather personal information from and send personal information to third parties (such as NHS bodies) where necessary so we can fulfil our legal obligations as a provider of pharmacy and healthcare products and services.
Transfers outside the UK
We may need to transfer your information outside the UK to service providers, agents and subcontractors in countries where data protection laws may not provide the same level of protection as those in the European Economic Area, such as the USA.
We may need to transfer your personal information to territories that are outside the EEA. We will only transfer your personal information outside the EEA where either the transfer is to a country which the EU Commission has decided ensures an adequate level of protection for your personal information or we have put in place our own measures to ensure adequate security as required by data protection law. These measures include ensuring that your personal information is kept safe by carrying out strict security checks on our overseas partners and suppliers, backed by strong contractual undertakings approved by the relevant regulators such as the EU style model clauses. We also use the EU Commission approved EU-US Privacy shield when personal information is transferred to the USA.
You can find out more information about standard contractual clauses as detailed by the ICO. Visit their website https://ico.org.uk/ and search for international transfers.
Details of third party data processor we use can be obtained by contacting our DPO by post at Lynstock House, Lynstock Way, Bolton, BL6 4SA or by e-mail on GDPR@cohenschemist.co.uk
How long will we keep your personal information for?
We need your personal information for as we have a legal or business reason to do so, which generally means as long as you remain a customer or as requested to meet our legal obligations, resolve disputes or enforce our agreements. To fulfil our obligations to the NHS, regulatory or similar bodies, health related personal information may need to be retained for a period of time after you cease to be a customer. We will always store it securely and not use it for any other purpose.
Keeping you up to date
We will communicate with you about products and services we are delivering using any contract preferences you have given to us – for example by post, e-mail, text message, and social media.
Where you have given us consent to receive marketing, you can update your contact preferences or withdraw consent by contacting our DPO by post at Lynstock House, Lynstock Way, Bolton, BL6 4SA or by e-mail on GDPR@cohenschemist.co.uk
Last Updated: 25/05/2018