Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“Any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
How we use your information
Your privacy is important to us. This privacy notice tells you how and why Ways to Wellness collect and use your personal data.
Ways to Wellness provide a range of specialist, personalised health and wellbeing services across the North East of England, on behalf of the NHS, ICS/ICB and other public sector organisations.
The data we collect depends on the context of the service you require or engage with, but is done with the purpose of ensuring your eligibility for a service, to make sure that we are providing an effective service to you, and in accordance with the requirements of our funders.
Why does Ways to Wellness need to collect and store personal data?
In order for us to provide you access to a Ways to Wellness (WtW) service we need to collect your personal data as a pre-requisite for participation. This data includes your contact details and reason for referral, and may also include family, lifestyle and social circumstance, health details, and details of other services you use. We may also log and monitor details of meetings, telephone calls, letters and emails for any referred clients, in order to be proactive in the service we provide.
In line with our obligations, we ensure that the information we collect and use is appropriate for its purpose, and does not constitute an invasion of your privacy.
The information we collect, store and use is done in a manner that is compatible with the UK’s General Data Protection Regulation (GDPR).
In terms of being contacted for marketing purposes, Ways to Wellness Limited would contact you for additional consent.
Will Ways to Wellness share my personal data with anyone else?
Ways to Wellness will ensure that only relevant information is shared in appropriate circumstances, such as with others involved in your care, to provide an effective service to you, and in line with our Data Protection Policy.
We may need to pass your personal data on to third-party service providers contracted to Ways to Wellness, in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide to you on our behalf which cannot be fulfilled directly by Ways to Wellness. When they no longer need your data to fulfil this service, they will dispose of the details in line with our procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
How will Ways to Wellness use the personal data it collects about me?
Ways to Wellness will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Ways to Wellness Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Ways to Wellness Limited are registered with the Information Commissioner’s Office with registration number ZA068438. Ways to Wellness Foundation are registered with the Information Commissioner’s Office with registration number ZB173507. The term ‘Ways to Wellness’ in this statement covers both the Limited and Foundation organisations.
Under what circumstances will Ways to Wellness contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
Ways to Wellness at your request, can confirm what information we hold about you and how it is processed. If we do hold personal data about you, you can request the following information:
Contact details of the Data Protection Officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of Ways to Wellness or a third party, information about those interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
How long the data will be stored.
Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint.
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this?
Ways to Wellness Limited accepts the following forms of ID when information on your personal data is requested: Passport, driving licence, birth certificate, utility bill (from last 3 months).
Does Ways to Wellness comply with the national opt-out policy?
Ways to Wellness complies with the national opt-out policy. We use and share confidential data for the purposes of patient care and treatment. Before Ways to Wellness uses confidential patient information for a purpose that is beyond individual patient care and treatment (such as for research and planning) Ways to Wellness will either gain explicit and informed consent from patients or will submit NHS numbers to the NHS Digital to check and remove any patients who have registered an opt-out choice. More information about National Data Opt Out can be found here: https://digital.nhs.uk/services/national-data-opt-out
Contact details of the Ways to Wellness Data Protection Officer (DPO)
