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Privacy Policy Wellness in One Place



At Altius Healthcare Limited we are committed to protecting and respecting your personal data.  This policy explains, amongst other things, when and why we collect your personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. It also provides information on your rights in relation to your personal data.  Please take your time to read this Privacy Notice carefully, by signing our registration forms you are agreeing to be bound by this policy.   Any questions or comments regarding this policy and our privacy practices should be sent by email to our Data Protection Officer on info@altiushealthcare.co.uk, or in writing to 30B the Barn, Park Road, Hale, Cheshire, WA15 9NN. Alternatively, you can telephone Altius Healthcare Limited on 0161 401 1000.

Who are we?
Wellness in One Place is an online programme provided by Altius Healthcare Limited that delivers an online wellness service. Altius Healthcare Limited is a private healthcare practice offering services including physiotherapy, podiatry, massage and sports rehabilitation.  The registered address is 30B The Barn, Park Road, Hale, Cheshire, WA15 9NN (company limited by guarantee no: 09473392).  We also work out of other sites, including Manchester Institute for Health and Performance Manchester, and 43 Knowsley Street in Bury and have contracts with sporting organisations.

How do we collect information about you?
We obtain information from your employer or when you contact us directly either in person, telephone, email or writing and/or enter into a contract with us.

What type of information is collected from you?
The personal information we collect may include your name, address, date of birth, email, contact details, and occupation.  Each time we process (use) this data we must have a legal justification (ground) for doing so, which depends on the purpose of our proposed use of that data.   Some of the further categories of information we may use – such as health, sexual orientation, ethnicity, religious beliefs and genetic information – is classed as a ‘special category of data’, and we must have an additional legal justification in order to use it.

 
How is your information used?
As stated above, we may use your information for a number of different purposes.  We will generally rely on the following grounds (in italics) when using your data for the following intended purposes:

     
  • To generate your personal wellness information, to analyse the results of this information and any trends within your data. We may report these trends, but if done so will be anonymised. 
  • When, for example, maintaining your client record, account and/or billing details, developing and improving our products and services and monitoring outcomes, we have a legitimate interest in processing your personal information, and such business need does not cause harm to you.
  • When analysing the results of an individual’s wellness programme and using anonymised data for feedback to employers and as marketing to other companies, we have a legitimate interest in processing your personal information, and such business need does not cause harm to you.
  • Where we have a legal or regulatory obligation to give such personal information to others, given the nature of the sector in which we operate, and such use may be necessary for the provision of treatment or the management of wellness systems and/or for us to establish, exercise and defend our legal rights.
  • In order to communicate with you and resolve any queries or complaints that you might have, in order to provide wellness services to you, and/or for us to establish, exercise and defend our legal rights or any claims against us.  
  • When communicating with any other individual that you ask us to, to update us about your wellness programme, and updating other professionals about your care, for example one of the wellness consultants, because we have a legitimate interest in ensuring other professionals involved in your wellness programme are fully up to date, and in order to provide wellness services to you.
  • In order to manage our business operations, for example such as maintaining accounting records, analysis of wellness and financial results, internal audit requirements and receiving professional advice (e.g. tax or legal advice) We need to use such personal information to establish, exercise or defend our legal rights and we have a legitimate interest in using your information which does not overly prejudice you.
  • To provide you with marketing which is relevant to our business, only where you have specifically confirmed your consent to do so
 
We have a legitimate interest in processing your personal data and sending the above data in order to provide you with the appropriate wellness programme.  We do require your consent to the use of your data as detailed in this privacy policy and we will require you to sign our client registration/consent forms.  Please note that failure to provide your information further to a contractual requirement with us may mean that we are unable to set you up as a user on the Wellness in One Place Programme.  We review our retention periods for personal information on a regular basis. We will only keep your information for as long as is reasonably necessary, and in order to comply with our specific legal and regulatory obligations. Further information can be obtained from our DPO.

How will we communicate with you
We may contact you via email with information and updates about Wellness in One Place, this is information relevant to the wellness programme and is with the intention of enhancing your experience of the service. We will retain this information in line with our retention periods for personal information, but you can opt out and have your email removed from this list at any time but this may affect the service wellness in one place is able to offer you.
We may from time to time contact you via email with newsletters and promotional material about Altius Healthcare Limited services and events that may be of interest to you.  If you do not wish to receive these emails please see the information below in ‘your rights’.  We will retain this information in line with our retention periods for personal information, but you can opt out and have your email removed from this list at any time.
We use Mailchimp and Google Analytics to support our web-based activities (both based in the USA). These companies are certified with the Privacy Shield which requires registered US companies to:
     
  • better safeguard EU citizens’ data
  • provide clear privacy information
  • limit the collection and use of data. 
 
The Privacy Shield also allows for more robust monitoring and enforcement by the US Department of Commerce and Federal Trade Commission (FTC) which includes increased co-operation with the European and Swiss Data Protection Authorities.

How is your data stored?
Your data will be stored on WordPress, on MySQL which is the database management system used for WordPress storage. Your email address will also be stored by Altius Healthcare Limited on our secure Practice Management system software and secure shared drive system.

Who has access to your information?
Wellness in One Place staff and administrators will have access to your information, and they should only access/use what is required in order for them to deliver the wellness service.  They are expected to comply with this policy in handling your personal data.  We may disclose your information to the third parties listed below for the purposes described in this policy. This might include:
     
  • Other members of support staff and wellness consultants involved in the delivery of your wellness programme.
  • Anyone that you ask us to communicate with or provide as an emergency contact, for example your next of kin or carer.
  • The police and other third parties where reasonably necessary for the prevention or detection of crime
  • Our third party services providers such as IT suppliers, lawyers, marketing agencies, document management providers and tax advisers.
  • Selected third parties in connection with any sale, transfer or disposal of our business.
  • The results of your wellness tests may be shared with selected third parties for marketing purposes, but will be done so anonymously.
 
We disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.  Please be reassured that we will not release your information to third parties beyond Altius Healthcare Limited for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

Your rights

 
  1. You have a right to be informed about the collection and use of your personal data.  We will provide individuals with privacy information at the time we collect their personal data from them.  If we obtain personal data from a source other than the individual it relates to, we will provide you with privacy information either within a reasonable of period of obtaining your personal data and no later than one month; or if we plan to communicate with the individual, at the latest, when the first communication takes place; or if we plan to disclose the data to someone else, at the latest, when the data is disclosed.
 
  1. You have a right to access any personal data we hold about you and for details on how we use it, the length of time we expect to hold this information and, if personal data was not provided by you, the source of the information.  You can request this access at any time, verbally or in writing, and we have one month to respond to this.  Your information will usually be provided to you in writing, unless otherwise requested. If you have made the request electronically (e.g., by email) the information will be provided to you by electronic means where possible.
 
  1. You have a right to rectification, that is the right to ask us to amend or delete your personal information.  The accuracy of your information is important to us. We’re working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or any of the other information we hold is inaccurate or out of date, please email us at: info@altiushealthcare.co.uk, or write to us at: 30B The Barn, Park Road, Hale, Cheshire, WA15 9NN. Alternatively, you can telephone 0161 401 1000.
 
  1. You have the right to erasure (also known as the right to be forgotten).  In some circumstances, you have the right to request that we delete the personal information we hold about you. However, there are exceptions to this right and in certain circumstances we can refuse to delete the information in question. In particular, for example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercise or defending legal claims. 
 
  1. You have the right to restriction of processing of your data.  When processing is restricted, we are permitted to store the personal data, but not use it. You can make a request for restriction verbally or in writing. This is not an absolute right and only applies in certain circumstances.  In particular, for example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercise or defending legal claims. 
 
  1. You have the right to data portability, which allows individuals to obtain and reuse their personal data for their own purposes across different services.  In some circumstances, we must transfer personal information that you have provided to us to you, or if this is technically feasible another individual/ organisation of your choice. The information must be transferred in an electronic format.
 
  1. You have a right to object to marketing.  You can ask us to stop sending you marketing messages at any time and we must comply with your request. You can choose to remain on our mailing list regarding Altius Healthcare Limited newsletters and promotional material.  No customer is added to the mailing list unless they give us permission to do so, going forward new clients will be asked to opt-in to our customer mailing list upon collection of their details for the first time.  If you do not want to receive direct marketing communications from us about our exciting products and services, then you can easily unsubscribe from this list by following the instructions in any of those emails or select your choice by ticking the relevant boxes situated on the patient consent form.  We will not contact you for marketing purposes by email unless you have given your prior consent. You can change your marketing preferences at any time by contacting the DPO by email: info@altiushealthcare.co.uk or telephone on 0161 401 1000
 
  1. You have the right not to be subject to automatic decisions (i.e. decisions that are made about you by computer alone) that have a legal or other significant effect on you.
 
  1. You have the right to withdraw consent. In some cases, we need your consent in order for our use of your personal information to comply with data protection legislation.  We have explained in the section ‘how is your information used?” where we rely on your consent in this way. Where we do this, you have the right to withdraw your consent to further use of your personal information. You can do this by contacting Altius Healthcare Limited’s DPO whose details at the top of the page.
  2. You have the right to complain to the Information Commissioner’s Office if you are unhappy with the way that we have dealt with a request from you to exercise any of these rights, or if you think we have not complied with our legal obligations.  Making a complaint will not affect any other legal rights or remedies that you have.
     
Security precautions are in place to protect the loss, misuse or alteration of your information
When you give us personal information, we take steps to ensure that it’s treated securely. Any sensitive information is encrypted and protected with the following software, or stored on a password protected shared drive or emailed via an encrypted website called Egress.  We strive to protect your personal information, but we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. We have internal policies in place to ensure that your data is not lost, misused or disclosed, and is not accessed except by our staff and contractors in the proper performance of their duties. Review of this Policy We keep this Policy under regular review. This Policy was last updated in March 2021.  



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