Privacy Notice

Superdrug Online Doctor

Who are we?

onlinedoctor.superdrug.com (the “Website”) is operated by HEALTH BRIDGE LIMITED.

We are registered in England and Wales under company number 07392646 and our head office and trading address is: Health Bridge Limited, 46 Essex Rd, London N1 8LN.

We are registered with the ICO (Information Commissioner’s Office) under number Z2715245.

Our Data Protection Officer can be contacted by emailing:

[email protected].

Our Role:

We are what is known as a data controller: In terms of the Data Protection Act 2018, that means we are trusted to look after and deal with your personal information in accordance with this policy. We determine the ways and means of processing and must therefore be accountable for it.

Your Rights

As a data subject you have rights in respect of our processing of your personal data.

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances unless it’s a legal requirement, or we have a valid business reason, not to delete it. As an healthcare provider, we will not always be able to delete your data for the following reasons:

- continuity of healthcare provision: we need to be able to know what treatments we have provided to you as your GP will do as well as, for example, providing relevant information to other healthcare professionals providing care to you if we need to (e.g. do we know of any allergies, any bad reaction to a certain ingredient etc.). Hence we will not delete your medical record as well as any communications between you and our team related to your request of a medical service.

- establishment, exercise or defence of legal claims.

Based on the guidance published by the General Medical Council which states that doctors should follow the UK Department of Health and Social Care guidance on how long health records should be kept, we’re keeping these data until ten years after the patient’s death.

You can ask us to suspend your electronic patient account by clicking on the suspend button in your account. Your account will stop working immediately and you will no longer be able to access your account and you will cease to receive any further notifications in relation to your account but the data will not be erased.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances, for example, because you believe that your data is incorrect, or the processing of your data is unlawful.

Your right to object to processing - You have the right to object to our processing your information if the legal basis is legitimate interest.

Your right to data portability - This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under a contract, or in talks about entering into one, and the processing is automated.

If you want to exercise any of these rights, please just contact us on [email protected] and state the nature of your request in the subject of your email (e.g. Access Request, Deletion request etc).

You also have the right to lodge a complaint about our processing with a supervisory authority — in the UK that is the ICO whose details are here: https://ico.org.uk/make-a-complaint/

Technical and Operational Security

Our promise

Our security measures protect you against unauthorised access, changes, disclosure or destruction of your data.

We regularly review our security measures, including how we collect, process and store data. Part of this means encrypting data and putting in place physical security measures to protect our storage systems. We are Cyber Essential Plus certified.

Your payment transaction and your personal data are encrypted using SSL technology.

Every member of our staff signs and agrees to a confidentiality agreement when they start working for us and are trained in relevant data protection regulations.

Access to your data is only given to employees on a need-to-know basis.

All our suppliers have to abide to privacy undertakings, in accordance with the applicable data protection laws and regulations.

Tell me more:

To see more about how we use your personal data, read the notice or notices which apply best to your relationship with us:

1. I am a Superdrug Online Doctor patient
2. I am just browsing your website
3. I am a research participant
4. I am a supplier

1. Patient Privacy Notice

Data that we process and how we use it

As a patient of Superdrug Online Doctor, we hold the following information about you:

Identity details

When you set up an account with us, you will provide your name, date of birth, gender and you might also have to provide an ID in order for us to check your identity.

When using the App, you will be asked to show your ID during the video consultation to confirm your identity.

We also generate a patient ID in order to identify you in a pseudonymised manner wherever possible.

Contact details

When you set up the account, the identifier and username for our services is your email address.

The email address is used to send you alerts to let you know that you have a service related email in your patient account and also to send marketing emails to you if you have not opted out.

We will email you about prescriptions reminders, basket abandonment and reviews if you have not opted out to these.

We process your delivery address in order to deliver your treatment and this is also required on the prescription and as a billing address for payment purposes.

If you provided a phone number, it is used to send information to you in relation to the service you requested. We do not currently use your phone number for marketing purposes, if we decide to do so, we will ask for your consent.

For sake of clarity, your email address will be shared with our delivery partner so that you receive delivery updates via your email and be able to track your order as per below.

Medical information

We hold information about your health and medical history that you provide us with when you complete our medical assessments on the website or on the app. This includes photos (when applicable) and information you provided when communicating with our doctors or Patient Care, the treatments that our doctors prescribed to you, the results of the tests, referral letters and fit notes.

This data is required to enable our doctors to provide the diagnosis and provide treatment or advice to you.

We might also obtain information from your GP when we or you inform your GP of the treatments we provided to you.

Our telephone consultation calls can be recorded and stored for up to 30 days for clinical governance purposes. Written consultation notes will be kept in your patient record thereafter.

Financial information

When you make a payment to us, we will process your payment data. However, we do not act as a payment provider, so we do not store your card details, we just pass them directly to the provider. We do however have access to the transaction details: type of card, bank details, last 4 digits of your card, billing address and transaction IDs. Those details are not directly saved by us, but we are able to access them in order to assist you or if there is a payment dispute. In the case of a dispute, we would store the details of the transaction until the dispute is settled.

Technical Information

When you are browsing our website, our App or using our services, we will automatically collect technical information such as the type of device you’re using, browser, IP address, screen size etc.

This allows us to understand any issues with our website, show you relevant information (e.g.pharmacies near you) and for the prevention of fraud.

Browsing activity/usage details

When using our Website, if cookies are loaded, we will process information about the pages you have visited, your searches, load and download times, time spent on our pages, interaction with the page (click, scrolling, mouse-overs) and what led you to our Website ( link in an article, google search etc).

When using our App, we collect technical information and your browsing behaviour. Please see the Website and App Browsing Privacy Notice for more information.

We perform analytics based on this data. Performing analytics is vital for us to understand how you interact with our website and various services in order to improve them and to give you a good user experience.

Marketing information

We store your consent status and the type of marketing you are subscribed/unsubscribed to.

Data used for research purposes

In some circumstances we will anonymise or aggregate your personal data (so that it can no longer be associated with you) for research or statistical purposes.

Aggregated Data is derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

Data that does not identify an individual does not fall under the UK or EU GDPR.

If you have participated in research or feedback surveys, we will store the different surveys you have participated in and your survey responses.

Note: For suppliers/processors based in the USA, we are monitoring the guidance from the ICO carefully (https://ico.org.uk/make-a-complaint/eu-us-privacy-shield/) and are conducting due diligence and moving to an appropriate new transfer mechanism as appropriate.

Within Superdrug Online Doctor:

Your medical information and identity details are shared amongst our doctors to provide quality and continuity of care. Our Patient Care might also need to access your record in order to assist you in your query and verify your identity before releasing any information to you.

Our IT department might need to access your account if there is a technical issue to solve or in order to enhance the tools we’re using.

Finally, the compliance/legal team might also access your information in order to send you data when you make a data subject request.

All our staff are bound to strict confidentiality undertakings and have had initial and ongoing data protection training.

Superdrug Online Doctor implements an access right policy and this allows access to the data only on a need-to-know basis.

With third parties and processors:

Like most companies, we use a number of suppliers as part of our data processing, for example cloud services, technology services, carriers. Your data are being shared with Superdrug Store Plc for the dispensing of your prescription. For marketing purposes, research and analytics, we are also using suppliers such as email platform providers, analytics software, survey tools.

We have Data Processing Agreements in place with these providers to secure the use of your data by these suppliers.

If data is transferred from the UK to the EEA or from the EEA to the UK, then it is done so on the basis of those countries receiving the data are having a comparable data protection regime to the country sharing the data (adequacy).

Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place, for example with Standard Contractual Clauses with additional due diligence.

In order to provide the medical service to you and for security purposes, we need to share your personal data with third parties including payment providers.

As regulated healthcare providers, we might need to disclose certain of your information including personal data and medical data to, including but not limited to:

• the medical regulators who inspect our service and premises (Care Quality Commission and General Pharmaceutical Council).
• Other regulators such as the General Medical Council and the Information Commissioner Office if you make a complaint or in case of an investigation.
• Your GP with your consent or based on your vital interests
• Other healthcare partners such as laboratories.

Finally, we may need to share your information for legal reasons:

• Should we sell or buy any business or assets, we may need to share your data with the future seller or buyer.
• If we are asked to share your personal data as a result of a court order, legal processing or any other legal obligation.
• To protect the rights, property, or safety of Superdrug Online Doctor, our patients, suppliers and partners, or others. This includes exchanging information for fraud protection, reducing credit risk and verifying your identity by an ID&V provider.

Rest assured, we only share information that is absolutely necessary and we go to great lengths to make sure everyone we work with takes your privacy as seriously as we do.

Retention Periods

Medical records

We follow the NHS Records Management Code of Practice for Health and Social Care 2016 and therefore keep your health record for 10 years after your death, or after we are made aware that you have left the EU. Note that the records include your identity data, medical data and contact details and the messages exchanged with our doctors and Patient Care.

Account details

If you registered with us and have not ordered any service, we will retain this data until you notify us that you want to stop using our service and ask for your data to be deleted unless we have a legal or regulatory reason to keep them.

If you’ve ordered from us or had any exchanges with our doctors about your health or if you are making any claim, we will keep these data as per the paragraph above (Medical Records) and in order to defend our rights and interests in case of a dispute or a claim.

Note that the account cannot be deleted but suspended which means that access is revoked. If we have no reason to keep the data as explained above, we will anonymise the account.

Research

If you have provided your data for research purposes, we retain the data for 4 years. After 4 years, the data is anonymised and so no longer falls under the data protection regulations.

Analytics

Data about the usage of our services and technical data used for analytics are retained in a pseudonymous manner for as long as you have a non-suspended account with us or until you action a right to erasure.

Marketing

Data used for marketing purposes is retained for as long as you have a non-suspended account with us until you ask for the deletion of your non-medical data. If you ask to unsubscribe to marketing, then the data is moved to a suppression list to ensure that there is no danger of you being added to any marketing lists in the future.

Supplementary Privacy Notice for Covid-19 testing services for Patients (Website service)

This notice describes how we may use your information to protect you and others during the Covid-19 outbreak. It supplements our main Privacy Notice.

In the context of the pandemic, the Secretary of State has required health organisations amongst other entities to share confidential patient information to respond to the Covid-19 outbreak based on reasons of public interest in the area of public health, and research in the public interest.

Any information used or shared during the Covid-19 outbreak will be limited to the period of the outbreak unless there is another legal basis to use the data.

Where data is used and shared under these laws your right to have personal data erased will also not apply.

We may share your confidential patient information including, but not limited to, your name, ethnicity, NHS number, test results with health and care organisations and public bodies engaged in disease surveillance for the purposes of protecting public health including the UK government.

If you are having a blood draw at a Clinic, we will share your name, telephone number, data of birth, address and email address with the clinic in order to perform the blood draw service

We may also use the details we have to send public health messages to you, either by phone, text or email and /or to follow-up on Covid-19 test you’ve done.

Your personal/confidential patient information will be safeguarded in the same way it would with any other consultation. We will not collect more information than we require and we will ensure that any information collected is treated with the appropriate safeguards.

2. Website and App Browsing Privacy Notice

Data that we process and how we use it

As a user of our Website and depending on the cookie preferences you gave, we collect your individual usage data which includes information about how you use our website, products and services. This is used to create aggregated data.

If cookies are loaded, we will process information about the pages you have visited, your searches on our website, load and download times, time spent on our pages, interaction with the page (click, scrolling, mouse-overs) and what led you to our website ( link in an article, google search etc).

When downloading our App, certain required information is transmitted to the AppStore. In particular, the user name, e-mail address, customer number of your account, time of download, payment information and individual device identification number can be processed. The processing of this data is exclusively carried out by the respective operator of the AppStore and is beyond our sphere of influence. Please contact the operator directly should you have any questions about this.

In addition to the above, we will automatically collect data when you are using our App. These are the type of your device, the unique identification number (e.g. EMEI number) , the I address shortened by the last octet, network information , your operating system, your location, your time zone, your login information ( after you have created the account), duration, type and scope of use of the functions of the App.

We perform analytics based on this data. Performing analytics is vital for us to understand how you interact with our website and various services in order to improve them and to give you a good user experience.

We do not use your browsing data to predict or make any assumptions about you.

Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with the patient privacy notice.

Note: For the browsing data while on www.superdrug.com, please refer to their privacy notice directly.

Lawful basis for processing

Our lawful basis for processing your data is legitimate interest for security purposes and for business purposes.

Data Sharing and Transfers

Like most companies, we use a number of suppliers as part of our data processing, for example cloud services, technology services and analytics tools. We have Data Processing Agreements in place with these providers. If data is transferred from the UK to the EEA or from the EEA to the UK, then it is done so on the basis of those countries receiving the data are having a comparable data protection regime to the country sharing the data (adequacy).

Finally, we may need to share your information for legal reasons:

• Should we sell or buy any business or assets, we may need to share aggregated data with the future seller or buyer.
• If we are asked to share your personal data as a result of a court order, legal processing or any other legal obligation.
• To protect the rights, property, or safety of Superdrug Online Doctor, our patients, suppliers and partners, or others. This includes exchanging information for fraud protection, reducing credit risk and verifying your identity by an ID&V provider.

Rest assured, we only share information that is absolutely necessary and we go to great lengths to make sure everyone we work with takes your privacy as seriously as we do.

Retention Periods

If any usage and technical data are linked to you directly once you register with us, we will keep them until you ask for the deletion of your data or until you inform us that you want to stop using our services.

3. Research Participant Privacy Notice

Data that we process and how we use it

As a research participant of Superdrug Online Doctor, we hold the information you provide when answering a survey, or participating in an interview, face to face or remotely.

We hold personal data and aggregated data such as statistical or demographic data.

Once data is aggregated it is not considered personal data, as you cannot be identified from it, directly or we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with the patient privacy notice.

We use these data in order to continually get feedback on our services and understand our customers’ expectations and experiences.

When you use our website we also collect additional information. Please see our Web Browsing Privacy Notice for more details.

Lawful basis for processing

Our lawful basis for processing your data is based on legitimate interest or consent depending on the type of research made.

If you provided consent, you may withdraw this consent at any time by emailing Patient Care or your research team contact.

Data Sharing and Transfers

Like most companies, we use a number of suppliers as part of our data processing, for example cloud services and technology services. In order to perform the interviews, we might reach out to external agencies and use tools to record sessions, your image and/or voice.

We have Data Processing Agreements in place with these providers to secure the use of your data by these suppliers.

Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place.

Finally, we may need to share your information for legal reasons:

Should we sell or buy any business or assets, we may need to share your data with the future seller or buyer.

If we are asked to share your personal data as a result of a court order, legal processing or any other legal obligation.

Rest assured, we only share information that is absolutely necessary and we go to great lengths to make sure everyone we work with takes your privacy as seriously as we do.

Retention Periods

If research data is linked to you as an individual then, we will keep the data for 4 years.

4. Supplier Privacy Notice

Data that we process and how we use it

We might have to share your data to third parties due to a legal obligation (e.g. financial authorities).

If data is transferred from the UK to the EEA or from the EEA to the UK, then it is done so on the basis of those countries receiving the data are having a comparable data protection regime to the country sharing the data (adequacy)

Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place, for example Standard Contractual Clauses.

We may need to share your information for legal reasons:

• Should we sell or buy any business or assets, we may need to share your data with the future seller or buyer.
• If we are asked to share your personal data as a result of a court order, legal processing or any other legal obligation.
• To protect our rights, property, or safety.

Rest assured, we only share information that is absolutely necessary and we go to great lengths to make sure everyone we work with takes your privacy as seriously as we do.

Lawful basis for processing

Our lawful basis for processing your data is either based on performance of the contract and/or to defend our rights in case of claims and/or legal obligation.

Data Sharing and Transfers

We might have to share your data to third parties due to a legal obligation (e.g. financial authorities).

Where data is transferred outside of the EEA, we ensure that appropriate protection and mechanisms are in place, for example Standard Contractual Clauses.

We may need to share your information for legal reasons:

• Should we sell or buy any business or assets, we may need to share your data with the future seller or buyer.
• If we are asked to share your personal data as a result of a court order, legal processing or any other legal obligation.
• To protect our rights, property, or safety.

Rest assured, we only share information that is absolutely necessary and we go to great lengths to make sure everyone we work with takes your privacy as seriously as we do.

Retention Periods

We will keep your data for the duration of our contract and for a period of 7 years after the end of our relationship or longer if submitted to a legal/regulatory obligation.