Privacy policy

Please see also the notes  in Security and confidentiality statement and the pages related to use of data in research.

BACKGROUND:

Dr Jeremy Bland and East Kent Hospitals University NHS Foundation Trust understand that your privacy is important to you and that you care about how your personal datais used and shared online. We respect and value the privacy of everyone who visits this website, www.carpal-tunnel.net (“Our Site”)and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1.            Definitions and Interpretation 

In this Policy the following terms shall have the following meanings:  

“Account”	means an account required to access and/or use certain areas and features of Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]
“personal data”	means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the [Data Protection Act 1998] OR [EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)]; and
“We/Us/Our”	Means: Dr Jeremy D P Bland, in the capacity of consultant neurophysiologist at East Kent Hospitals University Foundation NHS Trust, Ethelbert Road, Canterbury, Kent, UK, CT1 3NG

2.            Information About Us

2.1         Our Site is owned and operated by Dr Jeremy D P Bland, Consultant in Clinical Neurophysiology at East Kent Hospitals University NHS Foundation Trust. Ethelbert Road, Canterbury, Kent, UK, CT1 3NG 

2.2         Although Dr Bland works for East Kent Hospitals University NHS Foundation Trust and data from carpal-tunnel.net may be imported into the medical records of patients who are being who are being treated by the trust, the website is owned and operated purely by Dr Bland

3.            What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4.            Your Rights

4.1         As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1.1      The right to be informed about Our collection and use of personal data;

4.1.2      The right of access to the personal data We hold about you (see section 12);

4.1.3      The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);

4.1.4      The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);

4.1.5      The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6      The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7      The right to object to Us using your personal data for particular purposes; and

4.1.8      Rights with respect to automated decision making and profiling.

4.2         If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3         For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5.            What Data Do We Collect?

Depending upon your use of Our Site, We may collect some or all of the following personal [and non-personal]data (please also see section 13 on Our use of Cookies and similar technologies:

5.1         name;

5.2         date of birth;

5.3         gender;

5.4         job title;

5.5         contact information such as email addresses and telephone numbers;

5.6         IP address;

5.7         web browser type and version;

5.8         operating system;

5.9         a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;

5.10      Information about your medical symptoms and previous medical history of relevance to a diagnosis of carpal tunnel syndrome.

6.            How Do We Use Your Data?

6.1         All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under theGDPRat all times. For more details on security see section 7, below.

6.2         Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.2.1      Providing and managing your Account;

6.2.2      Providing and managing your access to Our Site;

6.2.3      Personalising and tailoring your experience on Our Site;

6.2.4      Providing an estimate of the probability that your symptoms result from carpal tunnel syndrome;

6.2.5      Replying to emails from you;

6.2.6      Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by changing your preferences in your account settings or by sending an email to Jeremy [dot] Bland [at] nhs [dot] net

6.2.7      Analysing your use of Our Site to enable Us to continually improve Our Site and your user experience;

6.2.8      In the case of patients attending the carpal tunnel clinic in Canterbury ONLY – we will copy the data you provide via the website into your permanent medical records at the hospital.

6.2.9      We will use your data in anonymised form (ie after removal of the personal identification) for medical research into the epidemiology, investigation and treatment of carpal tunnel syndrome. Such research will be carried out by Dr. Bland, sometimes in cooperation with other researchers, but identifiable personal data will never be shared with other researchers.

6.3         We will never, under any circumstances, use your data for marketing purposes, nor will we share your data with others for marketing purposes. We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.4         You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

6.5         We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

6.5.1      We will retain your data for as long as it is possible that you may at some time present or re-present with symptoms which might result from carpal tunnel syndrome, or for twenty years, whichever is the longest;

6.5.2      When personally identifiable data need no longer be kept as a part of your record with us to enable comparison with later information provided by you we will anonymise the data by removing the personal identifying information, but the anonymised data will still be retained for research purposes unless you specifically ask us to delete it.

7.            How and Where Do We Store Your Data?

7.1         We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

7.2         Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). At present the data is stored in the United Kingdom. Should the UK leave the EEA we will revise these terms.

7.3         Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

7.4         Steps We take to secure and protect your data include: 

7.4.1      Personal identifying information stored on the website is encrypted.

7.4.2      Records of patients attending the carpal tunnel clinic in Canterbury are pseudonymised using an identification key to which the index is held securely within the computer systems of the East Kent Hospitals NHS Foundation Trust

8.            Do We Share Your Data?

8.1         Subject to section 8.2,We will not share any of your data with any third parties for any purposes.

8.2         In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.

8.3         We compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. 

9.            What Happens If Our Business Changes Hands?

9.1         Our website is run as a personal project of Dr Bland, for research purposes, to aid in the running of the carpal tunnel clinic in Canterbury, and as a public information resource on carpal tunnel syndrome. It may be the case in the future that a health related organisation may wish to take over the running of the site, for example on the retirement or illness of Dr Bland, and should this occur existing data on the site will be accessible to the new administrators. If no suitable administrator is found then the entire contents of the site will be securely erased.

9.2         In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.

10.         Your Right to Withhold Information

10.1      You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

10.2      You may restrict Our use of Cookies. For more information, see section 13.

11.         How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). No fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at Jeremy [dot] Bland [at] nhs [dot] net, or using the contact details below in section 14. 

12.         Our Use of Cookies

12.1      Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

12.2      All Cookies used by and on Our Site are used in accordance with current Cookie Law.

12.3      Before Cookies are placed on your computer or device, you will be shown a warning prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. 

12.4      Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.5. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.9, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

12.5      The following Cookies may be placed on your computer or device:

Name of Cookie	Purpose	Strictly Necessary
Drupal session	Allows us to recognise you when you return to Our site	Yes
Has js	Checks whether your browser has javascript enabled	Yes
Utma, utmb, umtc, utmz	These four cookies are used by Google nalaytics to: Recognise you when you return to our site and track the pages you visit. Estimate our audience size. Monitor traffic levels and search queries	No

 

12.6      Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

12.7      The analytics service(s) used by Our Site use(s) Cookies to gather the required information.

12.8      In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

12.9      You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

12.10   It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.]
 

13.         Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at Jeremy [dot] Bland [at] nhs [dot] net, by telephone on +44 1227 783048, or by post at:

EEG Department

Kent and Canterbury Hospital

Ethelbert Road

Canterbury

Kent, UK

CT1 3NG

Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).

14.         Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

Revision date - 5th June 2018