Ashtons - Privacy Policy

Introduction

Welcome to the Ashtons privacy policy (‘Policy).

Ashtons respects your privacy and is committed to protecting your personal data. This Policy will inform you as to how we look after your personal data, including when you visit our websites (regardless of where you visit it from), or order or use any of our pharmacy or online services, including Live View or E-Works, and tells you about your privacy rights and how the law protects you.

We will never sell your personal data to a third party.

This Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Policy.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY
  11. COOKIE POLICY

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS POLICY

This Policy aims to give you information on how Ashtons collects and processes your personal data, including through your use of our websites (orders.ashtonshospitalpharmacy.com or ashtonshospitalpharmacy.com), or place an order via our pharmacy services, including our online Live View or E-Works services, or when you contact us or take part in a survey.

Our websites and services are not intended for use by children and we do not knowingly collect data relating to children unless it is with the consent of a guardian or adult.

It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.

CONTROLLER

Ashtons Hospital Pharmacy Services Limited is the controller and responsible for this website and is the controller and responsible for your personal data (collectively referred to as "Ashtons", "we", "us" or "our" in this Policy).

Our Data Protection Officer (DPO) is responsible for overseeing questions in relation to this Policy. If you have any questions, including any requests to exercise your legal rights, please contact the CTO using the details set out below.

CONTACT DETAILS

Our full details are: Ashtons Hospital Pharmacy Services Limited, Unit 4, 74 Dyke Road Mews, Brighton, BN1 3JD.

Email: dataprotection@ashtonshospitalpharmacy.com

CHANGES TO THE POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated in July 2019 and may be subject to further revisions.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

Our website or online services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or online services, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract (i.e. online service end user licence) we have with you, or we have legitimate interest in collecting because of a service offered, and you fail to provide that data when requested, we may not be able to perform the contract or service we have or are trying to enter into with you. In this case, we may have to cancel a registration or service you have with us but we will endeavour to notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new client or user of our pharmacy or online services
  1. Identity
  2. Contact
  3. Profile
  4. Special Category
  1. Performance of a contract with you or a client organisation to whom you are connected
  2. Consent to process Special Category data
To process and deliver a service, including:
  1. Pass your details to a permitted and authorised provider or healthcare professional or institution
  2. To inform of developments or updates in relation to the services we provide to you or provided by an authorised provider or healthcare professional or institution.
  3. Connect you to a third party administrative or technology provider in order to perform our services.
  1. Identity
  2. Contact
  3. Profile
  4. Special Category
  1. Performance of a contract with you or a client organisation to whom you are connected
  2. Consent to process Special Category data
  3. Necessary to comply with a legal obligation
  4. Necessary for our legitimate interests (including for tax and legal liability purposes)
To manage our relationship with you which will include:
  1. Notifying you about changes to our terms or privacy policy
  2. If you have some other form of contractual relationship with us
  3. Asking you for feedback
  1. Identity
  2. Contact
  3. Profile
  4. Special Category
  1. Performance of a contract with you or a client organisation to whom you are connected
  2. Consent to process Special Category data
  3. Necessary to comply with a legal obligation
  4. Necessary for our legitimate interests (to keep our records updated, to comply with our legal and tax obligations, or to study how customers services)
To administer and protect our business, our websites and online services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity
  2. Contact
  3. Technical
  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  2. Necessary to comply with a legal obligation
To deliver relevant website content and measure or understand the effectiveness of the advertising we serve to you
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Technical
Necessary for our legitimate interests (to study how clients use our products/services)
To use data analytics to improve our website, services, customer relationships and experiences
  1. Technical
  2. Usage
Necessary for our legitimate interests (to define types of clients for our services, to keep our websites and online services updated and relevant, to develop our business and to inform our marketing strategy)

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent (except in the case of Special Category data) in compliance with the above rules, or where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

In order to perform our services we may transfer your personal data outside the European Economic Area (EEA).

Some of our External Third Parties may be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we seek to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business or medical need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We seek to use third party technology providers that are ISO27001 certified or equivalent (SOC II) where practical and as a business we have achieved Cyber Essentials Plus accreditation.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For example, Ashtons will only process personal data relating to healthcare patients (Contact, Identity, Profile and Special Category data) for the period during which they are provided with healthcare by one of our client institutions, but we will store the relevant data for eight years starting from when the patient is discharged or last seen (or 20 years in the case of mental health records) and in line with current NHS retention guidance. After this period of time, the personal data will be destroyed.

By law we also have to keep basic information about our clients and employees (including Contact, Identity and any financial data) for six years after they cease being clients or employees for tax and legal liability purpose, but we also keep this information to make it easier for users to process new, follow-on or repeat service requests.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Logs will be kept of all records destroyed.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please Contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in the Ashtons group acting as joint controllers or processors and which provide IT and system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES

YOUR LEGAL RIGHTS

You have the right to:

11. COOKIE POLICY

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the memory of your computer or device if you agree. Cookies contain information that is transferred to your computer's memory.

We use the following cookies:

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.