Edition Date December 31, 2018
This is the Cleveland Clinic London Ltd Privacy Notice. It describes the types of personal data that we collect, how we collect and process that information, who we share such information with, and your options in connection with your information.
Purpose of this Privacy Notice
This Privacy Notice aims to give you information on how Cleveland Clinic London Ltd collects and processes your personal data through your use of the website or mobile application associated with this Privacy Notice (each a “Site” and collectively, the “Sites”), including any data you may provide through our Sites.
This Site is not intended for children and we do not knowingly collect data relating to children who are under 13 years of age.
It is important that you read this Privacy Notice 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 Privacy Notice supplements the other notices and is not intended to override them.
Cleveland Clinic London Ltd is the controller and responsible for your personal data (also referred to as “we”, “us” or “our” in this Privacy Notice).
If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Please direct any questions, comments, or complaints regarding this Privacy Notice to us using the contact information below.
Full name of legal entity: Cleveland Clinic London Ltd
Email address: LondonPrivacy@ccf.org
Postal address: 33 Grosvenor Place, London SW1X 7HY
Further guidance on your rights is available from the Information Commissioner’s Office (https://.ico.org.uk/). You have the right to complain to the UK’s supervisory office for data protection, the Information Commissioner’s Office at https://ico.org.uk/concerns/ if you believe that your data has been processed unlawfully. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This Privacy Notice does not override any applicable national data privacy laws and regulations applicable to Cleveland Clinic London Ltd.
Changes to the Privacy Notice
We reserve the right to update this Privacy Notice because of changes in the law or our business operations. We will post any changes to this Privacy Notice on the applicable Sites and, where appropriate, will notify you of changes by email. Please check the Site periodically for changes to the Privacy Notice.
Changes to Your information
We can most effectively communicate with you when we have information that is accurate and current. Please contact us to update your contact information as it changes.
This website 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, we encourage you to read the Privacy Notice of every website you visit.
We collect the following categories of personal data about individuals who visit the Site and other third parties.
Personal data does not include data where the identity has been removed (anonymous data).
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose that are anonymous. 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. 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 this Privacy Notice.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity Data by filling in forms or by corresponding with us by phone, email or otherwise. We do not knowingly collect health data through this Site. If we learn that you have provided health data through this Site, we will delete it.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using Cookies. We may also receive Technical Data about you if you visit other websites employing our Cookies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Below we describe the purposes that we use personal data and our lawful bases for using such data.
You are not required to submit your personal details to us through the Sites but if you choose not to do so, we may not be able to address your request or respond to any query that you wish to submit.
You have control regarding our use of personal data for direct marketing. You can elect not to receive particular marketing communications at any time by clicking on the unsubscribe link of those marketing emails. You may also contact us with the information set forth below specifying what marketing communications you no longer wish to receive.
Please see our Cookies Policy for information about our use of third-party cookies, web beacons, and other similar tracking technologies.
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, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 4 above.
We may transfer your data outside the European Economic Area (EEA) to countries that do not have the same level of data protection as your country. Unless the recipients are located in countries that have been deemed acceptable the European Commission (or are certified under a standard such as the EU-US Privacy Shield Framework), we make such transfers pursuant to standard contractual clauses approved by the European Commission. You may contact us for more information about such transfers and the specific mechanism used to transfer your personal data outside the EEA.
We have put in place security measures designed 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 need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Although we have implemented measures designed to protect personal data and the Sites, there is no way of ensuring that personal data is always protected while it is in transmission or being stored.
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.
In some circumstances you can ask us to delete your data: see your legal rights 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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.