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GDPR / Privacy Policy

JT Occupational Health Ltd understands that privacy is important, and that care is needed about how

personal data is used and shared.

1. Definitions and Interpretation:

     In this policy, the following terms shall have the following meanings:

     1) We/us/our   - means JT Occupational Health Ltd of 6 Wiswell Close, Rossendale, BB4 8HQ
     2) Personal Data  - means any and all data that relates to an identifiable person who can be directly or indirectly               identified from that data. This definition shall, where applicable, incorporate the definitions provided in the EU               Regulation 2016/679 – the General Data Protection Regulation ("GDPR").
     3) Patient  - Any person who is assessed by a JT Occupational Health Ltd clinician.
     4) Customer - Any organisation or person who buys services from JT Occupational Health Ltd.
     5) Manager - Anyone in the management structure of 'Patients'.


2. Information About Us

We are a Nurse led Occupational health service provider. We provide Occupational health Services such as pre-placement health and Occupational Health assessments and drug and alcohol screening. Our registered office is at JT Occupational Health, 6 Wiswell Close, Rossendale BB4 8HQ. 

3. What Does This Policy Cover?


This privacy policy applies to the data held by JT Occupational Health. We respect and value the privacy 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 data protection rights under the GDPR


4. Your Rights


    a) 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:


     - The right to be informed about our collection and use of personal data
     - The right of access to the personal data that we hold about you
     - The right to rectification if any personal data we hold about you is inaccurate or incomplete
     - 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)
     - The right to restrict (i.e. prevent) the processing of your personal data
     - The right to data portability, obtaining a copy of your personal data to re-use with another service or organisation 

     - The right to object to us using your personal data for particular purposes
     -Rights with respect to automated decision making and profiling

     - Further information regarding your rights can be found at A guide to individual rights | ICO

     b) If you have any cause for complaint about our use of your personal data, please contact us on                                           info@jtocchealth.com, and we will do our best to solve the problem for you.

     c) For further information about your rights, please contact the Information Commissioner's Office at                                     dpo@ico.org.uk. Further information can be found at Your right to complain | ICO

5. What Data Do We Collect?


We collect data from our customers, from patients, and from the managers of patients. Most of the data we collect relates to patients who are referred to us by their employer or who contact us directly. We may collect some or all of the following personal, and non-personal data:

     1) Name, and date of birth (to verify the identity of the individual)
     2) Contact information such as addresses, email addresses and telephone numbers (to enable us to contact and              communicate with customers, managers, and patients)
     3) Standard identification information to verify the identity of the patient for certain medical assessments
     4) Occupational health information and records
     5) Email addresses of our customers for marketing purposes
     6) Our clinicians may need reports and information from other healthcare professional (such as GP, specialist                    doctor or nurse). If this is needed, we will always obtain written consent to do this

6. How Do We Use Your Data?
All personal data will be 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 data under the GDPR at all times.

The main legal basis for Occupational Health processing your personal information is as below:

    1) Article 6 (1) (e): processing is necessary for the performance of a task carried out in the public interest or in the              exercise of official authority vested in the controller.

    3) Article 9 (2) (b): as a lawful basis processing is necessary for the purposes of carrying out the obligations and                exercising specific rights of the controller or of the data subject in the field of employment or social security or              social protection.

    3) Article 9 (2) (h): processing is necessary for the purposes of preventive or occupational medicine, for the                          assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or          treatment or the management of health or social care systems or services.

We will process data in line with the GDPR, NMC and where required GMC guidelines and Faculty of Occupational Medicine Guidelines (Ethics Guidance for Occupational Health practice).

    1) Medical information is held confidentially and securely. Confidential medical information can only be accessed            by authorised JT Occupational Health employees. 

    2) For our customers, and with their permission, we may also use their data for marketing purposes that may                      include contacting our customers by email, telephone, and/or post with information, alerts, and news on our                services. We will not, however, send any unsolicited marketing or spam and will take all reasonable steps to                  ensure that we fully protect our customer's rights and comply with our obligations under the GDPR

.

    3) You have the right to withdraw your consent to us using your personal data at any time. GDPR gives the right to            request records be erased. This will need to be reviewed on a case-by-case basis, as some records can be                    exempt from erasure, if it is thought there is any chance of litigation. Health surveillance records are exempt                  from the right to erasure due to the requirements of Health and Safety Law. Any records for which erasure has              been agreed will be undertaken within 30 days.

7.    We do not keep personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

We will retain data according to the retention policies of our customers. Where we are responsible for holding data, we will use the following retention periods:

   1) A data collected from a subject who applied for employment but was never employed by the Client  - Are kept            12 months after application or assessment
   2) Clinical Notes, Including Management referral notes and reports -  Are kept for 6 years after employment finishes.

   3) Health Surveillance records -  40 years after the last entry

   4) Fitness for work medical records - 6 years after employment finishes.
 

8,   How and Where Do We Store Your Data?

      1) Some records are held in paper form at client sites, and these are kept locked in secure filing systems. Only the            Occupational Health department has access to these records.

      2) Where your medical records are stored in an electronic format, these are held on a highly secure server which              can only be accessed with an authorized secure password by Occupational Health personnel. The server is                  managed by an outside company, located  within the EU, who have provided evidence of their GDPR                            compliance, and the server is  backed up regularly to a  secure database network.

9, Do We Share Your Data?

     a)  Subject to section 8.2, we will not share or sell any of your data with any third parties for any purposes.

     b) In certain circumstances, we may be legally required to share certain data held by us, which may include your             personal data, for example, for legal proceedings, where we are complying with legal obligations, a court order,           or a governmental authority.

10, How Can You Access Your Data?

 

    1) You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the           GDPR, 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.

11, Our Use of Cookies


      1)  Our site uses Google Analytics to perform statistical analysis of page use, page interactions and paths taken through the website in order for us to evaluate, develop and improve our website by collecting information about how users use our website, for example by recording the part of a webpage clicked, the number of pages visited, the length of time of each session, and error messages (where applicable) with the purpose of improving our website and providing users with a better experience. This allows us to understand individual behaviours and needs better and more accurately.

     2) For further information about Google Analytics:

     - You can find more information about the cookies used by Google Analytics at:           https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
     - You can find more information about Google's privacy policy relating to the Google Analytics service at: https://support.google.com/analytics/answer/6004245
     - You can find more information about how Google uses the data collected via this service at: https://policies.google.com/technologies/partner-sites
     - You can opt out of being tracked via Google Analytics by following the instructions at: https://tools.google.com/dlpage/gaoptout

 

     3)  All Cookies used by and on our site are used in accordance with current cookie law.

 

     4)  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. You                can choose to delete Cookies on your computer or device at any time. 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.

12, Contacting Us


If you have any questions, comments or queries about this privacy policy or about your data, please contact us by email at info@JTOccHealth.com, or by post at JT Occupational Health, 6 Wiswell close, Rossendale, BB4 8HQ. Please ensure that your query is clear, particularly if it is a request for information about the data, we hold about you.

 

13, 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 use of our site following the alterations. We recommend that you check this page each time you use the site.

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