GDPR & Privacy Policy

PRIVACY NOTICE Introduction The Radiology Clinic is committed to protecting our patient privacy and takes its responsibility regarding the security of patient information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information. This Notice sets out the following: • What personal data we collect and process about you in connection with your relationship with us as a patient and through your use of our website; • Where we obtain the data from; • What we do with that data; • How we store the data; • Who we transfer/disclose that data to; • How we deal with your data protection rights; • And how we comply with the data protection rules. All personal data is collected and processed in accordance with Maltese and EU data protection laws - Regulation (EU) 2016/679 (General Data Protection Regulation) Data Controller “The Radiology Clinic” (referred to as “we”, “us”, “our” in this notice) in this notice primarily refers to Radiology Services Ltd, the main operating company of the Radiology Services group. Dr Malcolm P Crockford. is the “data controller” of all personal information that is collected and used about Radiology Clinic patient for the purposes of the Regulation (EU) 2016/679 (General Data Protection Regulation). Radiology Services Ltd is registered in Malta with registration number C17259 and at Flat 1, Beatrice Flats, Giuseppe Cali St, Ta' Xbiex XBX1423 What personal data we collect Personal data means any information relating to you which allows us to identify you, such as your name, contact details, ID card number, date of birth, telephone numbers, email address, and clinical information. We also ask women whether they would like to be involved in the Breast Screening Programme and be recalled every 18 months. We may collect personal data from you through a telephone call, email or through our website or on site at our Clinic. Specifically, we may collect the following categories of information: - Name, date of birth, home address, e-mail address, telephone number, passport or other recognized personal ID card numbers and details, referring doctor, clinical problem, payment details; in emigration or immigration procedures, your passport or ID number, expiry date and country of issue. Purposes of processing and data retention Your data may be used for the following purposes: a. Providing the clinical services you request: we use the information you give us to perform the services you have asked for in relation to your visit to the Clinic; b. Contacting you in the event of an imaging examination time change or cancellation; c. Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes and to detect and / or prevent any fraudulent activities; d. Administrative or legal purposes: we use your data to deal with a dispute or claim e. We may pass your information to the referring medical practitioner or f. Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us; h. Provide tailored services: we use your data to provide information we believe is of interest to you, and to personalise the services we offer to you, such as special offers on our imaging tests; i. Marketing: we do not use your personal data for marketing purposes. Only children aged 18 or over can provide their own consent. For children under this age, consent of the children’s’ parents or legal guardians is required. We will retain your personal and medical data in order to meet our clinical and legal obligations or to deal with complaints, queries and to protect our legal rights in the event of a claim being made. When we no longer need your personal data, we will archive it and only use it should there be a claim or legal obligation to process it. Security of your personal data We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage. Sharing your personal data Your personal data may be shared with clinicians and other medical clinics/hospitals. We may disclose your information to trusted third parties for the purposes set out in this Privacy Notice. Such third parties can be medical Insurance companies, referring doctors, government authorities, hospitals and other similar entities. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with Maltese laws and the EU Regulation 2016/679 on data protection. a. Government authorities, law enforcement bodies and regulators for compliance with legal requirements; b. Trusted clinic/hospital service providers required to deliver the clinical services you have asked for, such as but not limited to, management of breast pathology; c. Referring doctors; d. Credit and debit card companies which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment to process payment or ensure the security of your payment transaction; e. Legal, accounting/audit and other professional advisers, law courts and law enforcement bodies in order to enforce our legal rights in relation to our provision of services to you; We may disclose your information to trusted third parties for the purposes set out in this Privacy Notice. Such third parties can be medical Insurance companies, referring doctors/clinicians and/or government authorities. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with Maltese laws and the EU Regulation 2016/679 on data protection. We may transfer your personal data to NON-EU countries in the case of emigration procedures. In such cases, appropriate safeguards are foreseen to ensure that the same level of protection is applied to your data. Cookies and site tracking Our Radiology Clinic website does not use cookies. Cookies are small text files that are transferred to your computer's hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site; thus enabling us to understand better the products and services that will be most suitable to you. A cookie contains your contact information and information to allow us to identify your computer when you travel around our site for the purpose of helping you accomplish your reservation. Most Web browsers automatically accept cookies, but, if you wish, you can change these browser settings by accepting, rejecting and deleting cookies. The "help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to change these settings, you may find that certain functions and features will not work as intended. The cookies we use do not detect any information stored on your computers. For more information about cookies and how to stop cookies being installed visit the following website: http://www.allaboutcookies.org. We DO NOT use tracking software to monitor customer traffic patterns and site usage to help us develop the design and layout of the website. Your Data Protection Rights Under certain circumstances, by law you have the right to: • Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it. • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. • Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you. • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you. We will, however, need to keep your data for legal purposes. • Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in a machine-readable format and to be able to transfer your data to another party in the same fashion. • Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, for instance adhesion to the breast screening programme, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. If you want to exercise any of these rights, then please contact our DPO by post at The Radiology Clinic, Flat 1 Beatrice Flats, Giuseppe Cali St, Ta' Xbiex XBX 1423 Malta or via email at dpo@kyte.global . You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. If you have any complaints regarding our processing of your personal data, please note that you may contact us at dpo@kyte.global If you are a European resident and you have a concern about our use of your information, or you wish to file a complaint, you can contact your local data protection regulator. A list of European data protection regulators can be found here: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm Changes to Privacy Notice Our Privacy Notice may change from time to time and any changes to the statement will be communicated to you by way of an e-mail or a notice on our website. Version 1.0 May 2018 May 2018