GDPR – May 2018

About this Privacy Notice

The confidentiality of patient information is of paramount importance to The Rutherford Cancer Centres Limited. This Privacy Notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us in accordance with UK data protection legislation.

We may need to update this Privacy Notice from time to time and where we are already processing your personal data we will notify you of any significant changes.

Who we are

The Rutherford Cancer Centres Limited is a Company registered in England and Wales (company number 10680302).

We operate a network of oncology centres nationally and internationally, providing a range of cancer services for patients. We are a wholly owned subsidiary of Proton Partners International Limited, a company incorporated and registered in England and Wales (company number 09420705) committed to providing innovative cancer treatment.

Information about our services is available on our website http://www.therutherford.co.uk/about-us/

Where the term ‘we’ or ‘us’ is used, this relates to Proton Partners International Limited and The Rutherford Cancer Centres Limited.

Our nominated representative, for the purpose of data protection legislation, is our Data Protection Officer whose contact details can be found at the end of this notice.

What is personal data?

The term ‘personal data’ relates to any information that can, or has the potential to, identify you as an individual such as your name, address, e-mail address, phone number. It also includes less obvious information such as identification numbers, electronic location data and other online identifiers.

Certain types of personal data are referred to in data protection legislation as ‘special categories’ of personal data. This is because they are classed as more sensitive and require additional protection.

Such information includes information about an individual’s:

  • Race
  • Ethnic origin
  • Politics
  • Religion
  • Trade union membership
  • Genetics
  • Biometrics (where used for identification purposes)
  • Health
  • Sex life
  • Sexual orientation

Processing personal data in line with data protection legislation

We will process your personal data in line with data protection legislation as follows:

  • We will always process personal data lawfully and fairly and in a transparent manner. We will ensure this Privacy Notice is available on our website and relevant extracts are provided when you register for our services.
  • We will process personal data to provide the range of services available at the Rutherford Cancer Centres and as described in this Privacy Notice.
  • We will ensure that whenever we collect personal data it is adequate, relevant and not excessive in relation to the purpose for which it is being processed.
  • We will ensure information processed is accurate and kept up to date by asking you to confirm when you access our services that the information we hold about you is correct.
  • We will ensure that your personal data is kept in a form that allows us to identify you for clinical purposes but is not kept in an identifiable format for longer than is needed. Where we need to keep your identifiable data longer for scientific, research or statistical purposes we will ensure that the appropriate technical and organisational measures are applied to protect the confidentiality of the information.
  • We will ensure that the processing of your personal data is carried out securely and confidentially. This means that we have policies, procedures and training in place to ensure robust security controls are applied to the processing of your data.

What personal data do we collect?

We collect personal data and special category data (where relevant). The type and amount of personal data we collect will depend on our relationship with you as described below:

1. Making enquiries about our services

When you contact us in person, by telephone, email, fax, letter, social media or through completion of a website enquiry form, to enquire about the services we offer, we will only collect personal data that is necessary to enable us to respond to your enquiry. The type of information collected will depend on the type of enquiry.

The types of information we will routinely collect on an enquiry will include:

  • Name
  • Address
  • Contact details
  • Nature of enquiry

To help us deal with your enquiry we may also need to collect more detailed information about your personal circumstances and health such as:

  • Diagnosis
  • Current health condition
  • GP and, or, consultant details
  • Information on current treatments

We may need to share your information with our team of healthcare professionals and medical practitioners to help us provide you with the most appropriate response to your enquiry.

If you provide personal information about another individual, you must inform them of this Privacy Notice. We will never relay or discuss personal information we hold about an individual to another individual without their consent or where evidence is provided of a lawful basis i.e. power of attorney.

2. Referrals and treatment

When an initial referral is received asking us to consider you for consultation and, or treatment, personal data is provided to us by the referring source. The sources from where we receive information may include, and are not limited to:

  • Patient self-referral
  • GPs
  • Clinicians (including their medical secretaries)
  • Hospital and healthcare provider establishments
  • Commissioning bodies
  • Agencies
  • Embassies

Information that may be received may include your personal contact details, information on your medical history, diagnosis and conditions, this forms part of your health record. As part of the consultation and booking process we may also request and receive scans and images from other healthcare providers.

Personal data is collected and recorded electronically, and in paper form, as part of the booking and treatment process at the Rutherford Cancer Centres, and which is required as part of the contract for services. Failure to provide this type of data may result in the inability to provide our services.

Health Records

Health records are created to record care and treatment received as a patient. The type of information collected and recorded in your health record may include and not limited to:

  • Personal data in relation to; your name, address, date of birth, ethnicity, contact details and next of kin
  • Medical history, referral, diagnosis, tests, scans, images, treatment, information on appointments, GP and referring clinician

Health records are created and stored under strict security and confidentiality controls which include unique system access to electronic records and physical security of hardcopy information.

Only information necessary for the arrangement and provision of treatment is collected. Information received and created is stored securely and is only accessed and shared by those involved in your treatment and care.

Roles involved in your treatment and care may include medical and administrative staff, finance staff responsible for coding and invoicing your treatment, multi-disciplinary care teams, clinical audit leads, consultants and private secretaries who are responsible for the administration of appointments.

Personal data in addition to health records

In addition to receiving information on your health status and condition, we will also process personal information that is required to prepare for, and to enter into, a contract for services. This may include payment method information, information from your insurers, agency, or commissioning body (where relevant).

3. Individuals captured on our CCTV system

We use CCTV cameras in our centres to protect the safety of our visitors, premises and our car parks. Personal images may be captured during recording. Signs are clearly displayed to inform visitors of CCTV recordings and recording will only be undertaken in public areas such as car parks and entrances to centres. All recordings are held securely and deleted after 30 days in line with our retention policy.

What is our lawful basis for processing your personal data?

Under data protection legislation we must always have a lawful basis for using personal data and special category data (as described earlier). The law provides a set of lawful purposes for processing personal data, such as:

The processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.’ (The Contract Basis)

‘The data subject has given consent to the processing of his or her personal data for one or more specific purposes.’ (The Consent Basis)

‘Processing is necessary for compliance with a legal obligation to which the controller is subject.’ (The Legal Obligation Basis)

‘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.’ (The Public Interest Basis)

‘The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.’ (The Legitimate Interests Basis)

When processing special category data there are different lawful purposes that also need to be identified, in addition to those set out above, such as:

‘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 and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3.’ (The Health Care Basis)

‘Processing is necessary in order to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent.’ (The Vital Interests Basis)

Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.’ (The Legal Claims Basis)

‘Processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law’ (The Substantial Public Interest Basis)

‘Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Union or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject, in particular professional secrecy.’ (The Public Health Basis)

‘Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.’ (The Scientific Research Basis)

‘The data subject has given explicit consent to the processing of those personal data for one or more specified purposes.’ (The Explicit Consent Basis)

Depending on the reason for us processing your personal data, there may be several lawful purposes that will apply, and which may be relevant at different times. This section describes the lawful basis for processing personal data and special category data at the Rutherford Cancer Centres.

We set out below the lawful bases that we will rely upon. To make it easier to understand which of these applies to you we have specified the lawful bases for each of the categories of individual whose personal data we process.

1. Making enquiries about our services

When you contact us to enquire about our services and ask us for information with a view to receiving services from us the legal ground we will rely upon to process your personal data to deal with your enquiry and provide you with information will be The Contract Basis.

Where this involves processing any personal data relating to your health we will also rely on The Healthcare Basis for processing.

2. Referrals and treatment

Processing of Personal Data

When a referral is made to us for treatment, either by self-referral or from another source, we will enter into an agreement for services with you and accordingly we will be relying on The Contract Basis for many processing activities which are required for us to be able to fulfil that agreement. This will include matters such as information you of appointments, providing treatment and taking payment for our services.

If your treatment is carried out under a contract we have with the NHS and no contract is in place with you directly we will be acting on behalf of the NHS in these circumstances and will rely on The Public Interest Basis for processing your personal data in connection with your treatment.

As a provider of health care services, we are required to comply with a range of legal and regulatory requirements for the treatments and services we provide. These include and are not limited to; recording decisions made in relation to Ionising Radiation Protection (Medical Exposure) Regulations (IRMER), and creation of accurate records of the medicines administered to patients in line with the Medicines and Healthcare Products Regulatory Agency.

There may be occasions where complaints or claims are made against us or an independent medical practitioner. It is therefore important that accurate information has been recorded about the treatment provided to a patient as this may be required as part of investigating the complaint or claim.

In addition, various bodies regulate healthcare providers who have the legal powers to require information to be disclosed to them about patients as part of their audit processes. Where such access is given the information is reviewed under strict confidentiality requirements.

For personal data processed in these circumstances we will be relying on The Legal Obligation Basis for processing.

The processing of your personal data by us for research and development into proton therapy is in our commercial interests as a provider of healthcare services and our aim to contribute to broader societal benefits. The processing of your personal data for research and development enables us to provide you with an improved healthcare service to you, which is in our and your interests. In such circumstances we will be relying on The Legitimate Interests Basis for processing.

We support and participate in audit and research programmes to enable the analysis and measurement of the effectiveness of treatment. Therefore, information gathered as part of the provision of treatments will be reviewed by those responsible for internal audit programmes and, also reviewed by external regulating bodies such as Healthcare Inspectorate Wales and Care Quality Commission, during site inspections, and who are bound by confidentiality requirements.

We may also share anonymised and aggregated patient information with organisations such as the National Institute for Clinical Excellence, and research partners for research or statistical purposes. Any information shared for these purposes will be fully anonymised unless you have given us your consent to provide “identifiable” personal data, in which case we will rely on The Consent Basis for sharing the personal data.

Processing of Special Category Data

In the planning and delivery of our services, for internal research purposes and for providing treatment and services to you, it is necessary for us to process special category data in relation to you. In such circumstances we will also rely on The Health Care Basis for processing.

There may be situations where complaints or claims are made against us a company or against our independent medical practitioners and where the processing of special category data is necessary to respond to those complaints or claims.

The lawful purpose we would rely on for special category data in these circumstances is The Legal Claims Basis.

It is important to us that we monitor the accuracy and quality of treatment we provide. We undertake quality audits to ensure high standards of quality and safety in our health care provision. Therefore, personal data collected when you access our services may be reviewed by:

  • Internal auditors who will assess that information has been collected and recorded accurately
  • External auditors such as regulating bodies to check that accurate information has been recorded (where such audits are carried out, strict confidentiality guidelines are adhered to)
  • Insurance companies, where you have accessed our services under your insurance policy – specialist clinical roles within the insurance company may request certain data to check that we are providing a high quality clinical service for their customers
  • Commissioning bodies such as the NHS where we provide a contract for clinical services, may undertake audits on the quality of our care

Where this involves the processing of special category data we will also rely on The Public Health Basis to process the data. On occasion emergency medical care may be required but you are incapable of giving consent to the processing of the personal data for medical purposes.

For example, an individual is admitted to an A & E department of a hospital with life-threatening injuries following an accident, and the hospital requires disclosure from the Rutherford Cancer Centres of the individual’s medical history. In such circumstances and in other emergency situations we will rely on The Vital Interests Basis for processing the personal data.   

There may be circumstances where we require your consent such as involvement in specific research projects. In such circumstances we will ensure we provide you with full information to allow you to make an informed decision and will only process your personal data in this way where we can rely on The Explicit Consent Basis for processing.

Use of Data for Cancer Registration

As a UK resident when you are diagnosed with cancer some information about you and your cancer is collected by your national cancer registry. Each country in the UK has its own national cancer registry for its resident population. The registries contain information about each person who has been diagnosed with cancer. Information is collected at a national level and is used to record how many people are diagnosed with cancer, what treatments they have and how well treatments work. It is used to provide national cancer statistics, plan and monitor NHS cancer services, find where new cancer services or improvements are needed and help with research into cancer, for example into potential causes or new treatments. Each cancer registry is authorised, by law, to collect this information and strict rules are imposed to make sure the information collected is kept under the highest levels of security.

The registry contains information about each person who has been diagnosed with cancer including: - name, address, date of birth, type of cancer, when and how you were diagnosed, what treatments you have had. Personal information, such as your name and address, is collected to make sure that all the information about you is accurately linked together. Collectively this information is used to provide national cancer statistics, plan and monitor NHS cancer services, find where new cancer services or improvements are needed, and help with research into cancer. Reports used for analysis are always anonymous and will never identify individuals even if they have a rare cancer.

When you attend our Centres for services you will be provided with a consent form which provides information on the cancer registries. We will rely on The Explicit Consent Basis to process your special category data. Only the minimal amount of personal data needed for the research purpose will be processed and where possible any personal data will be pseudonymised.

3. Individuals captured on our CCTV system

We process the personal data captured by the CCTV system:

  • to prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime
  • for the personal safety of staff, visitors and other members of the public, and to act as a deterrent against crime.

The images may be shared with the police, prosecution agencies or relevant legal representatives.

We will rely on The Legitimate Interests Basis to record and process and share the CCTV images. Our specific legitimate interests are the prevention of crime, protection of property and safety of individuals. Where the processing involves special category data we will also rely upon The Substantial Public Interest Basis, namely that the processing is necessary to prevent or detect an unlawful act.

4. Individuals who contact us by telephone

We record our telephone calls for quality and training purposes. We will rely on The Legitimate Interests Basis for processing your personal data. Our specific legitimate interest is the business need to maintain and improve the quality of our service. Where the processing involves special category data we will only do so where we can rely on The Express Consent Basis for processing.

Who your information is shared with

Healthcare Professionals

We employ a range of healthcare professionals to deliver our services, including nurses, radiographers, physicists, dosimetrists, play therapists, medical advisors, and a range of administrative roles.

In addition to our employed staff, medical practitioners and allied health professionals register with us to hold a private practice licence. Medical practitioners (often referred to as consultants) and allied health professionals are self-employed independent practitioners who must comply with our policies and procedures and ensure the safe processing of information within their private practice. You will be provided with information about their services and fees as part of the booking process.

At all times, healthcare professionals are responsible for complying with data protection legislation when handling your personal data, including any processing carried out by their private secretaries.

They are bound by our confidentiality and security policies, and applicable medical confidentiality guidelines, as well as their own codes of practice issued by their respective professional and regulating bodies which include the Health and Care Professions Council, General Medical Council, Nursing and Midwifery Council.

Disclosures within the company

The Rutherford Cancer Centres Limited is a subsidiary of Proton Partners International Limited, accompany based in the UK. Proton Partners International Limited provides central resources to the Rutherford Cancer Centres including finance, governance, internal auditing, senior management, marketing, health and safety and business development.

Types of processing of personal data that is undertaken by Proton Partners International Limited may include and not limited to; invoicing and accounting, review of records in relation to internal audit, review of health, safety and clinical incidents, management of mailing lists where individuals have opted in, review and management of complaints.

Access to your personal data and your health information is strictly controlled to ensure access is only allowed to those roles that require access and is in line with the lawful processes described in this notice. Sharing of your personal data with Proton Partners International Limited will usually be for company administrative purposes and in such circumstances we will rely on The Legitimate Interests Basis for sharing the information. Our specific legitimate interests are that it is commercially beneficial to have centralised responsibility for accounts and that it is beneficial to review matters and conduct audits across the group in order to ensure consistency of approach and standards.

Where special category personal data is shared this will be done based on The Legal Claims Basis, The Public Health Basis, The Health Care Basis or The Scientific Research Basis. If none of these legal bases are applicable, we will seek your Express Consent before sharing the information.

Sharing with other Healthcare Organisations

For your benefit, we may need to share your personal data as part of your treatment and care with other healthcare organisations e.g. your GP, NHS, ambulance services, and organisations who provide support services to us (diagnostic services, wellbeing services etc.).

Any sharing of personal data will only be undertaken where it is deemed ‘necessary’ in relation to your care and treatment and, where such data sharing is undertaken, contracts and data sharing agreements will be in place with the third party which stipulate the confidentiality and security and use of data shared.

Routine disclosures of personal data may include disclosures to:

  • Clinical roles involved with the planning and treatment of your care
  • Medical practitioners who review and advise on your treatment and care
  • Support roles such as bookings and reception staff and enquiry handlers
  • Individuals you have identified as emergency contacts
  • GPs
  • NHS bodies
  • Your clinician overseeing your care and their medical secretaries
  • Where you access services through your insurance policies, we will liaise with your insurer over your treatment and care and may be required to disclose information for the purpose of quality assurance

We will rely on The Legitimate Interests Basis for sharing the information. Our specific legitimate interests are that it is in your interests and ours that you have complete healthcare provision and that sharing with other health professionals will allow a consistent approach and to ensure that treatments are compatible.

Where special category personal data is shared this will be done based on The Public Health Basis, The Health Care Basis or The Scientific Research Basis. If none of these legal bases are applicable, we will seek your Express Consent before sharing the information.

We may also share your personal information with family or friends that you have given us as emergency contacts. We will rely on The Consent Basis and/or Explicit Consent Basis for sharing our personal information in these circumstances.

Third Parties

Within the day to day running of our business, we may use third party organisations to support the essential delivery of services. These may be; IT service providers, storage & shredding companies, debt management companies.

Where third party organisations are used, who may have access to your personal data, we ensure that a contract is in place and security checks are undertaken.

We may also be required to share personal information to prevent fraud and to assist the police in the prevention and detection of a crime.

International Transfers

We do not envisage the need to transfer your personal data outside the EEA. If this does become necessary we will let you know. However, rest assured that if we do transfer your personal data outside the EEA, we will use one of these safeguards to make sure it is protected:

  • We will only transfer it to a non-EEA country which the European Commission has decided has an adequate level of protection for personal data; or
  • We will put a written contract in place between us and the recipient that incorporates EC model clauses relating to the transfer of personal data outside the EEA; or
  • We will obtain your specific consent to the transfer.

How we communicate with you

We may communicate with you by letter, telephone, email, or text. We will ask you which method of communication you prefer.  It is important that you provide us with accurate information so that we can ensure the information we relay to you is done so in a confidential manner.

Where you request to receive all your information by email we may not be able to guarantee the security of information sent over the internet, but will discuss with you the options for password protecting and encryption of confidential health information that are sent by email.

It is important that we review and assess the quality of our services. Therefore, where you have accessed our services, we may contact you to ask you to complete a patient satisfaction survey.

It is also important that we monitor the outcomes of treatments provided, this is known as Patient Reported Outcome Measures (PROMS). To monitor outcomes, we may ask you to complete questionnaires relating to your health and quality of life or be interviewed over a period of time. We will talk to you about this during your treatment.

How we protect the security and confidentiality of your personal data

All employees are bound by contractual confidentiality clauses in employment contracts, receive mandatory training in data protection and confidentiality and process information under the direction of mandatory policies and procedures. Audits are carried out to ensure information recorded and created is accurate, up to date and kept securely.

Marketing

We would like to keep you updated on the services and treatments that we provide at our cancer centres but will only do this where you have opted in to receive such updates in which circumstances we will rely on The Consent Basis for the processing. When you access our services you are provided with an option to join our mailing list. You may also have the opportunity to opt in through links or forms when you visit our website or when you complete a registration form as part of your treatment. When you opt in to receive information on our services, should you wish to stop receiving updates you can contact us and we will remove you from any mailing lists.

We never share or sell your data to external marketing companies.

Your rights under data protection legislation

The right to be informed

You have the right to be informed of how we process your personal data. We inform you of how we process your data, through the provision of this Privacy Notice, and in notices we provide when you register for our services. We also inform you of other types of processing such as call recording or CCTV through notices and recorded messages. You can also contact us at any time to query any aspect of the processing of your data.

The right to access your personal information

You may contact us to request details of the type of processing we carry out on your personal data and a copy of the personal information which we hold about you. This is known as a Subject Access Request and must be submitted in writing to either the centre manager at the Rutherford Cancer Centre where you have accessed services or directly to the Data Protection Officer at the address shown below.

We must process your request within one month of receipt of the request, however, if it is a complex request we may need to extend this by up to two months. You will be kept informed if an extension is required.

The right to rectification

You have the right to have incorrect personal information amended or completed if it is incomplete.

The right to erasure

You have the right to request that we delete the personal information we hold about you. However, there are exceptions to this and in certain circumstances we may not be able to comply with your request. For example, the right of erasure of personal information does not apply to special category data where it is being processed for medical diagnosis and the provision of health and social care.

The right to restrict processing

You have the right to limit the way we use your personal information in certain circumstances. For example, this may occur if:

  • you have asked us to amend inaccurate information and we need to verify the accuracy or
  • you feel that your information has been unlawfully processed

The right to data portability

Where we are processing personal data purely in electronic format, there may be circumstances where you can request to have your data transferred (if technically possible) to another individual or organisation of your choice in an electronic format.

The right to object

You have the right to object to the processing of your personal data in certain circumstances:

Direct Marketing:

You can ask us to stop processing your personal data for direct marketing at any time. When we receive an objection to processing for direct marketing we must stop processing your data for this purpose.

Legitimate Interests:

You have the right to object to us processing your personal data for our legitimate interests (i.e. our business reasons) however you must give specific reasons to why you are objecting. We may not be able to meet your request depending on the reasons stated.

The right to withdraw consent

Where we rely on the Consent Basis or the Explicit Consent Basis to process your personal data you have the right to withdraw your consent to the processing at any time. Any withdrawal of consent will not affect the lawfulness of any processing which has already taken place before the consent was withdrawn.

Automatic decision-making and profiling

Decisions on treatment will be made, by healthcare professionals, on an individual case-by-case basis. We do not use automated decision-making tools or profiling when you provide us with personal information.

Personal data collected when using our website

When you visit our website, we automatically collect the following information:

  • Technical information, including the Internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
  • Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Tracking Performance of our Website – Use of Cookies

The 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.

We use Google Analytics cookies to collect information about how visitors use our site. Cookies are small files which are stored on a user’s computer, designed to hold a small amount of data specific to a particular user and website. Using cookies allows us to collect information about how visitors use our website.

Google Analytics sets four types of first-party cookies automatically:

  • _utma
  • _utmb
  • _utmc
  • _utmz

These cookies track the number of visitors to our website, how long the website sessions last, and note where the website visitor arrived from. The information collected by these cookies is anonymised and visitors cannot be identified. We will use this information to write reports and make improvements to the website.

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.

Our collection and use of the above information is based on The Legitimate Interest Basis for processing. We have a legitimate interest in ensuring that our website is user friendly and appeals to our patients and other users.

How long do we keep personal data for?

Under data protection legislation personal data must only be processed for as long as it is necessary and not kept for an excessive period of time. The following table provides information on the retention periods for the type of data routinely processed at the Rutherford Cancer Centres. To ensure we can always provide the highest level of care and to ensure that we can monitor outcomes and conditions over a long period of time it is fundamental that certain information about individuals’ health is maintained so that it can be referred to at a later date.

Type of record

Retention period

Oncology records of any patient

Minimum of 30 years or 8 years after death of patient

All other medical records

30 years

Pathology

In relation to clinical need

CCTV (which is installed in areas such as car park, waiting room, clinical corridors)

Maximum of 30 days

Credit card details (no outstanding debt on patient’s account)

6 months

Credit card details (outstanding debt on patient’s account)

6 months

Invoices to patient

6 years

Patient email enquiries

6 years

Patient surveys

6 years

Complaints file

30 years

Litigation file

30 years

Subject access request (SAR)

3 years

Subject access request (SAR) if there has been an appeal

6 years

Referrals not accepted

2 years as an ephemeral record

Call recording (may be used for clinical negligence purposes)

3 years

Recorded conversation (forms part of health record)

Stored as a health record

Clinical trials and research – research data sets

20 years

Incidents (serious)

20 years

Incidents (not serious)

10 years

Complaints file

10 years

Litigation records

10 years

How to contact us

You can contact the Data Protection Officer by writing to us at:

The Data Protection Officer
The Rutherford Cancer Centres Limited
Celtic Springs
Spooner Close
Newport
NP10 8FZ

How to complain

If you believe that your information has been unfairly or unlawfully used, you have the right to contact the Information Commissioner’s Office at the address below:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745

This Privacy Notice was updated on 28th June 2018