Privacy policy

Locala Choose Well is fully committed to protecting your privacy. All information collected on our website will be used solely to process orders and provide you with a more personalised experience. Any information provided to Locala Choose Well will be managed in accordance with the Data Protection Act 1998 and transmitted via a secure connection.

The purpose of this Privacy Notice

The purpose of this Privacy Notice is to let you know how we process your Personal Data when you engage with our services or visit our website. This Privacy Notice explains what Personal Data we collect from you and how we collect, use, store and disclose it. This Privacy Notice also contains information about your rights under applicable data protection legislation.

We are committed to compliance with the applicable data protection legislation. We believe that ensuring data protection compliance is the foundation of trustworthy relationships.

It is important that you read this Privacy Notice together with any other Privacy Notice we 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.

What information do we collect about you?

All clinicians, health and social care professionals caring for you, keep records about your health, and any treatment and care you receive from Locala Choose Well. These records help to ensure that you receive the best possible care. They may be paper or electronic and they may include:

• Basic details about you such as name, address, email address, NHS number, date of birth, next of kin, etc.
• Contact we have had with you such as appointments or clinic visits.
• Details of diagnosis and treatment given
• Information about allergies or health conditions.

It is essential that your details are accurate and up to date. We will always check that your personal details are correct when you visit us and please inform us of any changes to your contact details or GP Practice as soon as possible. This minimises the risk of you not receiving important correspondence.

By providing Locala Choose Well with your contact details, you are agreeing to us communicating with you about your healthcare, i.e. by letter (postal address), by voice mail or voice message (telephone or mobile number), by text message (mobile number) or by email (email address).

How your personal information is used and collected

In general terms, your records are used to direct, manage and deliver your care so that out team will have the information they need to assess and improve the quality and type of care you receive and your concerns can be properly investigated if a complaint is raised.

How long health records are retained

Information is held for specified periods of time as set out in the The Records Management Code of Practice for Health and Social Care 2021.  20240111-NHSE-Records-Retention-Schedule.pdf

Legal basis for the processing of your data

The UK GDPR requires that a Controller must have a legal basis for processing Personal Data. These may be:

• Your consent. We will obtain you consent directly from you, and you are able to withdraw your consent at any time. You can do this by contacting [email protected]
• We have a contractual obligation.
• We have a legal obligation.
• We have a vital interest.
• We need it to perform a public task.
• We have a legitimate interest.

In some cases, we may process special category data. This is afforded some extra protection due to its sensitive nature, and therefore, under UK GDPR we are required to provide a lawful basis for processing, and a secondary condition under Article 9. The conditions we may rely on are:

• Explicit consent
• Employment, social security and social protection (if authorised by law)
• Vital interests
• Not-for-profit bodies
• Made public by the data subject
• Legal claims or judicial acts
• Reasons of substantial public interest (with a basis in law)
• Health or social care (with a basis in law)
• Public health (with a basis in law)
• Archiving, research and statistics (with a basis in law).

Transfers of information Outside the European Economic Area

Locala Choose Well ensures that personal confidential data, even it would constitute fair processing, is not, unless certain exemptions apply or protective measures taken, disclosed or transferred outside the European Economic  Locala Choose Well takes payment information through Stripe Payments UK and Stripe do transfer data outside of the EEA.  Please see their Privacy Policy.

When do we share information about you?

We share information about you with others directly involved in your care. We use information we hold about you to:

• Review the care we provide to ensure it is of the highest standard and quality
• Ensure our services can meet patient needs in the future
• Investigate patient queries, complaints and legal claims
• Prepare statistics about organisation’s performance
• Audit Locala Choose Well accounts and services

Everyone working within Locala Choose Well has a legal duty to keep information about you confidential. Similarly, anyone who receives information from us also has a legal duty to keep it confidential.

We will not disclose your information to any other third parties without your permission unless there are exceptional circumstances, such as if the health and safety of others is at risk or if the law requires us to pass on information.

Nationally there are strict controls on how your information is used for these purposes. These control whether your information has to be anonymised first and with whom we may share identifiable information.  

Care Quality Commission

The Care Quality Commission has powers under the Health and Social Care Act 2008 to access and use information – including personal and medical records – where they consider this is necessary for them to carry out their functions as a regulator. They also have powers to access and use information as part of their role protecting the rights of people whose rights are restricted under the Mental Health Act 1983, and powers under the Health and Safety at Work Act 1974.

If you do not want CQC to look at your personal information when they check our services, please let us know. We can mark your records to show that you do not want CQC to see them.

If we know that you don’t want CQC to look at your information, your wishes will be respected, other than in rare circumstances which are explained in their Code of Practice on Confidential Personal Information here.

You can change your mind about your choice at any time.

Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.

Since 2020, Health and care organisations are required to have systems and processes in place so they can apply your national data opt-out choice. Locala Choose Well is not currently able to apply your national data opt-out choice to any confidential patient information we may use or share with other organisations for purposes beyond your individual care.  The national implementation plan is available on the nhs.uk website.

When other people need information about you

Everyone working in Health and Social Care has a legal duty to keep information about you confidential and anyone who receives information from us is also under a legal duty to keep it confidential.

From time to time, we may need to share information with other professionals and services concerned in your care. We will only share information in this way if we have your permission and it is considered necessary. 

Other ways in which we use your information

SMS text processing

When attending one of our services for an outpatient appointment or a procedure you may be asked to confirm that we have an accurate contact number and mobile telephone number for you. This can be used to provide appointment details via SMS text messages and automated calls to advise you of appointment times.

Surveillance Cameras (CCTV)

Some of the premises we use have surveillance cameras (CCTV) for the purpose of prevention and detection of crime as well as to:

• protect staff, patients, visitors and Trust property
• apprehend and prosecute offenders, and provide evidence to take criminal or civil action in the courts
• provide a deterrent effect and reduce unlawful activity
• help provide a safer environment for our staff
• assist in traffic management and car parking schemes
• monitor operational and safety related incidents
• help to provide improved services, for example by enabling staff to see patients and visitors requiring assistance
• assist with the verification of claims

You have a right to make a Subject Access Request of surveillance information recorded of yourself and ask for a copy of it. Please see the ‘Data Subjects Rights’ section. The details you provide must contain sufficient information to identify you and assist us in finding the images on our systems.

We reserve the right to withhold information where permissible by Data Protection Legislation and we will only retain surveillance data for a reasonable period or as long as is required by law. In certain circumstances (high profile investigations, serious or criminal incidents) we may need to disclose CCTV data for legal reasons. When this is done there is a requirement for the organisation that has received the images to adhere to Data Protection Legislation.

Security of information

Confidentiality affects everyone: Locala Choose Well collects, stores and uses personal and special category personal data every day, such as medical and clinical records, personal records and computerised information. This data is used by many of our colleagues in the course of their work.

We take our duty to protect personal information and confidentiality very seriously and we are committed to comply with all relevant legislation and to take all reasonable measures to ensure the confidentiality and security of personal data for which we are responsible, whether computerised or on paper. All our colleagues are bound by a duty of confidentiality and undertake regular training.

At Board level, we have appointed a Senior Information Risk Owner who is accountable for the management of all information assets and any associated risks and incidents, and a Caldicott Guardian who is responsible for the management of patient information and patient confidentiality.

Additionally, we put in place appropriate organisational and technical security measures. These measures include ensuring our internal IT systems are suitably secure and implementing procedures to deal with any suspected data breach.

In the unlikely event of a data breach, we will take steps to mitigate any loss or destruction of data and, if required, will notify you and any applicable authority of such a breach.

Although we use appropriate security measures once we have received your Personal Data, you will appreciate that the transmission of data over the internet (including by email) is never completely secure. We endeavour to protect Personal Data, but we cannot guarantee the security of data transmitted to or by us.

Examples of our security include:

• Encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password). This is done with a secret code or what is called a ‘cypher’. The hidden information is said to then be ‘encrypted’.

• Pseudonymisation, meaning that we’ll use a different name or key so we can hide parts of your personal information from view.  This means that someone outside of Locala could work on your information for us without ever knowing it was yours.
• Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it.
• Data stewardship is a way for us to be clear about who is responsible for what data and sets out clearly who has access to the data – limiting access to only those who need it to carry out our duties.

• Regular testing of our technology and ways of working including keeping up to date on the latest security updates.

Individual Rights

You have rights under the data protection legislation and these are:

Right to be informed 

Subject Access

Right to Rectification

Right to Erasure

Right to Objection

Right to Restriction

Right to Portability

Right to withdraw consent

Right related to automated profiling 

Right to complain

Subject to certain legal exemptions, we must comply when you inform us that you wish to exercise these rights. There is no charge, unless your requests are manifestly unfounded or excessive. In such circumstances, we may make a reasonable charge or decline to act on your request. Before we action your request, we may ask you for proof of your identity. Once in receipt of this, we will process the request without undue delay and within one calendar month. In order to exercise your rights please contact our Resolution Team. Details of how to contact the Resolution Team are below.

You can contact us if you wish to complain about how we collect, store and use your Personal Data. It is our goal to provide the best possible remedy with regard to your complaints.

However, if you are not satisfied with our answer, you can also contact the relevant competent supervisory authority. In the UK, the relevant supervisory authority is the ICO, contact details of which can be found below.

How can you access your records?

The UK GDPR gives you a right to access the information we hold about you on our records. Requests should be made to the Resolution team. We will provide your information to you within one month (this can be extended dependent on the complexity of the request) from receipt of your application:

Before fulfilling your request, we will need to be able to verify your identity and will ask you to provide relevant documents. 

Information will be provided free of charge except where requests are unfounded or excessive, in particular repeat requests when we may either charge a reasonable administrative fee or refuse to act on the request.

Locala Choose Well,

Eddercliffe Health Centre,

Bradford Road,

Liversedge,

WF15 6LP

or via email to [email protected].

Data controller

The Data Controller responsible for keeping your information confidential is:

Locala Health and Wellbeing,

Eddercliffe Health Centre
Bradford Road,

LIversedge,

West Yorkshire,

WF15 6LP
Data Protection Officer is Hayley Silverwood.

The Data Protection Officer’s role is to monitor and advise the organisation on meeting its data protection responsibilities. 

Our Caldicott Guardian is Victoria Vallance, Director of Quality and Professional Practice. She can be contacted using the details below.

Email: [email protected]

Raising a concern

Patients who have a concern about any aspect of their care or treatment from Locala Choose Well, or about the way their records have been managed, should contact the Customer Liaison Team on [email protected].

If you have any concerns about how we handle your information you have a right to complain to the Information Commissioners Office about it.

The UK GDPR requires organisations to lodge a notification with the Information Commissioner to describe the purposes for which they process personal information. These details are publicly available from:

Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, SK9 5AF

Telephone: 08456 306060

Website: ico.org.uk

Your obligations

If any of your Personal Data changes whilst you are a user of our services, it is important that you update the information within your account to ensure that the data we hold about you is accurate and up to date.

We operate according to the principles of the UK GDPR, and PECR, regardless of the location of the data subject.

Changes to this Privacy Notice

We reserve the right to update this Privacy Notice from time to time. Updates to this Privacy Notice will be published on our website. To ensure you are aware of when we make changes to this Privacy Notice, we will amend the revision date at the bottom of this page. Changes apply as soon as they are published on our website. We therefore recommend that you visit this page regularly to find out about any updates that may have been made.

Version 1

February 2025