PRIVACY POLICY

Introduction

At The Express Clinic, we take the issue of your privacy very seriously, which is why we work hard to ensure we have policies and procedures in place that allows us to continue our mission of providing COVID-19 tests to the UK community. The following privacy policy explains what personal data we collect from you, or that you provide to us, how we process it and what we do to keep it safe and as such we look to work in accordance with the Data Protection Act 2018.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. 

Who we are and what we do 

We’re TRM Enterprises UK, trading as The Express Clinic, providers of COVID-19 testing to the UK community. We are registered at UK Companies House and our company number is 12947098 our office is based at 5th Floor, The Grange, 100 High St, Southgate, N14 6BN, England.

 

We collect personal data of the following types of people to allow us to undertake our business:

  • You, our patients or prospective patients who purchase a laboratory test or book an in-person sample appointment.

  • Pharmacies and labs that we partner with for the provision of our service.

  • Our own employees, contractors, partners and shareholders.

We collect information about you to carry out our core business and ancillary activities.

Information you give to us or we collect about you

This is information about you that you give us by registering on or filling in forms on our site www.theexpressclinic.com and corresponding with us by phone, e-mail or otherwise. It includes information you provide when you purchase a laboratory test or book an in-person sample appointment, enter our database, subscribe to our services, enter a promotion or survey, and when you report a problem with our site.

The information you give us or we collect about you may include your name, e-mail address, age, date of birth, gender & passport number (if you are due to travel from or to the UK).

Information we collect about you when you visit our website.

With regard to each of your visits to our site we will automatically collect the following information:

technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform;

information about your visit, including the full Uniform Resource Locators (URL) and how you interact with our site.

Purposes of the processing and the legal basis for the processing

We use information held about you in the following ways:

To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information and services that you request from us or we think will be of interest to you because it is relevant to your specific medical needs.

To provide you with information about other services we offer that are similar to those that you already utilise, been provided with or enquired about.

Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.

We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal obligations.

Our Legitimate Business Interests

We have a number of lawful reasons that mean we can use your personal information, including your consent, where you give it. One lawful reason is something called ‘legitimate interests’. In general terms, “Legitimate Interests” means we can process your personal information if:

  • We have a genuine and legitimate reason; and

  • We are not harming any of your rights and interests.

Consent

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time. 

If the patient is a child under the age of 18 he/she will require the consent of their parent or legal guardian to carry out the test. The parent or legal guardian will have to sign the information and consent form in relation to the child’s testing.

 

Other Uses we will make of your data:

  • Use of our service

  • To notify you about changes to our service;

  • To ensure that content from our site is presented in the most effective manner for you and for your computer; and

  • To ensure patients are administered the correct COVID-19 test and receive the correct results. 

We will use this information:

  • To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

  • To improve our website to ensure that our service is provided in the most effective manner for you;

  • As part of our efforts to keep our website safe and secure;

  • To generate reports and build statistics for Public Health England, which is a government entity;

  • To keep your medical record and communicate with you regarding your treatment or services you requested from us;

  • To process your payment;

  • To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and

  • To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process.

Cookies

Our 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. For detailed information on the cookies we use and the purposes for which we use them see our Cookie notice [Insert hyper link]

Disclosure of your information inside and outside of the UKEEA

There are certain third parties we work with to help us to delivery to you the best service we can. In order to achieve this we will share your personal information with:

Your personal data will not be provided to any third party for non-medical purposes without your written consent unless required by law.

We will disclose your personal information to third parties:

  • If we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

  • If The Express Clinic or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of service, website terms of use and other agreements; or to protect the rights, property, or safety of The Express Clinic, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store and process your personal data

The data that we collect from you is stored on cloud servers within the European Economic Area (”EEA”).   All information you provide to us is stored on these secure servers and any payment transactions are encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Data will be held in servers in Europe however may be accessed by remote staff working outside the EU, however such staff will be given appropriate training and only access to personal data as far as it is necessary to perform their roles.

On the 31 December 2020, the Brexit transition period ended. The UK awaits an adequacy decision from the European Commission, to allow transfers from the EEA to the UK without the requirement of additional safeguards. The EU-UK Trade and Cooperation Agreement contains a bridging mechanism that allows the continued free flow of personal data from the EU/EEA to the UK after the transition period until adequacy decisions come into effect, for up to 6 months. EU adequacy decisions for the UK would allow for the on-going free flow of data from the EEA to the UK. Subject to the decision made by the European Commission, this privacy policy may be updated accordingly.

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

The GDPR provides you with the following rights. To:

  • 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.

  • Request erasure

of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing. 

  • 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.

  • Request the restriction of processing

of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

  • Request the transfer

of your personal information to another party in certain formats, if practicable.

  • Make a complaint

to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/

Access to information

The Data Protection Act 2018 gives you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.

Your right of access can be exercised in accordance with the Act.

A subject access request should be submitted to our Data Protection Officer. No fee will apply as laid down by The Data Protection Act 2018.

 

Changes to our privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy notice.

Contact

We hope that we have shared with you all the information you need, but in the event that we haven’t, or if you have any questions then please do not hesitate to contact us via email at info@theexpressclinic.com