First Issue: November 2023 Issue Version: 3
Purpose of Issue / Description of Change: Revised and Updated
Planned Review Date: November 2025
Named Responsible Officer: Mark Oak, Pharmacist and SIRO
Approved By: Michael Ball, Superintendent Pharmacist
Date: November 2023
1. Data Protection Principles
Under the UKGDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
- Processing is fair, lawful, and transparent.
- Data is collected for specific, explicit, and legitimate purposes.
- Data collected is adequate, relevant, and limited to what is necessary for the purposes of processing.
- Data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay.
- Data is not kept for longer than is necessary for its given purpose.
- Data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction, or damage by using appropriate technical or organisation measures.
- We comply with the relevant UKGDPR procedures for international transferring of personal data.
2. Who is responsible for managing my information?
The following organisation is responsible for managing your information and all websites operated and/or created in relation to it are owned and maintained by: –
H and AK Fletcher Limited (t/a Broadway Pharmacy) whose registered office is at 331 Garstang Road, Fulwood, Preston, PR2 9UP and whose company registered number is 01292679 (“we” or “us”).
This is our Privacy Notice, and it explains how we collect, use, share and protect your personal data.
We are responsible for the collection and proper management of any personal information you submit.
We will keep your personal details secure and use the information you provide consistently with applicable privacy and data protection laws and the terms of this Privacy Notice.
3. What information do we collect?
If you choose to arrange an appointment with us or make a query about arranging an appointment with us or in relation to the treatments, products, and services we can provide we will collect the details that you give us in relation to that appointment or query.
The information we hold is likely to include your name, age, contact details, home address, date of birth, information about your appointment, treatment, or query, medical, and health details relating to you, and any additional information we may need to help meet your specific requirements (we will be clear with you about any information we request).
We may also collect technical details of your use of our website including, but not limited to, cookies, traffic data, location data and other communication data and the resources and services that you access via the website. For further details on our use of cookies, please see our Cookies Policy.
4. How do we use your information?
The information you provide may be used in a number of ways, for example:
- to enable us to arrange or reschedule appointments with you.
- to enable us to contact you when required.
- to assess, consider, arrange, obtain, and provide treatments to you.
- to assist in diagnosis and in the recommendation of treatments and procedures suitable for you.
- to refer you to other health practitioners for treatment.
- to enable us to provide related support services.
- for statistical purposes when we evaluate our range of services.
- as may be reasonably and lawfully required in emergencies.
- to manage patient queries; and
- to help us to provide details or information you may have requested.
Information about you may also be needed for the following reasons:
- To ensure that our services meet your needs
- To assist staff to review the care that they provide and to ensure that it is of the highest standard
- To investigate complaints or legal claims
- To ensure that H and AK Fletcher t/a Broadway Pharmacy receives funding from its commissioners to pay for your care
- To prepare anonymous statistics on our performance in order to manage, improve and extend the services we are able to provide to you
- To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
- To use data analytics to improve our website, marketing, relationships and experiences
- To send you our email updates where you have requested us to do so
When information is used for statistical or financial purposes, strict measures are taken to ensure that you cannot be identified from your information. You have the right to withhold information unless the law requires us to obtain it.
5. Who will you be seen by?
Whilst in our care you will be seen by a range of health care professionals and support workers. They will keep records which may be written and/or held on computer about your health and the treatment that you receive from them.
6. On what legal basis will we process your information?
We will always process your personal information on lawful grounds and in particular on the grounds set out below:
Consent
At your specific request we may send your records to another health or medical practitioner. You can withdraw your consent at any time.
We will also obtain your consent to send you our updates via email, where you have requested us to do so.
Legal Obligation and Compliance
We may also use, process and disclose your personal data for compliance purposes, as required by any legal, regulatory, law enforcement, professional or taxation authority and to the extent that we are required to do so by law or regulation.
Performance of a Contract
We may also process your personal data in order to perform our services for you.
Legitimate Interest
We want to give you the best possible patient experience whilst respecting your privacy.
We may also use some of your personal information for statistical purposes when we evaluate our range of services.
We may also make use of your personal data to the extent required to establish, exercise, protect, enforce, or defend our legal rights and to take legal advice.
Where we process more sensitive “special category data” such as your medical records or information relating to your health, we may process your personal information on the following legal grounds:
For Medical Purposes and Pursuant to a Contract with a Health Professional
We may process your health, medical and other related records, and details where necessary for the purposes of medical diagnosis, the provision of health care or treatment, the management of health care systems and services subject to UK law and/or pursuant to your contract with us as health professionals subject to all applicable conditions and safeguards.
Explicit Consent
At your specific request we may send your records to another health or medical practitioner. You can withdraw your consent at any time.
7. Who will you share my information with?
Where necessary or required, we may share your personal information as follows:
- With third party service providers, in connection with services performed on our behalf. For example, website hosting, our email provider, our software provider, our IT provider and analytics and search engine providers that assist us in the improvement and optimisation of our website.
- With government bodies and law enforcement agencies.
- With the NHS.
- With public health authorities.
- With our insurers and legal advisers.
- With third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
This list is not exhaustive and we may use and disclose your personal data without your permission:
(a) in connection with any legal proceedings or claims or prospective legal proceedings or claims,
(b) to legal, judicial, regulatory, law enforcement, public health, governmental, professional and taxation authorities,
(c) to prevent crime;
(d) to take legal advice; and
(e) to establish, exercise, protect, enforce or defend our legal rights
8. How do you manage my information?
We may from time to time appoint other members of our group of companies, or third-party service providers, to help us manage efficient systems within the business. Some of these systems may for operational reasons be located in countries overseas including the USA.
We will only transfer your information to service providers who help manage our systems, or overseas, where we are satisfied that this is lawful and that adequate levels of protection are in place to protect the integrity and security of any information being processed and in compliance with UK data protection law.
If we transfer your personal data to service providers outside the United Kingdom, then we will always use a lawful method to do so. In the case of transfers to other countries outside the UK or the European Economic Area then this will be an agreement in a legally approved form.
9. Updating Your Details
If you would like to change any of your preferences relating to the way in which we may use your information for direct marketing, then please update your user preferences or send an email to: contact@broadway-pharmacy.co.uk or contact us at 331 Garstang Road, Fulwood, Preston, PR2 9UP.
10. How long will we hold your information for?
We have a system of retention periods in place to ensure that your information is only stored whilst it is required for the relevant purposes or to meet legal requirements. Where your information is no longer required, we will ensure it is disposed of or deleted in a secure manner.
11. Your rights
You have the right to ask us at any time:
- to confirm whether we hold any of your personal data.
- to send you a copy of any personal data that we hold about you.
- to correct any inaccuracies in your personal data and to add relevant details where the personal data we hold is incomplete.
- to delete (to the extent possible) any of your personal data, where we are required by law to do so.
- to stop processing your personal data, where we are required by law to do so.
- to let you have a portable copy of the personal data we hold about you, where we are required by law to do so.
- to stop processing any of your personal data that we process on the basis of our legitimate interests; and
- to stop sending you marketing material. However please note that we may continue to send you service related (i.e., non-marketing) communications, such as email updates relating to your treatment.
Where we have reached a decision that affects you by processing your personal data automatically then you have the right to speak to someone to discuss that decision.
We do not use your personal data for the purpose of profiling.
Where we process your personal data on the basis that you have given us your consent to do so then you may contact us at any time to withdraw your consent
If you wish to exercise any of these rights or wish to object to our use of your personal information, please write to us at the address given below.
Mark Oak, Data Protection Co-ordinator. By email to: contact@broadway-pharmacy.co.uk or write to us at 331 Garstang Road, Fulwood, Preston, PR2 9UP.
12. When do you monitor telephone calls?
We may from time-to-time record telephone calls you have with members or our staff for training purposes and to improve the quality of our service. If we plan to record any telephone call, your express consent will be sought prior to any recording. You may withdraw or not give your consent at any time.
13. How do we update this privacy notice?
We keep our privacy notice under regular review, and we will place any updates on our webpage.
14. Who can I contact if I have queries about this privacy notice?
You can also contact us directly if you have any questions about our privacy notice or information we hold about you.
Please write to us at the address given below.
Mark Oak, Data Protection Co-ordinator. By email to: contact@broadway-pharmacy.co.uk or write to us at 331 Garstang Road, Fulwood, Preston, PR2 9UP.
If you are dissatisfied with our handling of any query or complaint you also have the right to raise concerns with The UK Information Commissioner: https://ico.org.uk or at:
Customer Contact
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF
