Bupa Instant GP Privacy Notice

Privacy Notice

We are committed to protecting your privacy when dealing with your personal information. This privacy notice provides details about the information we collect about you, and how we use and protect it. It also provides information about your rights.


Scope of this Privacy Notice

This privacy policy applies to all personal information you provide or which is generated as a result of your using this Bupa healthcare app (referred to as the "App").

This privacy notice does not apply to any information you may give to us or any other companies in the Bupa group in relation to other Bupa group services you may be receiving – you should refer to Bupa’s general Privacy Notice for more information.

This App is provided to you by Bupa Insurance Services Limited (Registered in England, number 3829851) whose registered office is at 1 Angel Court, London, EC2R 7HJ (referred to as "Bupa"). Bupa is registered with the Information Commissioner's Office, registration number Z5040072.

We provide the App to you by working alongside Babylon Healthcare Services Limited (Registered in England, number 09229684, Information Commissioner’s Office registration number ZA085885), our clinical services provider (referred to as “Babylon”), and Babylon Partners Limited (Registered in England, number 08493276). The registered office and principal place of business for both Babylon companies is 60 Sloane Avenue, London, SW3 3DD. Babylon is regulated by the UK's Care Quality Commission as a provider of remote clinical services on Bupa’s behalf, and is responsible for all clinical governance of the services provided via the App.

Bupa and Babylon are each controllers of personal information which you provide or which Bupa or Babylon receive as a result of your using the App, including your medical information. In this privacy policy Bupa and Babylon are referred to together as "we", "us" and "our".

This policy explains how we use your personal data when using this Bupa healthcare app (referred to as the “App”). We want to help you understand how we work with your data, so that you can make informed choices and be in control of your information. We invite you to spend a few moments understanding this policy. We may update this policy from time to time and we will notify you when we do so.

This policy covers:

  • What personal data we hold and how we get it;
  • What we use your personal data for;
  • Sharing your personal data;
  • Retention;
  • Data security and transfers; and
  • Your rights.

If you have any further questions about how we process your information, please don't hesitate to get in touch by contacting Babylon’s Data Protection Officer:
Address: Data Protection Officer, Babylon Health, 60 Sloane Avenue, London, SW3 3DD
Email: DPO@babylonhealth.com

We use the following categories of personal data:

Personal details
When you register with us, you complete forms and provide us with basic information about yourself, such as your name, date of birth, physical address and email address. You will also provide us with a copy of identification documentation for ID checks to be carried out by one of Babylon’s commercial partners.

Health and medical information
The main type of information we hold about you is health and medical information: information about your health, symptoms, treatments, consultations and sessions, medications and procedures. This includes details of your consultations with our doctors, and interactions with our digital services.

We get some of this information directly from you, when you register with us and when you use our healthcare services. If you have given consent for us to do so, we will send the consultation notes that we take during your use of the App to your NHS GP. Any correspondence we receive from you is uploaded electronically to your Babylon medical record.

We retain recordings of our consultations with you, in order to provide you with an easy way to re-watch your consultations where you wish to, so that we can ensure high quality care is provided to you, and, with your consent, to allow us to learn from them to improve our services. These recordings are held securely in accordance with our retention policy. You can access recordings of your consultations at any time through the App.

We may also hold information about you and your health from other apps, devices and services where you have given your consent to that data being shared with us. Examples include where you decide to share information collected from a smart watch or similar device with our App.

Financial information
If you make any payments on the App, your credit/debit card details are processed directly by a third party processor that will store all payment information and transaction details. We will only retain details of transactions on secure servers and we will not retain your credit or debit card information.

Technical information and analytics
When you use our App, we may automatically collect the following information where this is permitted by your device settings:

  • (a) technical information, including the address used to connect your mobile phone or other device to the Internet, your login information, system and operating system type and version, browser or app version, time zone setting, operating system and platform, and your location (based on IP address); and
  • (b) information about your visit, including products and services you viewed or used, App response times, interaction information (such as button presses) and any phone number used to call our customer service number.

We work with partners who provide us with analytics and advertising services (for our services only and not for third party advertising). This includes helping us understand how users interact with our services, providing our advertisements on the internet, and measuring performance of our services and our adverts. Cookies and similar technologies may be used to collect this information, such as your interactions with our services.

The purposes for which we use your personal data and the legal grounds on which we do so are as follows:

  • We obtain and use your personal details and financial details in order to establish and deliver our contract with you.
  • We obtain and use your medical information because this is necessary for medical purposes, including medical diagnosis and the provision of healthcare or treatment. This includes the information collected through our consultations with you (such as notes and recordings), our digital services. It may also include sharing information with other healthcare professionals as necessary for the provision of care to you, such as your GP (if you use our private service), specialist referral services, therapists, pharmacists, hospitals, accident and emergency services, pathology service providers, and diagnosis centres chosen by you for the purpose of imaging request forms.
  • Where you have provided your explicit consent, we will use your medical information (always having removed personal identifiers, such as your name, address and contact details) to improve our healthcare products and services, and our artificial intelligence system, so that we can deliver better healthcare to you and Babylon users. This medical information (de-identified in the way described above) may include your medical record (both records received and created by us), transcripts and recordings of your consultations, and your interactions with our artificial intelligence services, such as our symptom checker. This does not involve making any decisions about you – it is only about improving our products, services and software so that we can deliver a better experience to you and Babylon users. Strict confidentiality and data security provisions apply at all times.
  • We may obtain and use data about your precise location where you give your consent (through providing us access to your location), for example, to help direct you to the nearest pharmacy. We may also derive your approximate location from your IP address.
  • We use your email address and/or phone number to contact you with occasional updates and marketing messages where you have not opted out, based on our legitimate interest in marketing our services to you and subject to your right to opt out at any time.
  • Based on our legitimate interest in managing and planning our business, we may analyse data about your use of our products and services to, for example, troubleshoot bugs within the App, forecast demand of service and to understand other trends in use, including which features users use the most and find most helpful, and what features users require from us. This does not involve making any decisions about you – it is only about improving our App so that we can deliver better services to you. Strict confidentiality and data security provisions will apply at all times.
  • Where necessary, we may need to share personal and financial details for the purposes of fraud prevention and detection.
  • We also store your medical information, such as notes from consultations, recordings of our consultations with you and your interactions with our digital services, for safety, regulatory, and compliance purposes. For example, we may need to review your information and, where necessary, make disclosures in compliance with reasonable requests by regulatory bodies including the General Medical Council, MHRA, and Care Quality Commission, or as otherwise required by law or regulation.
  • Where necessary for safety, regulatory and/or compliance purposes, we may audit consultations and your other interactions with our services. Strict confidentiality and data security provisions will apply at all times to any such audit and access.

  • We may share your personal data with members of our corporate group and our partners. This is to help us deliver our services to you.
  • We may share your personal data with companies we have hired to provide services on our behalf, including those who act as data processors on our behalf, acting strictly under contract in accordance with Article 28 GDPR. Those data processors are bound by strict confidentiality and data security provisions, and they can only use your data in the ways specified by us.
  • We may share with our commercial partners aggregated data that does not personally identify you, but which shows general trends, for example, the number of users of our service.
  • We will, where necessary for your treatment or care, share your information with your other health and social care providers. For example, your NHS GP and other NHS bodies, specialist referral services, therapists, pharmacists, hospitals, accident and emergency services, pathology service providers, diagnosis centres chosen by you for the purpose of imaging requests, and other health and care bodies. This may include sharing information with such services for safeguarding purposes in accordance with our legal obligations.
  • We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of our services or the physical safety of any person.

Except as described above, we will never share your personal information with any other party without your consent.

We retain your medical records in accordance with national best practice guidance - in particular, advice provided by the Department of Health (2006) Records management: NHS code of practice, and summary guidance issued by the British Medical Association. The below is a summary of our retention policy, but we may retain records for other periods as required by law or regulation.

 Type of record  Retention period
 GP records  

GP Records retained for 10 years after death or after the patient has permanently left the country unless the patient remains in the European Union. In the case of a child, if the illness or death could have potential relevance to adult conditions or have genetic implications for the family of the deceased, the advice of clinicians should be sought as to whether to retain the records for a longer period.

Electronic patient records (EPRs) must not be destroyed, or deleted, for the foreseeable future.

   

 Maternity records

 25 years after the birth of the last child
   

 Records relating to persons receiving treatment for a mental disorder within the meaning of mental health legislation

 20 years after the date of the last contact; or 10 years after the patient's death if sooner

We do not store your personal health data on your mobile device. We store all your personal health data – including your primary care information, medication information and diagnostic information – on secure servers.

Where you have chosen a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

We do not store any credit or debit card information. Payments are processed via a third party payment provider that is fully compliant with Level 1 Payment Card Industry (PCI) data security standards. Any payment transactions are encrypted using SSL technology.

We encrypt data transmitted to and from the App. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Your data may be processed or stored via destinations outside the European Economic Area, but always in accordance with data protection law and subject to strict safeguards. For example, we work with third parties to use their software platforms who have servers outside the UK or EEA to send communication emails to our users.

As indicated above, whenever we rely on your consent to process your personal data, you have the right to withdraw your consent at any time by accessing the privacy settings in the App.

You also have specific rights under the GDPR and DPA to:

  • Wherever we process data based on your consent, withdraw that consent at any time. You can do this via the privacy section of our App;
  • Understand and request a copy of information we hold about you. Recordings of your appointments with us and other medical notes can be accessed via the App. For other information, you can make a request by email;
  • Ask us to rectify or erase information we hold about you, subject to limitations relating to our obligation to store medical records for prescribed periods of time;
  • Ask us to restrict our processing of your personal data or object to our processing; and
  • Ask for your data to be provided on a portable basis.

You may also contact the Information Commissioners Office (the data protection regulator in the UK): Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, telephone: 0303 123 1113 (local rate).

For any questions or concerns, you can contact us by sending an email to DPO@babylonhealth.com

Digital GP services are provided by Babylon Healthcare Services Limited.

Registered in England and Wales number: 09229684. Registered office: 60 Sloane Avenue, London SW3 3DD. Bupa health insurance is provided by Bupa Insurance Limited. Registered in England and Wales No. 3956433. Bupa Insurance Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Arranged and administered by Bupa Insurance Services Limited, which is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales No. 3829851. Registered office: 1 Angel Court, London EC2R 7HJ.

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