Privacy Policy and Terms of Use

Information about our organisation

At Central and North West London NHS Foundation Trust (CNWL) we are dedicated to safeguarding and preserving your privacy when visiting our site or using our services. This privacy policy explains what happens to any personal data that you provide to us, or that we collect from you.

You may access and use this website if you agree to be legally bound by the terms set out below. If you do not agree to be legally bound by those terms please do not access and/or use www.sexualhealth.cnwl.nhs.uk

This site is only intended for use by people who live in England.

CNWL makes decisions on what data is processed and how this will be done. This role is undertaken in accordance with the UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

For all requests regarding the control of your data, please contact Central and North West London NHS Foundation

Gordon Hospital
Bloomberg Street
London
SW1V 2RH
Email: heathrecords.cnwl@nhs.net

Changes to terms

We may make changes to this privacy policy at any time. Changes will be posted here and are effective immediately. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

Who manages this website?

This website is managed by Central and North West London NHS Foundation Trust (CNWL).

What information do we collect?

We collect the following information from people visiting the website:

Site usage information, using cookies and page tagging techniques
Personal and sensitive personal data:

If you submit an order for a Surrey home self-test kit, we collect personal and sensitive personal data (as described in the Data Protection Act 1998) from you.

Personal data is data that relates to an identifiable living person and can include your name, address, date of birth etc. Sensitive data can include information relating to a data subject’s race or ethnicity, political views, religious or other beliefs, physical or mental health/conditions, sexual orientation and the commission or alleged commission of an offence, or proceedings or sentence relating to offence or alleged offences.

We only collect data in response to questions we need to ask, to make sure you get the right home self-test kit or contraception, care and treatment and, information that we are required to collect for anonymous bulk reporting for health planning and monitoring. The information required for reporting is anonymous and will not identify you

CNWL collects the following information when you submit an order for a Surrey home self-test kit or online contraception:

Name
Date of birth
Post code
Address
Mobile number
Email address
Ethnicity
Country of birth
Sexual orientation.

CNWL via its partner Sevenoaks Digital Ltd. collects the following information when you submit an order for a repeat PrEP prescription, using the Online PrEP Service:

Name
Date of birth
Post code
First line of address
Mobile number
Email address
Your Sexual Health London (SHL) User ID
Clinical information pertinent to the prescription of PrEP medication

How we use your information

We use information collected from cookies and page tagging to improve the content and design of the website.

If you submit an order for a Surrey home self-test kit or online contraception:

We record your information securely in our clinical system. This information is deleted from our website after 30 days in line with data protection regulations.

When you submit an order, you are consenting to allow CNWL to share information with our third party supplier, The Doctors Laboratory Limited (TDL), who supplies our home self-test kits to you by post and carries out the testing on your returned samples. Information and results are shared through a secure link.

This information will not be processed further by TDL but will be stored securely.

As an NHS Trust, we are required to carry out anonymous bulk reporting for health planning and monitoring. These reports are anonymous and do not include any personal details.

CNWL will never share your information with other organisations for marketing, market research or commercial purposes. CNWL doesn’t pass on your personal information to any other website.

For more information about your health records, visit CNWL’s main website.

Depending on your contact preferences we may notify you by SMS or email:

Once that we have dispatched your self-sampling kit or online contraception
If you do not return your test kit promptly. This may take place up to three times
When your kit has arrived at the laboratory, and when your results are ready.
Once in the future to remind you to get tested again unless you’ve opted out.

Where you may require treatment or onward care, or in certain circumstances where our system determines you may need additional support (for example if we believe you may be at risk) our partners will make direct contact with you.

If you submit an order for Online PrEP

The information you submit to the patient form for the Online PrEP Service is held by our partner Sevenoaks Digital Ltd. for 14 days, after which it is automatically deleted. Before deletion it will be transferred to CNWL’s clinical system as part of your permanent patient record.

As it is a condition of using the Online PrEP service that you have recently completed a sexual health screen via Sexual Health London (SHL), we will ask for your SHL User ID and the PX number of your most recent sexual health screen in order to check your results on the SHL system. By providing your SHL ID and PX number, you consent for CNWL sexual health staff to check your test results. This information will not be used for any other purpose.

CNWL will never share your information with other organisations for marketing, market research or commercial purposes. CNWL does not pass on your personal information to any other website.

For more information about your health records, visit CNWL’s main website.

Depending on your contact preferences we may notify you by phone, SMS or email:

Once your request for a repeat PrEP prescription has been processed and the medication mailed out to you or is ready to collect from clinic
If we need any further information or to clarify something that you have submitted on your form that affects whether we can safely prescribe PrEP

Sharing your data with third parties

Sometimes we have a legal duty to provide personal information to other organisations.

We may also share your personal information when we consider/believe that there is a good reason to do so, which is more important than protecting your privacy. This doesn’t happen often, but in these circumstances, we may share your information:

to find and stop crime and fraud; or
if there are serious risks to the public, our staff or to other professionals.
to protect a child; or
to protect adults who are thought to be at risk, for example if they are frail, confused or cannot understand what is happening to them.

For all these reasons, the risk must be serious before we can override your right to privacy.

If we are worried about your physical safety or feel we need to take action to protect you from being harmed in other ways, we or our partners will discuss this with you and, if possible, get your permission to tell others about your situation before doing so.

We may still share your information if we believe the risk to others is serious enough to do so.

If this is the case, we will make sure that we record what information we share and our reasons for doing so. We will let you know what we have done and why, if we think it is safe to do so.

Duration of storage

Duration of storage of your patient data is as follows:

Your data is stored on our clinical system indefinitely as part of your patient record
Data you submit to access Online Testing in Surrey is stored by our partner TDL Ltd. for 28 days and then automatically deleted, prior to which it will have been transferred to your patient record on our clinical system
Data you submit to access Online contraception and Online PrEP is stored by our partner Sevenoaks Digital Ltd. for 14 days and then automatically deleted, prior to which it will have been transferred to your patient record on our clinical system

Your rights

The law gives you a number of rights in relation to what personal information is used by CNWL and how it is used. These rights allow you to:

know what information is held about you by the Trust.
provide you with a copy of the personal information that we hold about you
correct personal information about you which you think is inaccurate
delete personal information about you if you think we no longer should be using it and there is no legal reason to retain it
stop using your personal information if you think it is wrong, until it is corrected
transfer your personal information to another provider in a commonly used format
review automated decision-making processes that have been used to make decisions about you.

The right to withdraw consent and the right to erasure may not apply due to the nature of the services being provided and our basis in law for processing this data. We will consider requests to remove personal identifying information from your record to ensure that the data we do retain is anonymised, while enabling us to meet our statutory requirements.

To request any of the above, please email healthrecords.cnwl@nhs.net

You have the right to lodge a complaint with a supervisory authority. For independent advice about data protection, privacy and data sharing issues, you can contact the Information Commissioner’s Office (ICO) at http://www.ico.org.uk.

Read our Your Information Leaflet about how we share your health records

Automated decision- making

We use automated decision-making to confirm eligibility for the services you may wish to access, for example based on your geographic postcode of residence and age.

We also use automated decision making, based on national clinical guidelines, to determine whether our services are appropriate for your individual circumstance and to determine which type of test kit is most suitable for you.

If the automated decision-making process determines that you are not suitable for the service, you will be provided with information about accessing care from a physical clinic.

Cookies

Cookies are small text files that are held on your computer. We use cookies to gather information to help us improve the website.

Google Analytics is an analytics product that CNWL uses to do things such as keep track of the number of visitors to the site and the length of their stay. When you visit our website, Google Analytics will deposit the cookies on your computer to enable us to obtain this information.

The metrics obtained through the use of first-party Google Analytics cookies do not include any information that would allow CNWL to identify visitors individually to the website; the data is anonymous. The anonymised data that is collected is stored on Google’s servers.

The Google Analytics data sharing policy offers CNWL the option to share analytics data either ‘Anonymously with Google and others’ or with ‘Google products only’. UK government websites that use Google Analytics have been advised not to select either of these options. CNWL has chosen not to share the analytics data in either of these ways.

Full details on the cookies set by Google Analytics are published on the Google website. Google also publishes a browser add-on to allow you to choose that that information about your website visit is not sent to Google Analytics.

Changes to this privacy policy

We may make changes to this privacy policy at any time. Changes will be posted here and are effective immediately. You should visit this page regularly so you know:

What personal information CNWL collects
How CNWL uses your personal information
When (if ever) CNWL shares your personal information with someone else

Third party content and linking to other websites

This website contains links to other NHS and non-NHS websites. This privacy policy applies to CNWL only.

Following a link to another website

When you go to another website, read the privacy policy on that website if you want to know what it does with your information. CNWL doesn’t pass on any of your personal information to other websites.

Following a link to this site from another website

When you come to this site from another website, the Trust may get personal information about you from the other website. You should read the privacy policy of websites you visit that link you to this site if you want to know about this.

These policies will explain how they collect and use your personal information, and whether they pass this on to websites they link you to.

Third-party website content

We embed external content from third-party websites such as Youtube and Vimeo including cookies. This content is not published on our website. It is delivered using tools and services from third party sites that can be inserted into our site such as media players, RSS feeds and widgets. These websites may use cookies. Their content is subject to the privacy policy of the relevant third-party provider and not ours.

Data Protection Notice

Under the Data Protection Act, CNWL must protect any information collected from you. We use leading technologies and encryption software to protect your data, and maintain strict security standards to prevent any unauthorised access to it.

Access to your information

For a copy of any information collected about you through cookies, please email communications.cnwl@nhs.net. For a copy of information held in your health records please contact healthrecords.cnwl@nhs.net