Your privacy on the Peninsula website

 

Your privacy is important to us. This privacy policy covers what we collect and how we use, disclose, transfer and store your information.

What information do we collect when you use this website?

When you use this website, we use various technologies to collect information automatically – such as your IP address. This is commonplace across all internet services to enable the investigation of issues such as service availability and the identification of malicious use. This information is then kept in our internet access logs. 

We also collect some personal information directly – for example, when you actively submit details like your postcode to find nearby services.

How do we use the information we collect about you?

We analyse information to see what is most effective about our website and associated services to help us identify ways to improve it and to make it more effective. We may also use information for other purposes, which we would describe to you at the point when we collect the information.

Email subscriptions

If you sign up for one of our email subscription services, we will hold the information you submitted (such as your email address) for as long as we are providing you services. 

If you do not access the services provided by us, for instance you do not open or click through one of the emails for more than a year, we will send you an email asking you to confirm that you wish to continue receiving our emails. If you do not respond to this email within 1 month we will unsubscribe you.

We will remove all personal information we hold relating to you, which you registered with us, within 6 months of you unsubscribing from the site. We hold this information for a further 6 months following unsubscription, as we may need to use it for statistical analysis or if you choose to resubscribe. Be assured that if you unsubscribe you will not receive further information from us.

Third-party services    

If you turn on cookies that measure website use we may use the following services on this website:

  • New Relic provides information on how well our site is working

  • Adobe Analytics, Google Analytics and Hotjar collect information about how you use our website, to help us make it better

  • survey tools are used to ask you questions to help us make the website better. These surveys may collect both personal data and data that cannot identify you (anonymised data). You will be reminded of specific details when we collect this data and your rights under this policy and legislation are not affected

Syndication

We offer a free syndication service that enables partner organisations to pull content from the NHS website via an application programming interface (API) and display it on their website, app or service. 

In line with the syndication standard licence agreement, we require personal information of those using this service for contractual purposes. We use the data to inform subscribers of changes to functionality, structure or features within the syndicated content, or if there is a breach of the agreement. We also use subscriber's personal data to feed into internal reports, which identify active callers of the API alongside their usage.

While an active subscriber is receiving syndicated content we will continue to store their personal data. A partner can remove their own account without admin assistance via the API developer portal. Once an account has been closed by either the user or an admin, we will no longer store their data.

Cookies

Our website uses cookies. These are small files saved on your phone, tablet or computer when you visit a website. They store information about how you use the website, such as the pages you visit.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission before we can use them on your device.

General data services

 

We process and publish data in directories on NHS.UK from data aggregators and professional bodies – for example, the British Association for Counselling and Psychotherapy (BACP). This is to provide information to the public about health-related services.

Social media

 

We utilise the following social media platforms to interact with our users:

  • Facebook (incorporating Instagram)

  • YouTube

How this website collects and stores your data

 

If you choose to interact with us on social media, we may receive some personally identifiable data about you, which is supplied by the channel you are using (for example, Facebook, Twitter or YouTube). This may include:

  • name

  • social media handles (such as Twitter account name)

  • location history (where you are contacting us from)

  • images (such as your profile picture)

We will process and store your data in accordance with the terms and conditions and privacy policy of the platform in question. You should be aware that your use of these platforms is governed by the terms and conditions agreed between you and the platform, rather than this website.

We may use social media management tools (such as Hootsuite) to help deliver elements of our service to you. Any personally identifiable data processed using these tools is supplied by the platforms we use, in accordance with their terms and conditions.

We will not remove, duplicate or transfer your personal data from or between any of the social platforms that we use, except for when you give us explicit permission to do so or when we believe that we need to in order to respond to an urgent risk to health.

For example, if you interact with us in a way that raises serious concerns about your mental health, we may share your personal details with local NHS services to ensure that you are offered appropriate support.

You should be aware that social networks may control some of the data associated with interactions between you (the user) and us  on their platforms. For example, we will be able to delete our own records of a private message conversation if you request us to do so, but social networks may store a copy of this conversation that we are unable to access.

We would recommend using the privacy tools built in to the social networks in question to ensure you are able to exercise your rights appropriately.

Understanding how social networks use your data

 

Social networks use information about your online activity to build a profile of you. This data is then used (anonymously) to send you targeted adverts across various digital platforms.

You should be aware that interacting with health-related accounts such as ours may help build the profile of you that social networks maintain, and could potentially result in you receiving adverts related to health issues.

This process of collecting data for advertising purposes is not controlled by the NHS website, and we do not have access to the profiling data stored by social networks about you.

How long do we hold this information?

 

Unless otherwise stated, business information that falls under this website is held for a minimum of 3 years and will be subject to review. We will hold the information for as long as we are providing you services.

Do we share information?

  • we strive to capture the minimal amount of personal data, and only share with other organisations where the law permits us to do so or where we require and have gained your consent

  • we only share information with our authorised Data Processors for the sole purpose of processing the data in connection with the service we have procured from them. These processors must act at all times on our instructions as the Data Controller under the Data Protection legislation

  • we do not sell individuals' information

  • we host health information campaigns on behalf of Public Health England, where we are Data Processors. These campaigns may have separate privacy terms and consent requirements

  • before you submit any information, you will be informed why we are asking for specific information and it is up to you whether you provide it

How can you access, amend or withdraw the personal data you have given us?

 

To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within 1 month (subject to any extensions to which we are lawfully entitled).

*Please note that we may keep a record of your communications to help us resolve any issues that you raise.

Right to object

  • if we are using your data because we have a legal basis to do so under the Health and Social Care Act, and you do not agree, you have the right to object. We will respond to your request within the required time frame (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply

  • this right enables you to object to us processing your personal data where we do so for one of the following reasons: (i) to enable us to perform a public task or exercise official authority; (ii) to send you direct marketing communications; and (iii) for research or analytical purposes.

Right to withdraw consent

 

Where we have obtained your consent to process your personal data, or consent to send you information, you may withdraw your consent at any time and we will cease to carry out the particular activity that you previously consented to, unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.

Data access requests

 

You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. 

If we provide you with access to the information we hold about you, we will not charge you for this. If we refuse your request for any legitimate reason, we will always tell you the reasons for doing so.

 

Right to remove

 

In certain situations, you have the right to request us to "remove" your personal data. We will respond to your request within the agreed timeframe (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. 

If we do agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name on a register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data is collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.

Normally, the information must meet one of the following criteria:

  • the data is no longer necessary for the purpose for which we originally collected and/or processed it

  • where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing

  • the data has been processed unlawfully (i.e. in a manner that does not comply with existing Data Protection regulations)

  • it is necessary for the data to be deleted for us to comply with our legal obligations as a data controller

We would only be entitled to refuse to comply with your request for one of the following reasons:

  • to exercise the right of freedom of expression and information

  • to comply with legal obligations or for the performance of a public interest task or exercise of official authority

  • for public health reasons in the public interest

  • for archival, research or statistical purposes

  • to exercise or defend a legal claim. When complying with a valid request for the removal of data, we will take all reasonably practicable steps to delete the relevant data

Right to restrict processing

 

You have the right to request that we restrict our processing of your personal data in certain circumstances. 

This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important public interest.

The circumstances in which you are entitled to request that we restrict the processing of your personal data are:

  • where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified

  • where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data

  • where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it

  • where we have no further need to process your personal data but you require the data to establish, exercise or defend legal claims

If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

 

Right to rectification

 

You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. 

Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

Keeping information secure

 

We invest significant resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and so we cannot be held responsible for unauthorised or unintended access that is beyond our control.

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