PRIVACY POLICY

Consent to installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided HERE and it is important that you read that information. 

Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in the policy, which can be found HERE.  

YES I consent to the installation of the App for the provision of services within the App. 

NO I do not consent to the installation of the App. 

How you can withdraw consent

Once you provide consent by selecting “YES”, you may change your mind and withdraw consent at any time by contacting us on info@doccoms.co.uk but that will not affect the lawfulness of any processing carried out before you withdraw your consent. 

Introduction 

This policy (together with our end-user licence agreement as set out on our website (EULA) and any additional terms of use incorporated by reference into the EULA, and our terms & conditions, together our Terms of Use) applies to your use of:

  • Doccoms mobile application software (App), which is available on our website (Website), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
  • Any of the services accessible through the App (Services) that are available on the Website. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. 
  1. Important information and who we are

RMJ Clinical Solutions Limited is the controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).

We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.

  1. Contact details

Our full details are:

  • Full name of legal entity: RMJ Clinical Solutions Limited
  • Name or title of DPO: Roseanna Jaggard
  • Email address: Roseanna@doccoms.co.uk
  • Postal address: 11 Rosaline Road, London, SW6 7QT
  • Telephone number: 020 3290 0234

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK. 

  1. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. 

This version was last updated on June 10th, 2019. It may change and if it does, these changes will be posted on this page and, where appropriate, notified when you next start the App or log onto our Website. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you. 

  1. Third party links

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

  1. The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data.
  • Contact Data.
  • Financial Data.
  • Transaction Data.
  • Device Data.
  • Content Data.
  • Profile Data.
  • Usage Data.
  • Marketing and Communications Data.
  • Location Data.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  1. How is your personal data collected?

We will collect and process the following data about you:

Information that you provide to us. This Includes personal data you provide to us when you:

  • Download our app;
  • Register with us;
  • Create a Doccoms account with us;
  • Purchaser services through our Website or App;
  • Log in to Doccoms App and use the Services;
  • Report a problem with Doccoms App or Website;
  • Request marketing to be sent to you; or
  • Provide feedback to us. 

Information we collect about you and your device. Each time you visit our Website or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.

Your Messages. Once your messages (including your chats, photographs or videos) are delivered, they are stored within the App for a period of 30 days, after which it will be transferred to our secure third-party data server, and deleted from our App. 

Information others provide about you. We may receive information about you from other users of our App and Services. For example, when other users that you know use our App and Services, they may provide your telephone number, name, and other information that relates to your medical profession. 

  1. Cookies

We use cookies to distinguish you from other users of the App, Website or the distribution platform (Appstore) and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse our Website and also allows us to improve the App and the Website. 

A cookie is a small data file that may be placed on your computer or Device to recognise you as a user when you visit the App or the Website. When you next visit the App or Website the cookie allows us to distinguish you from other users. There are two categories of cookies: (a) ‘persistent cookies’ that remain on your computer or Device until deleted manually or automatically; and (b) ‘session cookies’ which remain on your computer or Device until you close your browser, when they are automatically deleted.

We use the following cookies: –

  • Strictly Necessary Cookies – These are cookies that are required for the operation of our Website. 
  • Performance Cookies – Allows us to see and count the number of visitors on our Website and App and what they do during their visit. We use the information gathered from these cookies to improve the overall performance. The data from these cookies doesn’t allow us to identify you.

You can refuse cookies by activating settings of your chosen browser(s). Any refusal of cookies may restrict your access to the Website. 

  1. How we use your personal data

We are dedicated to helping medical professionals more effectively connect with one another. The personal data that you choose to provide to us about yourself will only be used to the extent that the law allows us to do so. Most commonly we will use your personal data in the following circumstances: 

  • Where you have consented before the processing.
  • Where we need to perform obligations under a contract we are about to enter or have entered with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation. 

Please see our Glossary to find out more about the types of lawful basis that we will rely on to process your personal data. 

We will only send you direct marketing communications by email if we have your consent. You have the right to withdraw that consent at any time by contacting us. 

  1. Purposes for which we will use your personal data

Purpose/activity 

Type of data 

Lawful basis for processing 

To install the App and register you as a new App user 

Identity

Contact 

Financial 

Device

Your consent 

To process in-App purchases and deliver Services including managing payments and collecting money owed to us 

Identity 

Contact 

Financial 

Transaction

Marketing and Communications 

Your consent

Performance of a contract with you 

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you including notifying you of changes to the App or any Services 

Identity 

Contact 

Financial 

Profile 

Marketing and Communications 

Your consent

Performance of a contract with you 

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) 

To administer and protect our business and this App including troubleshooting, data analysis and system testing

Identity 

Contact

Device 

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) 

To deliver content and advertisements to you 

To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the advertising we serve you 

To monitor trends so we can improve the App

Identity 

Contact 

Device 

Content 

Profile 

Usage 

Marketing and Communications 

Location 

Consent 

Necessary for our legitimate interests (to develop our products/Services and grow our business)

  1. Disclosures of your personal data

You share your information as you use and communicate through our Services, and we share your information to help us operate, provide, improve, understand, support, and market our Services within the NHS and Private Practice groups. To provide the Services we need to share your personal data with other users within the NHS and Private Practice group. This includes medical professionals who work within the NHS or NHS affiliated Private Practice. 

These organisations have been vetted by us to ensure that your information will be dealt with responsibly. These organisations are not permitted to use your personal information for any means other than to use it in accordance with our instructions. 

From time to time it may also be necessary to share your information with regulators, such as the Care Quality Commission, the General Medical Council, NHS Digital, the Information Commissioners Office and the Health Service Ombudsman. 

Users with whom you communicate may store or reshare your information (including your personal data and messages that were transmitted) with others on and off our Services, including patients of the NHS or Private Practice.

  1. International transfers

Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. Data security

At Doccoms we take security and the secure storage of personal data seriously. We encrypt and store all personal data on secure servers using the latest technologies. All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. 

Where personal data is stored on your Device it will be encrypted and protected by 2 factor authentication.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

  1. Data retention

The data that you provide to us in accordance with this policy will only be retained by us for as long as necessary to fulfil the purposes we collected it for. 

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 90 days then we will treat the account as expired and your personal data may be deleted. Please contact us in the event of an extended holiday, a fellowship abroad or for any other reason, which will mean you do not access Doccoms for 90 days or longer; but you would like to retain your account. 

  1. Touch ID/Fingerprint Recognition

Users may choose to use fingerprint recognition/touch ID as part of our Services when logging into the App. The data provided as part of this service is not stored as processed by Doccoms. Should Users have any concerns as to this, they should contact and/or review their relevant platform providers privacy policy. 

  1. Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data. 

Your Right of Access

You have the right to ask us for copies of your personal information. There are some exemptions, which means you may not always receive all the information we have about you. You can read more about this here (https://ico.org.uk/your-data-matters/your-right-of-access). 

Your Right to Rectification

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. You can read more about this here (https://ico.org.uk/your-data-matters/your-right-to-get-your-data-corrected).

You Right to Erasure

This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request (https://ico.org.uk/your-data-matters/your-right-to-get-your-data-deleted).

Your Right to Restriction of Processing

This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful, but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or 
  • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

(https://ico.org.uk/your-data-matters/your-right-to-limit-how-organisations-use-your-data/). 

Your Right to Object to Processing

You have the right to object to processing if we are able to process your information because the process forms part of public tasks or is in our legitimate interests. You can read more about this here (https://ico.org.uk/your-data-matters/the-right-to-object-to-the-use-of-your-data/). 

Your Right to Data Portability

This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about this here (https://ico.org.uk/your-data-matters/your-right-to-data-portability/).

Your Right to Withdraw Consent

Where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

You can exercise any of these rights at any time by contacting us at info@doccoms.co.uk. 

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us. 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Description of categories of personal data

  • Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
  • Contact Data: billing address, delivery address, email address and telephone numbers.
  • Financial Data: bank account and payment card details.
  • Transaction Data: includes details about payments to and from you and details of in-App purchases. 
  • Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and/or time zone setting. 
  • Content Data: includes information stored on your Device, including users’ lists, login information, photos, videos or other digital content, and/or check-ins. 
  • Profile Data: includes your username and password, in-App purchase history, your interests, preferences and feedback.
  • Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise [and the resources that you access.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 
  • Location Data: includes your current location disclosed by GPS technology. 
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