The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore the way this website processes, stores and protects user data and information will also be detailed within this policy.
Trulife is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this privacy statement.
Trulife may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 25/05/2018.
1. Who is processing your personal data?
1.1 Trulife, and the authorities, if required to by law
2. Who can I contact if I have any questions regarding the processing of my personal data?
2.1 Please feel free to contact the Trulife Data Protection team: [email protected]
3. What is the purpose of the processing of my personal data?
3.1 Trulife wants to stay in contact with our customers/potential customers. We do this by e.g. sending you updates, evaluations/feedback, newsletters and invitations.
4. What categories of personal data is Trulife processing about me?
4.1 Typically, we process e.g. your name, address, e-mail address and phone number.
5. With whom does the company share my data with?
5.1 Normally, Trulife does not share your personal data with anyone outside the company. However, sometimes we transfer your personal data to service providers.
6. Is my personal data transferred outside of EU?
6.1 Trulife is a global company; hence personal data will from time to time be processed in our global business environment – also outside of EU in a secure appropriate manner.
7. For how long does Trulife process my personal data?
7.1 We will process your personal data for as long as it is necessary to fulfill the purpose mentioned in section 3 and in accordance with applicable law. Or until you make us aware you do not want us to process your personal data any longer.
8. Can I lodge a complaint with a supervisory authority about Trulife’s processing of my personal data?
8.1 Yes, you can do that at any time. Please contact your local data protection agency/supervisory authority.
9. What are my rights?
9.1 You have the right to (i) get your personal data rectified and/or erased if they are incorrect, (ii) be informed about the personal data Trulife is processing about you and (iii) object to the processing of your personal data.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over the other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
If you have any questions in relation to the above please feel free to contact the Trulife Data Protection team: [email protected]
Privacy Notice for Patients
In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, as prospective patients of Trulife, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
A) DATA PROTECTION PRINCIPLES
Under GDPR, 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:
a) processing is fair, lawful and transparent
b) data is collected for specific, explicit, and legitimate purposes
c) data collected is adequate, relevant and limited to what is necessary for the purposes of processing
d) data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
e) data is not kept for longer than is necessary for its given purpose
f) 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
g) we comply with the relevant GDPR procedures for international transferring of personal data
B) TYPES OF DATA HELD
We may keep several categories of personal data on our patients in order to carry out effective and efficient processes. We keep this data within our computer systems and sometimes in hard copy, e.g. physical records such as sketches required in order to manufacture repeat products.
Specifically, we may hold the following types of data, depending on the requirements of each Trust:
a) personal details such as name, address, phone numbers, email address, date of birth, NHS number, hospital number;
b) your gender, marital status, information of any disability you have or other medical information.
C) COLLECTING YOUR DATA
Your data is usually provided to us by the NHS Trust through which you have been referred to Trulife. You may also provide further data yourself directly to Trulife employees, for example during clinical appointments.
D) LAWFUL BASIS FOR PROCESSING
The law on data protection allows us to process your data for certain reasons only.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
Activity requiring your data Lawful basis
Supplying or manufacturing orthotic or prosthetic devices Our legitimate interests
Correspondence regarding appointments and the provision of orthotic or prosthetic services Our legitimate interests
Dealing with complaints made against us Our legitimate interests
E) SPECIAL CATEGORIES OF DATA
Special categories of data are data relating to your:
b) sex life
c) sexual orientation
e) ethnic origin
f) political opinion
h) trade union membership
i) genetic and biometric data.
We may carry out processing activities using special category data:
a) for the purpose of providing appropriate medical treatment
b) to determine reasonable adjustments
Most commonly, we will process special categories of data when the following applies:
a) you have given explicit consent to the processing
b) we must process the data in order to carry out our legal obligations
c) we must process data for reasons of substantial public interest
d) you have already made the data public.
F) FAILURE TO PROVIDE DATA
Your failure to provide us with data may mean that we are unable to fulfil our requirements for providing services to you for which we have been contracted.
G) WHO WE SHARE YOUR DATA WITH
Employees within our company who have responsibility for recruitment will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR.
Data is shared with third parties for the following reason:
• manufacture of custom orthotic devices by third parties where this has been deemed appropriate by the prescribing clinician.
We may also share your data with third parties for other reasons to comply with a legal obligation upon us; for example, where a Court Order requires us to do so, or to prevent harm to you or other people. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
We do not share your data with bodies outside of the European Economic Area.
H) PROTECTING YOUR DATA
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
I) RETENTION PERIODS
We only keep your data for as long as we need it which is typically for the duration of the contract between Trulife and your NHS Trust.
At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data and there will be no consequences of withdrawing consent.
J) AUTOMATED DECISION MAKING
Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. Trulife does not use any automated decision making.
K) YOUR RIGHTS
You have the following rights in relation to the personal data we hold on you:
a) the right to be informed about the data we hold on you and what we do with it;
b) the right of access to the data we hold on you. We operate a separate Subject Access Request policy and all such requests will be dealt with accordingly;
c) the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
d) the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
e) the right to restrict the processing of the data;
f) the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
g) the right to object to the inclusion of any information;
h) the right to regulate any automated decision-making and profiling of personal data.
In addition to the above rights, you also have the unrestricted right to withdraw consent, that you have previously provided, to our processing of your data at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact our Data Protection Officer (details below).
L) MAKING A COMPLAINT
If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
M) DATA PROTECTION COMPLIANCE
Our Data Protection Officer is: